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HomeMy WebLinkAbout13-5037 Supreme Couruof Pennsylvania Cour{ Commen Pleas For Protlronotarr E lse Onlr GIB � C o�,er �heef f . � Cumberland '" County �0i1Qt�t: - ZY The information collected 'on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR KHUN AUNG C BY MERGER TO NATIONAL CITY MORTGAGE, A LUCIA J. ROI T DIVISION OF NATIONAL CITY BANK JOHN SAILON I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO Name of Plaintifflappellant'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 ❑ Premises Liability ❑ Zoning Board ` • Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) ❑Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑Employment Dispute: Other T ❑ Other: Q MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑ Other ❑ 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 MELI,,ON INDEPENDENCE CENTER - 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413- 2311_ 4 s: x �y utaT r e WGROUP COO t : , PNC BANK, NATIONAL ASSOCIATION, SUCCES I e E , l_ ar; ; D C l�, E�COURT OF COMMON PLEAS BY MERGER TO NATIONAL CITY MORTGAGE, t� �, L �� � ti � Y ���� � � A DIVISION OF NATIONAL CITY BANK OF Cumberland COUNTY 3232 Newmark Drive Miamisburg, Ohio 45342 CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE KHUN AUNG CIVIL ACTION: M F S027 TGAGE LUCIA J. ROI PORECLO RR C// JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 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 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 AVISO 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.g_ov 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 h!Ltp://www.phfa.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.orgjforeclosure/ 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 homeretentiongkmilawgroup.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 121089FC. 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, Ohio 45342. 2. The name(s) and address(es) of the Defendant(s) is /are KHUN AUNG, 5205 Wertzville Road, Enola, PA 1.7025, LUCIA J. ROI, 5205 Wertzville Road, Enola, PA 17025 and JOHN SAILON, 5205 Wertzville Road, Enola, PA 17025, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On February 16, 2008 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on February 26, 2008 as Instrument #200805519. 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 December 01, 2012 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 05/01/201.3: Principal Balance ............................... ............................... ....................$183,514.70 Interest from 11/01/2012 to 05/01/2013 at 6.0000 % .......... ......................$5,505.42 Monthly interest rate at $917.57 LateCharges ......................................... ............................... ........................$252.39 ProRata MIP ......................................... ............................... ........................$155.50 OtherFees .............................................. ............................... .........................$27.00 AppraisalCosts ..................................... ............................... ........................$175.00 InspectionCosts ...................................... ............................... ......... .................$9.00 $189,639.01 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, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copy of such Notice attached and incorporated as Exhibit `B ". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $189,639.01, together with interest at the rate of $917.57, per month 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 Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. By: Z�Y GROUP, P.C. chll 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. 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, Justin Pierce , as a Authorized 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 unsworn falsification to authorities. Date: _AtAa1 w,+ r 5� ao 3 P M RTGAGE, A DIVISION OF PNC AN , NATIONAL ASSOCIATION N E: Justin Pierce LE: Authorized Signer #121089FC - K.HUN AUNG, LUCIA J. ROI and JOHN SAILON 5205 Wertzville Road Enola, PA 17025 hibitA Exhibit "A» Legal Description ' All that certain parcel of land situated in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania, being known and designated as Lot Igo. 5 on Plan of Lots laid out and adopted by Harriet S. Raudabaugh on March 3, 1955, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Flan Book No. 7, Page 20. Tax,Tarcel JD: I0 -14 --0840 -003 Eyhifiit(B *Exhibit has been redacted to remove all personally identifiable information or non-public information O PN C Attention: Collection Department MORTGAGE" (B6- YM07 -01 -5) 3232 Newmark Drive Miamisburg, OH 45342 _. 9yyy 8b8 0 y ?W JOHN SAILON ?1�6 900a • • • 5205 WERTUILLE RD ENOLA, PA 17025 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loan Number: 270 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 3232 Newmark Drive Miamisburg OH 45342 P.O. Box 1820 Dayton OH 45401.1820 Date: 7/10/2013 Re: Loan No. 70 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 5205 WERTZVILLE RD, ENOLA, PA 17025, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,603.61 for the months of 121112012 through 121112012, of $1,568.77 for the months of 121112012 through 61112013. Late charges and other charges have also accrued to this date in the amount of $312.39. 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 $12,897.39. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $12,897.39, 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, OH 45342. 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 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 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 ATTORNEYS 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. PNC Attention Collection Department MORTGAGE'" (B6- YM07 -01 -5) 3232 Newmark Drive Miamisburg, OH 45342 LUCIA J ROI • 5205 WERTZVILLE RD . • b8 y 0 ENOLA, PA 17025 g1y1 8 'tygb 90x8 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loan Number: 001270 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. PA002 A Division of PNC Bank, National Association T1 937 - 910 -1200 T2 800 - 822 -5626 3232 Newmark Drive Miamisburg OH 45342 P.O. Box 1820 Dayton OH 45401 -1820 Date: 7/10/2013 Re: Loan No.�270 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 5205 WERTZVILLE RD, ENOLA, PA 17025, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,603.61 for the months of 121112012 through 121112012, of $1,568.77 for the months of 121112012 through 61112013. Late charges and other charges have also accrued to this date in the amount of $312.39. 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 $12,897.39. You may cure this default within TRWTY (30) DAYS of the date of this letter, by paying to us the above amount of $12,897.39, 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, OH 45342. 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 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 how 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. t PNC Attention= Collection Department MORTGAGE`" (B6- YM07 -01 -5) 3232 Newmark Drive Miamisburg, OH 45342 JOHN SAILON - • ' • 229 MAIN ST 1 86 p5g8 NEW KENSINGTON, PA 15068 7196 9Q p8 911 • • Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loan Number.-_1270 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. PA003 A Division of PNC Bank, National Association T1 937 - 910 -1200 T2 800 -822 -5626 3232 Newmark Drive Miamisburg OH 45342 P.O. Box 1820 Dayton OH 45401 -1820 Date: 7/10/2013 Re: Loan No.�270 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 5205 WERTZVILLE RD, ENOLA, PA 17025, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,603.61 for the months of 121112012 through 121112012, of $1,568.77 for the months of 12/1/2012 through 61112013. Late charges and other charges have also accrued to this date in the amount of $312.39. 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 $12,897.39. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $12,897.39, 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, OH 45342. 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 Sheriff s 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. PN C Attention = Collection Department MORTGAGE`" (36-YM07-01 3232 Newmark Drive Miamisburg, OH 45342 . � • :b111 W b LUCIA J ROI , 229 MAIN ST NEW KENSINGTON, PA 15068 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loan Number: X1270 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. PA004 A Division of PNC Bank, National Association T1 937- 910 -1200 T2 800- 822 -5626 3232 Newmark Drive Miamisburg OH 45342 P.O. Box 1820 Dayton OH 45401 -1820 Date: 7/10/2013 Re: Loan No.1=1270 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 5205 WERTZVILLE RD, ENOLA, PA 17025, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,603.61 for the months of 12/1/2012 through 121112012, of $1,568.77 for the months of 121112012 through 61112013. Late charges and other charges have also accrued to this date in the amount of $312.39. 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 $12,897.39. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $12,897.39, 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, OH 45342. 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 Sheriff s 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. PNC Attention Collection Department MORTGAGE'" (B6- YM07 -01 -5) 3232 Newmark Drive Miamisburg, OH 45342 KHUN AUNG 5205 WERTUILLE RD ENOLA, PA 17025 ." yy Ob - • yyy eb b ' � � q qp qb � 1y Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loan Number: � 270 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. PA005 A Division of PNC Bank, National Association Ti 937 - 910 -1200 T2 800 -822 -5626 3232 Newmark Drive Miamisburg OH 45342 P.O. Box 1820 Dayton OH 45401 -1820 Date: 7/10/2013 Re: Loan No.�270 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 5205 WERTZVILLE RD, ENOLA, PA 17025, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,603.61 for the months of 121112012 through 121112012, of $1,568.77 for the months of 12/1/2012 through 61112013. Late charges and other charges have also accrued to this date in the amount of $312.39. 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 $12,897.39. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $12,897.39, 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, OH 45342. 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 niortgage. 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 Sheriff s 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. ® PN C Attention: Collection Department MORTGAGES" (B6- YM07 -01 -5) 3232 Newmark Drive Miamisburg, OH 45342 KHUN AUNG 229 MAIN STREET NEW KINSINGTON, PA 15068 0 pox 1 8684 D65 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loan Number: _1270 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. A Division of PNC Bank, National Association T1 937 - 910 -1200 T2 800 - 822 -5626 3232 Newmark Drive Miamisburg OH 45342 P.O. Box 1820 Dayton OH 45401.1820 e Date: 7/10/2013 Re: Loan No. 1270 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 5205 WERTZVILLE RD, ENOLA, PA 17025, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,603.61 for the months of 121112012 through 121112012, of $1,568.77 for the months of 12/1/2012 through 61112013. Late charges and other charges have also accrued to this date in the amount of $312.39. 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 $12,897.39. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $12,897.39, 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, OH 45342. 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 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 how 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 Sheriff s 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. 4 J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY � / Sj 3 y "' �- -�' ��. MORTGAGE, A DIVISION No. / UU ISION OF NATIONAL CITY BANK � Plaintiff' f.. vs. KHUN AUNG LUCIA J. ROI JOHN SAILON 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 submitt (Sig ture of Counsel for Plaintiff) Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Fleas 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 [J No ❑ Listing date: Price: S Realtor Larne: _ Realtor Phone: Borrower Occupied? Yes D No Mailing Address (if different): City: State° Zip: Phone Numbers: Home: Office: Cell: Other: Funa l: # of people in household.: How long? Mailing Address; City: State: , Zip: Phone Numbers: Home: Office: Cell: Other: Email: # ofpeople in household: How long? First. Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loam: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & I,nsurance: Date of Last Payment: Primary Reason for Default: is the loan in Bankruptcy? Yes E] No E] If yes, provide names, location of court, case number & attorney. Assets A mount Owed Value: Home: $ $ Other Real testate: $ $ Retirement Funds: $ Investments: $ $ Checking: - $ Savings: $� $ Other:. $ $ - Automobile #l: Model Year: Amount owed. Value: Automobile #2: Model: Year: Amount owed: Value; Other transportation. automobiles boats m iorc cles Model - year Amount owed: Value Montlrl , Income Name of Employers: I 2. I Additional Income. Description (not wages ): 1. monthly amount: 2 monthly amount: Borrower Pay Days: _ Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE ,,"4 ?UNT Mormage. Food 2 Mort a Utilities Car Pa ent s Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel /re ics Other ro . a meat Install..T,oan Pa cot Cable TV Child Su rt/Atirn. Spending Monti Ida /Child Care /Tuft. I Other Expenses Arnount Available for Monthly Mortgage Payments Based on income & Expenses: Have you been working with a Housing Counseling Agency? yes D No E if yes, please provide the following information: Counseling Agency: Counselor: Phone,(Offace): Fax,-, Email; Have you made application for Homeowners Emergency Mortgage Assistance Program _(HEMAP) assistance? Yes F] No If yes, please indicate the status of the application:_ Have you had any prior negotiations with your Lender or lender's loan servicing company to resolve your delinquency? Yes [] No If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (lame): Phone: Servicing Company (Marne): Contact. Phone: authorize the above aiamed to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. YWe understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Late Please forward this document along with the following information to lender and lender's counsel: Proof of income Past bank statements 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 . {hardship letter} Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff _ ��k��q�,, of 4rrratrcr•,���,f� �= !�!.? i �i ,!, f ,_ Jody S Smith Chief Deputy 3 OCT —4 P11i -, Richard W Stewart Solicitor P`yf�3E'�Lf'� , x. r�. r ., ;, ENu4sYL�'At,11A PNC Bank National Association vs. Case Number Khun Aung (et al.) 2013-5037 SHERIFF'S RETURN OF SERVICE 08/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lucia J. Roi, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Westmoreland, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 08/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Sailon, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Westmoreland, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 08/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Khun Aung, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Westmoreland, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 08/28/2013 10:29 AM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lucia J. Roi, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 5205 Wertzville Road, Hampden Township, Enola, PA 17025. Residence is vancant. 08/28/2013 10:29 AM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Sailon, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 5205 Wertzville Road, Hampden Township, Enola, PA 17025. Residence is vacant. 08/28/2013 10:29 AM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Khun Aung, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 5205 Wertzville Road, Hampden Township, Enola, PA 17025. Residence is vacant. 09/25/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Westmoreland County, the within named Defendant Lucia J. Roi, not found. Jonathan Held, Sheriff, Return of Service attached to and made part of the within record. 09/25/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Westmoreland County, the within named Defendant Khun Aung, not found. Jonathan Held, Sheriff, Return of Service attached to and made part of the within record. 09/25/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Westmoreland County, the within named Defendant John Sailon, not found. Jonathan Held, Sheriff, Return of Service attached to and made part of the within record. (ci Ccu.^::yau-�;r;;hait`,7r',eosofi Vin,. SHERIFF COST: $115.95 SO ANSWERS, October 01, 2013 RbNIV R ANDERSON, SHERIFF {c? CAM' Su ie Sh-art',Tefeoso"..?..,.. Ho Lt -Vo-) SHERIFF'S OFFICE OF CUMBERLAND COUNTY . Ronny R Anderson Sheriff SCAN '¢ SCAN Jody S Smith Richard W Stewart Chief Deputy Solicitor PN sBank National Association Case Number Khun Aung (et al.) 2013-5037 SERVICE COVER SHEET all S 50 N_ LO Service Details: „ o Category: Civil Action - Notice of Residential Mortgage Foreclosure Diversion Progr Zone: X Manner. Deputize (Expires: 09/25/2013 Warrant: w W.......... Notes: 0 W 0 Lo Q a oSery o: Dina` aer�r�ce Name: John Sailon Served: Personally Adult In Charge Posted Other V5 Primary 229 Main Street Adult In W Address: New Kensington, PA 15068 Charge: --- w Phone: DOB: Relation: z ✓ U w Alternate Dat . o Time: Address: r U j rn Phone: Deputy. Mileage: Z _ AttorneylOraginaator: N Name: KLM Law Group, P.C. Phone: 215-627-1322 Service Attempts: 9 Date: Time: 0 19 Mileage: M r N Deputy: Notes/Special Instructions: Sworn to and subscribed before me Notarial Notary Public �° ,?2 Deanne Torok,Notary �dayof�.W,20s.i City of Greensburg,;es noreland 21 County My CpMMIS510n Expires June il, �V!{/rRr� �.t, 1ION OF NOTARIES MEMBER,PENNSYWANIA ASSOr�A = Now, August 27, 2013 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Westmoreland Count) O to execute service of the documents herewith and make return thereof according to law. OReturn To: ESTMO LAND CO Cumberland County Sheriffs Office I G SHERIFF U) One Courthouse Square NOTARY ('��Z � Carlisle, PA 17013 Ronny R Anderson, Sheriff • TOTAL `ADVANCE REFUND C) z4- I J &j.t,� tja'1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY----- ,V ( --- Ronny R Anderson �t�'k,, t CUft.'., Sheriff A Jody S Smith `''` - Richard W Stewart Chief Deputy ;)PF C=",p_ E M-EPA$rF Solicitor PNC Bank National Association vs. C tumber Khun Aung (et al.) SERVICE CO VER SHEET O N_ SerYlCe DIIJ�:r t N CD Category: civil Action - Notice of Residential Mortgage Foreclosure Diversion Progr Zone: E _ . _ ..y _ X Manner. Deputize Cfxpires: 09/25/2013 ` Warrant: w .� Notes: 0 Ln0 0 Q a _ z Serve Tv: `" _ FiBS @� 00 g — -- Name: Lucia J. Rol Served. Personally Adult In Charge Posted Other z -- m . .-- co Primary 229 Main Street Adult In W Address: New Kensington, PA 15068 / Charge: v - Phone: DOB: Relational Z A.)j f c F.� Alternate Date: w Address: Val Time: co Phone: Deputy: Mileage: Attor»erlQrgrnt Q . . . N Name: KLM Law Group, P.C. Phone: 215-627-1322 Service Attempts . . a ,.. Date: c� �"- _1/6'.1-3 Time: J 0 Mileage: M N Deputy: f-6 Notes!Specta lrrs#Xt►�t�t�ns: nl Sworn to and subscribed before me COMMONWEALTH OF PENNSYLVANIA Notarial Seal this dayof ,20 Deanne Torok,Notary Pub 1 City of Greensburg,westrnoreland ij M Commission- resJune it,20 —_ — .� Now, August 27, 2013 I, Sheriff of umberland Countt7,1P@hff"fWfff?%W�9TuTize the Sheriff of Westmoreland Count) Q to execute service of the documents herewith and make return thereof according to law. U Return To: O Cumberland County Sheriffs Office X One Courthouse Square Carlisle, PA 17013 Ft6nny R Anderson, Sheriff LL SHERIFF'S OFFICE OF CUMBERLAND COUNTY L Ronny R Anderson 0,�� 01 61jutr•rf���� Sheriff SCAN Jody S Smith Richard W Stewart Chief Deputy Solicitor PNC Bank National Association ----- Case Numbe r'��.. vs. 1 Khun Aung (et al.) 2013-5037 0 SERVICE COVER SHEET N N Service Details: o Category: Civil Action -Notice of Residential Mortgage Foreclosure Diversion Progr Zone: X Manner. Deputize _ CExpires: 09/25/2013 Warrant: W __,.___ Notes: co co 0 Q A z Serve To: ina�� eii+lce u r (7 Name: Khun Aung Served. Personally Adult In Charge Posted Other Z _ N LAdd ry Main Street _ Adult In Z ess: New Kensington, PA 15068 Charge: - _ - Relatio o w Phone: n!-� _. DOB: _ z �� . I` Alternate ,(1� '� Date: �/ Time: w Address: u) Phone: Deputy. Mileage: f (/ Z , Attorney/Qgil►a#are .. P.C. hone: 215-62 rn Name: KLM Law Group, P. � N 7 1322 / Service Attempts - :_ 4 Date: p J3 Cl) Time: c `�D 0 Mileage: M T N Deputy: Notes 1 Special lnstructlons :. . CONiNi6iNMEAL rH OF PIEW SYLVANTA Notarial Sea! Sworn++to)' and subscribed before me Deanne Torok,Notary Public L7 this _dayof.411114k,20„1,1, City of Greensburg,We§tmoreland County M Co,, I 9n Expires tune 11,2016 — I MFMN ERy PEN111IRTRAN11A ASSOCL4T1 N OF NOTARIES Z Now, August 27, 2013 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Westmoreland Counfi = to execute service of the documents herewith and make return thereof according to law. Return To: Z Cumberland County Sheriffs Office G Q One Courthouse Square Carlisle, PA 17013 Ronny R Anderson, Sheriff KML Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPIIIA, 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, Ohio 45342 VS. KHUN AUNG LUCIA J ROI JOHN SAILON 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: Term No. 13-5037 CD r CD KML LAW GROUP, 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 E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson + ;L EJ-C" Sheriff oti��xt},at �trraLrrl� A l f1E PRO T ki-4"I 1,;-, Jody S Smith Chief Deputy 2"t114 JUN 25 PM 3: 33 Richard W Stewart CUMBERLAND OFFICE CUMBERLAND COUNTY Solicitor PENNSYLVANIA PNC Bank National Association Case Number vs. 2013-5037 Khun Aung(et al.) SHERIFF'S RETURN OF SERVICE 06/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lucia J. Roi, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 06/20/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Dauphin County, the within named Defendant Lucia J. Roi, not found. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, June 20, 2014 RbNIV R ANDERSON, SHERIFF (c)CountySuite Shen B,Teleosoft,Inc. Shelley Ruhl Jack Duignan Real Estale Deputy Chief Deputy Matthew L. Owens Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff PNC BANK,NATIONAL ASSOCIATION, Commonwealth of Pennsylvania S/B/M TO NATIONAL CITY MORTGAGE, ET AL VS County of Dauphin LUCIA J. ROI Sheriffs Return No. 201.4-T-1785 OTHER COUNTY NO. 2013-5037 1, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for LUCIA J. ROI the DEFENDANT named in the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, JUNE 18, 2014. PROPERTY MANAGER OF ADDRESS 2140 QUEENS DRIVE, HARRISBURG, PA 17110 STATED THE DEFENDANT DOES NOT RESIDE THERE. Sworn and subscribed to So Answers, before me this 19TH day of June, 2014 kAl(— Sheriff of ph'n Co COMMONWEALTH OF PENNSYLVANIA Deputy Sheriff NOTARIAL SEAL Deputy: W CONWAY Karen M.Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $47.25 6/16/2014 My Commission Expires January 8,2018 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, Ohio 45342 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: Term No. 13-5037 KML LAW GROUP, 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 E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 ___c )<_,Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff CD , --(CD CD -2-?os3? 214 ?no?S SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson s ' L Sheriff H PROTHONO I,,ri . �,,, ,,,w of Ealtrafrrr/,yfi Jody s smith b 1514 JUL -9 AM 9: 38 Chief Deputy PO. ..ik-. Richard W Stewart CUMBERLAND COUNTY Solicitor OFF ICE OF THE SI -F ERIFF PENNSYLVANIA *AMENDED* PNC Bank National Association vs. Khun Aung (et al.) Case Number 2013-5037 SHERIFF'S RETURN OF SERVICE 06/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lucia J. Roi, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 06/20/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in . Mortgage Foreclosure returned by the Sheriff of Dauphin County, the within named Defendant Lucia J. Roi, not found. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, June 20, 2014 (c) CounlySuito Sheriff, Teleosoft, Inc. RONR ANDERSON, SHERIFF Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy PNC BANK, NATIONAL ASSOCIATION, S/B/M TO NATIONAL CITY MORTGAGE, ET AL LUCIA J. ROI Sheriffs Return No. 2014-T-1785 OTHER COUNTY NO. 2013-5037 VS I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for LUCIA J. ROI the DEFENDANT named in the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, JUNE 18, 2014. PROPERTY MANAGER OF ADDRESS 2140 QUEENS DRIVE, APT. B3, HARRISBURG, PA 17110 STATED THE DEFENDANT DOES NOT RESIDE THERE. Sworn and subscribed to before me this 27TH day of June, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff of By De : • ty Sheriff Deputy: W CONWAY Sheriffs Costs: $47.25 6/16/2014 Mk.tivet. orf the Sitetily Shelley Ruhl Real Estale Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy PNC BANK, NATIONAL ASSOCIATION, S/B/M TO NATIONAL CITY MORTGAGE, ET AL VS LUCIA J. ROI Sheriffs Return No. 2014-T-1785 OTHER COUNTY NO. 2013-5037 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for LUCIA J. ROI the DEFENDANT named in the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, JUNE 18, 2014. PROPERTY MANAGER OF ADDRESS 2140 QUEENS DRIVE, HARRISBURG, PA 17110 STATED THE DEFENDANT DOES NOT RESIDE THERE. Sworn and subscribed to before me this 19TH day of June, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff of Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $47.25 6/16/2014 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE, OF THE; F..;14-FRIFF JUL 1 Ir`f 3t: I PENNSYLVANIA. t 1A PNC Bank National Association vs. Khun Aung (et al.) Case Number 2013-5037 SHERIFF'S RETURN OF SERVICE 07/07/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lucia J. Roi, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 5205 Wertzville Road, Hampden Township, Enola, PA 17025. Residence was found to be vacant as of August 2013. SHERIFF COST: $28.00 SO ANSWERS, July 07, 2014 RONNY R ANDERSON, SHERIFF icy CountySuite Sherif[, tele soft Inc. Jul. 25. 2014 11:20AM No 3995 IML Law Group, P.C. Suite 5000 - BNY independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff f• y r PwtJ(yJ/� 20!!! JUL 25 [J' 5:a PENNS Y LV t-0 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, Ohio 45342 vs. KHUN AUNG, LUCIA J. ROI and JOHN SAILON 5205 Wertzville Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 13-5037 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. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R,C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a mortgage upon the premises 5205 Wertzville Road, Enola, PA, 17025, hereinafter, the "mortgaged premises". 2. Defendants, KIJUN AUNG, LUCIA J. ROI and JOHN SAILON, are the mortgagors and real owners of the mortgaged premises. 3. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 2083(a)(9),1, Alyk Oflazian, Esquire hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendants have obtained counsel. Moreover, clue to the nature of this motion, it was not possible to locate or contact the Defendants to request his concurrence_ 4. The last known address of Defendant, Kbun Aung ONLY is 3158 29th Street, Astoria, NY 11106 and for Defendant, Lucia 3. Rou ONLY are 2140 Queens Drive, Apt B3, Harrisburg, PA 17110 and 5205 Wertzville Road, Enola, PA 17025 and for Defendant, John Sailon ONLY is 5205 Wertzville Road, Enola, PA 17025 from our investigative searches. 5. The Sheriff has been unable to effect service of the Complaint upon Defendants, Khun Aung, Lucia J. Roi and John Sailon. Service was attempted on Defendants, Khun Aung, Lucia J. Roi and John Sailon at the mortgaged premises 5205 Wertzville Road, Enola, PA 17025. The property is vacant. Service was attempted on Defendant, Khun Aung at 3158 29th Street, Astoria, NY 11106. The return of service indicates per the current occupant, John Doe Defendant, Khun Aung is unknown at said address. Service was attempted on Defendant, Lucia J. Roi at 2140 Queens Drive, Apt B3, Harrisburg, PA 17110. The return of service indicates per the property manager Defendant, Lucia J. Roi does not reside at said address. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendants, Khun Aung, Lucia J. Roi and John Sailon. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendants, Khun Aung, Lucia J. Roi and John Sailon, by posting the premises and certified and regular mail to the Defendant's last known addresses. By: KML LAW GROUP, 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 5LA1yk Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff Affidavit of Good Faith Investigation At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 121089FC Attorney/Law Firm: KML LAW GROUP, RC Subject Name: KHUN AUNG Property Address: Street: 5205 VVertzville Road City: Enola State: PA Zip: 17025 Skip Results: Date of Birth: Last Known Address (as of 5/22/2014) Street: 3158 29Th St City: Astoria State: NY ProVest File Number 3988766 Zip: 11106 3339 Death Record Search As of 05/22/2014, the Social Security Administration has no death record on file for Khun Aung. Social Security Number [X] Verifed [] Not Verified SSNt Employment Search During a search for employment of our defendant no employment information was provided prior to the investigation or found during the investigation. Business Records Search No business records found. Creditor Header Inquiry The latest address from the credit header info is: Address: 3158 29TH ST, ASTORIA, NY 11106 3339 Department of Motor Vehicle Records Search* Unable to obtain Motor Vehicle Records in the State of Pennsylvania, Drivers License Information Search [J Govemmental**+ [] Non-governmental No records found. Professional Licenses Search No records found. Freedom Of Information Act Inquiry Made to U.S. Postal Service The following addresses were sent to the United States Postal inspector at the zip code listed with no return information to date: PO BOX 284 1 NEW YORK 1 NY 1 10150 0284 1 NEW YORK 5205 WERTZVILLE ROAD 1 ENOLA 1 PA 17025 CUMBERLAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty 'Inquiry of Relatives, Neighbors, & Friends No phone listings found for possible relatives. 516-967-8 i77 Called possible neighbor, Wendy Desarno, number has been disconnected. 718-204-2041: Called possible neighbor, Tanveer Shabbir, there was no answer_ Comments: A search of Federal Bureau of Pnsons resulted in no records for our defendant. A search of Pennsylvania Department of Corrections resulted in no records for our defendant. Our defendant was not found to be currently incarcerated searching Pennsylvania County1 Jails. A search of Philadelphia Prison Systems resulted in no records for our defendant. 717-695-0168: Called number listed to defendant; Khun Aung, number has been disconnected_ " Data not available in AL, AR, CA. HI, NH, OR, PA, VA, WA. Historical data in CO, DE, 10. IL, KY, LA. MDMA, MS, , NH. ND. SC, WV. + Data available in CO, CT, DE, FL, 10, 11, KY, LA, ME, MD, MA, Mt, MN, MS, MO, NH, NO, OH, SC, TN, TX, WV, WI, WY, The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities, Under penalties of perjury, I declare that I have read the foregoing affidavit and that the facts stated in it are true. STATE OF FLORIDA # Iv F. COUNTY OF HILLSBOROUGH Gianna Hernandez ProVest File Number 3988766 Sworn to or affirmed and signed before Provest Services LLC .(Seal) gate; © 2: a l 2-0ACk JOSHUA N. PIMENi ESL Notary Public. Stale of Fiui ex My Comm. Expires May 24, 20+ No. EE 97050 MAY 2 2014 e on this;day of ( Personally Known. ( ) Produced Printed Name of Notary Public as identification Affidavit of Good Faith Investigation At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below, The following is true and accurate representation of my investigation. Client provided information: File Number: 121089FC Attorney/Law Firm: KARL LAW GROUP, P.0 Subject Name: LUCIA J. ROI Property Address: Street: 5205 Wertzville Road City: Enola State: PA Zip: 17025 Skip Results: Date of Birth ProVest File Number: 3988766 Last Known Address (as of 5/22/2014) Street: 2140 Queens Dr Apt B3 City: Harrisburg State: PA Zip: 17110 3534 Death Record Search As of 05/22/2014, the Social Security Administration has no death record on file for Lucia J Roi. Sociat Security Number [X) Verifed [ ] Not Verified SSN/ Employment Search During a search for employment of our defendant no employment information was provided prior to the investigation or found during the Investigation. Business Records Search No business records found. Creditor Header Inquiry The latest addresses from the credit header info are: Addressl: 2140 QUEENS DR APT B3, HARRISBURG, .PA 17110 3534 Address2: 5205 WERTZVILLE RD, ENOLA, PA 17025 1260 Department of Motor Vehicle Records Search* Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Drivers License Information Search [ ] Governmental'*+ [X] Non-govemmentat No verifiable information. Professional Licenses Search No current records found. Freedom Of Information Act Inquiry Made to U.S. Postal Service The following addresses were sent to the United States Postal inspector at the zip code listed with no return information to date: PO BOX 284 I NEW YORK 1NY 110150 0284 I NEW YORK 5205 WERTZVILLE ROAD 1 ENOLA 1 PA1 170251 CUMBERLAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Inquiry of Relatives, Neighbors, & Friends No phone listings found for possible relatives. 717-732-2000: Spoke with possible neighbor, Steve Stoner, does not know defendant. Corrmments: A search of Federal Bureau of Prisons resulted in no records for our defendant, A search of Pennsylvania Department of Corrections resulted in no records for our defendant. Our defendant was not found to be currently incarcerated searching Pennsylvania County Jails. A search of Philadelphia Prison Systems resulted in no records for our defendant. 717-671-9857: Called number listed to defendant, Lucia Roi, generic answering machine answered, no message left. 717-695-0358: Called number listed to defendant, Lucia Roi, number ihas been disconnected. Data not available in AL, AR, CA, HI, NH, OR, PA, VA, WA_ '.I-istorical data in CO, DE, ID, tL, KY, LA, MD, MA, MS, MO, NH, ND, SC, WV, + Data available in CO, CT, DE. FL, ID, IL, KY, LA, ME. MD, MA, MI, MN, MS, MO. NH, ND, OH, SC, TN, TX, %4N,W, WY. The foregoing statement is true and correct, 1 understand that false statements herein are made subject to the penalties of 18 Pa.0 S.A, §4904 relating to unswom falsification to authonties- Under penalties of perjury, I declare that I have read the foregoing affidavit and that the facts stated in it are true. Gianna Hernandez ProVest File Number: STATE OF FLORIDA COUNTY OF HILLSBOROUGH MAY 22 2014 76& Sworn to or affirmed and signed before me on this day of Provest Services LLC (Seal) Date: -66 \ 2_2 \zo JOSHUA Pt MIM194TEL Notary Public, State of Florida My Ccnm. Expires May 24.2015 No EE 97050 Printed Name of Notary Public Personally Known ( ):Produced as identification Affidavit of Good Faith Investigation At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 121089FC Attorney/Law Firm: KML LAW GROUP, P.0 Subject Name: JOHN SAILON Property Address: Street: 5205 Wertzville•Road City: Enola State: PA Zip: 17025 Skip Results: Date of Birth: Last Known Address (as of 5/22/2014) Street: 5205 Wertzville Rd City: Enola State: PA ProVest File Number: 3988766 Zip: 17025 1260 Death Record Search As of 05/22/2014, the Social Security Administration has no death record on file for John Salton. Social Security Number [Xj Verifed [ j Not Verified SSNMIIIIMMI Employment Search CATHOLIC COMMUNITY OF MYANMAR Business Records Search CATHOLIC COMMUNITY OF MYANMAR 5205 Wertzville Rd, Enola, PA.17025 John Salton Principal ----- - - ---- Creditor Header Inquiry The latest address from the credit header info is: Address: 5205 WERTZVILLE RD, ENOLA, PA 17025 1260 Department of Motor Vehicle Records Search* Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Drivers License Information Search [ j Govemmental**+ [X] Non-govemmental No verifiable information. Professional Licenses Search No current records found. Freedom Of Information Act Inquiry Made to U.S. Postal Service The following addresses were sent to the United States Postal inspector at the zip code listed with no return information to date: PO BOX 284 ( NEW YORK 1 NY { 10150 0284 1 NEW YORK PO BOX 213 {GAITHERSBURG 1 MD { 20884:0213 1 MONTGOMERY 5205 WERTZVILLE ROAD 1 ENOLA 1 PA { 17025 !CUMBERLAND COUNTY. Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Inquiry of Relatives, Neighbors, & Friends 717-671-9857: Called number listed to co-defendant, Lucia Roi, generic answering machine answered, no message left. 717-732-2000: Spoke with possible neighbor, Steve Stoner, does not know defendant. Comments: . A search of Federal Bureau of Prisons resulted in no records for our defendant. A search of Pennsylvania Department of Corrections resulted in no records for our defendant. Ourdefendant was not found to be currently incarcerated searching Pennsylvania County Jails. A search of Philadelphia Prison Systems resulted in no records for our defendant. 717-695-0168: Called number listed to defendant, John.Sailon, number has been disconnected. • Data not available in AL, AR, CA, HI, NH, OR, PA, VA, WA Histoncal data in CO, DE, ID, IL, KY, LA. MD. MA, MS, MO, NH, ND, sc. WV. * (Data available in CO, CT. DE, FL, ID, IL. KY, LA, ME, MD, MA, MI, MN, MS. MQ, NH. ND, OH, SC. TN, TX, WV. WI, WY The foregoing statement is true and correct. I understand that false statements herein aremade subject to the penalties of 18 PaCSA. §4904 relating to unsworn falsification to authorities. Linder penalties of perjury, 1 declare that I have read the foregoing affidavit and that the facts stated in it are true: Glenna Hernandez ProVest He Nu Pa:west Services LLC Date: 03 ‘zzlio k •STATE OF FLORIDA COUNTY OF HILLSBOROUGH 766 Sworn to or affirmed and signed b (Seal) MI 2 2 2014 on this day of JOSHUA N, PIMENTEL clary Public. State of Florida My Comm. Expires May 24205 No. EE 97050 .N.‘sonally Known ) Produced as identification Printed Name of Notary Public SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff o-rtn�h ofCombrty !'i �l1ii(, 0 Jody S smith Chief Deputy � 2013 OCT-4 ,, � Richard W Stewart CUMBERLAND"`" `� J. Solicitor Orrlc= r �; s r,=;IF� PNC Bank National Association vs. Khun Aung (et al.) Case Number 2013-5037 SHERIFF'S RETURN OF SERVICE 08/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lucia J. Roi, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Westmoreland, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 08/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Sailon, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Westmoreland, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 08/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Khun Aung, but was unable to locate the Defendant in -the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Westmoreland, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 08/28/2013 10:29 AM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lucia J. Roi, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 5205 Wertzville Road, Hampden Township, Enola, PA 17025. Residence is vancant. 08/28/2013 10:29 AM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John Sailon, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 5205 Wertzville Road, Hampden Township, Enola, PA 17025. Residence is vacant. 08/28/2013 10:29 AM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Khun Aung, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 5205 Wertzville Road, Hampden Township, Enola, PA 17025. Residence is vacant. 09/25/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Westmoreland County, the within named Defendant Lucia J. Roi, not found. Jonathan Held, Sheriff, Return of Service attached to and made part of the within record. 09/25/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Westmoreland County, the within named Defendant Khun Aung, not found. Jonathan Held, Sheriff, Return of Service attached to and made part of the within record. 09/25/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure retumed by the Sheriff of Westmoreland County, the within named Defendant John Sailon, not found. Jonathan Held, Sheriff, Return of Service attached to and made part of the within record. fci CountySuite Short(, Tolecsoft Inc. SHERIFF COST: $115.95 October 01, 2013 (c) CcuatySUite Shentt. Teleosett. Inc. SO ANSWERS, Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY "AOil of efi)rjbei,�b OFFICE OF 114E kFF;IFF PNC Bank National Association vs. Khun Aung (et al) Case Number 2013-5037 SHERIFF'S RETURN OF SERVICE 07/07/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lucia J. Roi, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 5205 Wertzville Road, Hampden Township, Enola, PA 17025. Residence was found to be vacant as of August 2013. SHERIFF COST: $28.00 SO ANSWERS, 1 July 07, 2014 RONR ANDERSON, SHERIFF (c) CountySuilo Sheriff. Teleosof Inc. IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK; et seq. Plaintiff (Petitioner) V. KHUN AUNG; et aL Defendant (Respondent) CASE and/or DOCKET No.: 13-5037 Sheriff's Sale Date: AFFIDAVIT OF SERVICE rXCompinint fSmmnons (JOther: 1.4-14 r✓ (9 43 i(, A% , certify that 1 am eighteen years of age or dder and th�yat 1 am not aparty to the action nor an employee nor relative of a party, and that I attempted to serve KHUN AL G the above process on the' day of �) Vt,(3 20 /t. atr : y o'clocki4.2hf, at 3158 29Th St Astoria, NY 11106 3339 Manner of Service: By handing a copy to: rj An officer, partner, trustee, or registered agent of the Defendant organization who is nota plaintiff in the action` D The manager, clerk, or other person for the time being in charge of a regular place of business or activity of the Defendant organization who is not a plaintiff in the action • n An agent authorized by the Defendant organization in writing to receive service of process for it who is not a plaintiff in the action • I "I U 0 (J I By handing a copy tothe Defendant(s) By handing n copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in charge of the residence because no adult family member was found " By handing a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at which he/she resides • By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s) agent or to the person for the time being in charge thereof • By posting a copy of the original process on the most public part of the property pursuant to an order of court • Name: Relationship/Title/Position: Remarks: Description: Approximate Age Height Weight Race Sex Hair Defendant was not served because: Li Moved' t nknown Olio Answer El Vacant DOther: /. Vin Llr`Dit di ' 1) r 044 aC. C C)C-c v�l J�✓! Service was attempted on the following dates/times: 1) Commonwealth/State of /t4( 2) 3) County of PO--55afrt' Before me, the undersigned notary public, this day, personally, appeared following: ) SS: Aij (/ e-te (/'t% d tome known, who being duly swom according to law, deposes the I he y swear or affr t the facts set f r h in the foregoing Affidavit of Service are Iran and correct. J 6 gnature of Affiant) File Number: 121089FC Case ID 9:4010436 Subscribed and swom before i �[���t 2 0 2 0 V this day 0' t KAREN KANE Notary Public, State of New York No. 01KA6096127 Qualified In Nassau County Commission Expires December 04, 2015 Notary Public • Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy PNC BANK, NATIONAL ASSOCIATION, S/B/M TO NATIONAL CITY MORTGAGE, ET AL LUCIA J. ROI Sheriffs Return No. 2014-T-1785 OTHER COUNTY NO. 2013-5037 VS I, Jack Lotwick, Sheriff of the County of Dauphin, State of Permsylvania, do hereby certify and return, that I made diligent search and inquiry for LUCIA J. ROI the DEFENDANT named in the within REINSTA I ED COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, JUNE 18, 2014. PROPERTY MANAGER OF ADDRESS_ 2140 QUEENS DRIVE, APT. B3, HARRISBURG, PA 17110 STATED THE DEFENDANT DOES NOT RESIDE THERE. Sworn and subscribed to before me this 27TH day of June, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires Jany 8, 2018 So Answers, Sheriff of By De !Ity Sheriff Deputy: W CONWAY Sheriffs Costs: $47.25 6/16/2014 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, Ohio 45342" vs. KHUN AUNG, LUCIA J. ROI and JOHN SAILON 5205 Wertzville Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 13-5037 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendants, Khun Aung, Lucia J. Roi and John Sailon, which the Sheriff has been unable to personally serve upon Defendants, Khun Aung, Lucia J. Roi and John Sailon. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendants, Khun Aung, Lucia J. Roi and John Sailon, by posting the premises and certified mail and regular mail to the Defendant's last known addresses. By: KML LAW GROUP, 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 lyk Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff 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, Ohio 45342 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON 5205 Wertzville Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS of Cumberland County No. 13-5037 CERTIFICATE OF SERVICE Marlene Powers, an employee of KML Law Group, P.C., counsel for plaintiff, does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendants, Khun Aung, Lucia J. Roi and John Sailon this % day of July 05� 2014, by first class mail, postage prepaid. KHUN AUNG 5205 Wertzville Road Enola, PA 17025 LUCIA J ROI 2140 Queens Drive, Apt. B3 Harrisburg, PA 17110 UCIA J. ROI 5205 Wertzville Road Enola, PA 17025 JOHN SAILON 5205 Wertzville Road Enola, PA 17025 KHUN AUNG 3158 29th Street Astoria, NY 11106 By: KML Law Group, P.C. Marlene Powers, Legal Secretary Direct Phone: 215-825-6340 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, Ohio 45342 vs. KHUN AUNG, LUCIA J. ROI and JOHN SALON 5205 Wertzville Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 13-5037 ORDER AND NOW, this le day of 41.E 2014, upon consideration of the Plaintiffs Motion fdr Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants, Khun Aung, Lucia J. Roi and John Sailon, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants, Khun Aung, Lucia J. Roi and John Sailon, by posting a copy of the Complaint upon the premises 5205 Wertzville Road, Enola, PA, 17025, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendant's last known address at 5205 Wertzville Road, Enola, PA, 17025, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant, Khun Aung ONLY at 3158 29th Street, Astoria, NY 11106 and for Defendant, Lucia J. Roi ONLY at 2140 Queens Drive, Apt B3, Harrisburg, PA 17110 and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants, Khun Aung, Lucia J. Roi and John Sailon, by sending copies of same to Defendant, Khun Aung ONLY at 3158 29th Street, Astoria, NY 11106 and for Defendant, Lucia J. Roi ONLY at 2140 Queens Drive, Apt B3, Harrisburg, PA 17110 by certified and regular mail and by posting the premises. Service is complete upon mailing. Cop y 7/30//c/ -t?) BY CO 4 Distribution list: Michael T. McKeever, Esquire, Suite 5000 — BNY Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 KHUN AUNG, 3158 29th Street Astoria, NY 11106 LUCIA J. ROI, 5205 Wertzville Road Enola, PA 17025 JOHN SAILON, 5205 Wertzville Road Enola, PA 17025 "r KML Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF culls4 PC ANS y1Yfl COO/ PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, Ohio 45342 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13-5037 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: KML LAW GROUP, 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 E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 Jennifer Lynn Frechie Pa. ID 316160 :Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff KML UAW Groin ,-P.€; - Suite 5000 - BNS -Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff PRO 70111 ,�(lGH��� ��r 18 111 2' 22 CUNBERLAN Y IA �, PENNSYLVANIA ENNA Nlq PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, Ohio 45342 vs. KHUN AUNG, LUCIA J. ROI and JOHN SAILON Mortgagor(s) 5205 Wertzville Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CERTIFICATE OF SERVICE The undersigned, on behalf of Plaintiff, hereby certifies that on CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13-5037 he did serve upon Defendant(s) KHUN AUNG, LUCIA J. ROI and JOHN SAILON a true and correct copy of the above -captioned Complaint by certified and regular mail in accordance with the Court Order dated July 30th 2014. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. By: Respectfully submitted, KML Law Group, P.C. Nick Barone, Legal Assistant NBarone@kml l awgroup. com 215-825-6365 (Direct Phone) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i ;!©-i`) _ I- IC Sheriff I HE PRO THONO 1141A !. Jody S Smith 2tjly �� r Chief Deputy ' 1 i to: C9 Richard W Stewart ``p CUMBERLAND COUNT \ Solicitor OFF l E `�F H ERIF� PE'NNS YLVANIA PNC Bank National Association vs. Khun Aung (et al.) Case Number 2013-5037 SHERIFF'S RETURN OF SERVICE 08/12/2014 06:00 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Lucia J. Roi, pursuant to Order of Court by "Posting" the premises located at 5205 Wertzville Road, Hampden Township, Enola, PA 17025 with a true and correct copy according to law. E DIMARTLE, DEPUTY 08/12/2014 06:00 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: John Sailon, pursuant to Order of Court by "Posting" the premises located at 5205 Wertzville Road, Hampden Township, Enola, PA 17025 with a true and correct copy according to law. IE DIMARTLE, DEPUTY 08/12/2014 06:00 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Khun Aung, pursuant to Order of Court by "Posting" the premises located at 5205 Wertzville Road, Hampden Township, Enola, PA 17025 with a true and correct copy according to law. uku IE DIMARTLE, DEPUTY SHERIFF COST: $94.95 SO ANSWERS, August 14, 2014 RONNY R ANDERSON, SHERIFF (c) C,ountySuite Sheriff. Teleowit. Inc. KML LAW GROUP, P.C'. Suite 5000 — BNY Mellon 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 OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, Ohio 45342 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON (Mortgagor(s) and Record Owner(s)) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) OF THE PROTHONOTAI?; 2014 SEP 29 AN II: 02 CUHBERL PEN SYLANO COUNTY VANIA IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13-5037 PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF - UNDER Pa.R.C.P. 2352 TO THE PROTHONOTARY:' Kindly file of record the Praecipe of WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 20] 3-NPLI for Voluntary Substitution under Pa.R.C.P. 2352 due to Assignment of Mortgage and attached Statement of Material Facts in Support of Voluntary Substitution, Verification, Certification of Service. The address for the new Plaintiff is 500 Delaware Avenue, 11th Floor, Wilmington, Delaware 19801. By: KML LAW GROUP, P.0 Michael McKeever Pa. ID 61 9 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 ' Jill P. Jenkins Pa. ID 306588 AIykL. Oflazian Pa. ID 3129I2, Atto'rneys for Plaintiff . SO, vet.,t-Ort. o 5I3 Okliskk c‘. eic*--rn 39 I tV ISS1 KML LAW GROUP, P.C. Suite 5000 - BNY Mellon 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 OF NATIONAL CITY BANK 3232 Newmark Drive Miamisburg, Ohio 45342 vs. KHUN AUNG LUCIA J. ROt JOHN SAILON (Mortgagor(s) and Record Owner(s)) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13-5037 STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.R.C.P. 2352 WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1, by counsel, hereby voluntarily substitutes itself as Plaintiff in the above -captioned matter and in support thereof represents as follows: 1. The above -captioned Action of Mortgage Foreclosure relates to a property located at 5205 Wertzville Road Enola, PA 17025 ("Property"). 2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Instrument #200805519 in the Office of the Recorder of Deeds for Cumberland County. 3. The original Plaintiff in this action is PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, A DIVISION OF NATIONAL CITY BANK. _ • 4. WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST • 2013-NPL1 is the successor in interest to the Plaintiff by an assignment of mortgage recorded in land records of Cumberland County on September 10, 2014 in Instrument # 201420382 and is hereby voluntarily substituted as Plaintiff in the above -captioned matter.. Respectfully submitted; By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 5 '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 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff x_ S a Lzdnr e_.p:14.,.2/110 3 138'9."7 KML LAW GROUP, P.C. SUITE 5000 — BNY MELLON 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 OF NATIONAL CITY. BANK 3232 Newmark Drive Miamisburg, Ohio 45342 Plaintiff vs. KHUN AUNG LUCIA. J. ROI JOHN SAILON (Mortgagor(s) and Record Owner(s)) 5205 Wertzville Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE Term No. 13-5037 Doris Guzman, hereby certifies that he/she did serve true and correct copies of Praecipe for Voluntary Substitution and all supporting papers attached hereto upon Defendant, by first class mail, postage pre -paid, on KHUN AUNG 5205 Wertzville Road Enola, PA 17025 LUCIA J. ROI 5205 Wertzville Road Enola, PA 17025 JOHN SAILON 5205 Wertzville Road Enola,'PA 17025 KHUN AUNG 3158 29th Street Astoria, NY 11106 KHUN AUNG 4060 SARA DR APT 204 UNION TOWN, OH 44685 LUCIA J ROI 2140 Queens Drive, Apt. B3 Harrisburg, PA 17110 LUCIA J. ROI 4060 SARA DR APT 204 Union Town, OH 44685 JOHN SAILON 4060 Sara Dr Apt 204 Union Town, OH 44685 _ By: XML, Law Group, P.C. Doris Guzman, Legal Assistant Dguzman@kmllawgroup.com 215-825-6402 (Direct Phone) In the Court of Common Pleas of Cumberland County WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL DALE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 1 lth Floor Wilmington, DE 19801 VS. KHUN AUNG LUCIA J. ROI JOHN SAILON (Mortgagor(s) and Record Owner(s)) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT No. 13-5037 d N r*t -v LEDN -11 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 KHUN AUNG, LUCIA J. ROI and JOHN SAILON in accordance with the attached consent judgment dated 9/22/14 Assess damages as follows: Debt Interest from 8/1/2014to Date of Sale per diem at $917.57 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIF BE DUE IN THE COMPLAINT AND IS CALCULABLE AS SUM C . ' TAIN F AND NOW 9e91 - By: KML LAW GROUP, _Michael McKeever Pa. 29 _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 L Goldman Pa. 205047 _Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 34alvatore Filippello Pa. ID 313897 _Alyk L. Oflazian Pa. ID 312912 _Jennifer Lynn Frechie Pa ID 316160 Attorneys for Plaintiff $214,608.16 D AMOUNTS ALLEGED TO kI,),C11OMPLAINT. O.w`\ sllb.SD?c1 Qi edo cZw 31i Sq /I „k,,Asce axle'd� , Judgment is entered in favor of WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013- NPL1 and against KHUN AUNG, LUCIA J. ROI and JOHN SAILON in accordance •th thchent judgm dated 9/22/14 and damages assessed in the sum of $214,608.16 as per the above certifio ion. Prothonotary Rule of Civil Procedure No. 236 — Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUS 1EE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue llth Floor Wilmington, DE 19801 KHUN AUNG LUCIA J. ROI JOHN SAILON (Mortgagors and Record Owner(s)) 5205 Wertzville Road Enola, PA 17025 Plaintiff vs. Defendant(s) No. 13-5037 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 consent judgment in the above -captioned matter has been entered against you. David D. Buell Prothonotary of Cumberland Co 1 Courthouse Square Carlisle, PA 17013 Prothonotary By: Deputy 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILMINGTON SAVINGS FUND SOCIETY, FSB,DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 Plaintiff vs. NO. 13-5037 KHUN AUNG LUCIA J. ROI JOHN SAILON 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): KHUN AUNG, has a last known residence of 5205 Wertzville Road, Enola, PA 17025, 3158 29th Street, Astoria NY 11106 and 4060 Sara Dr Apt 204, Union Town OH 44685. 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 By: KML LAW GROUP, P.C. Michael McKeever Pa. 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 A Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: AUNG First Name: KHUN Middle Name: Active Duty Status As Of: Sep -24-2014 Results as of : Sep -24-2014 11:08:23 AM SCRA 3.0 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 The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Order Notification End Date Active Duty Start Date Service Component Active Duty End Date Status 1 Service Component NA This response reflects whether the individual or his/her unit has received early notification to report for active duty 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. 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: KDT9JACA8000ADO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 Plaintiff vs. KHUN AUNG LUCIA J. ROI JOHN SAILON Defendant(s) NO. 13-5037 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): LUCIA J. ROI, has a last known residence of 5205 Wertzville Road, Enola, PA 17025, 2140 Queens Drive, Apt. B3, Harrisburg PA 17110. and 4060 Sara Dr Apt 204, Union Town OH 44685. 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 J q By: � 7t KML LAW GROUP, P.C. Michael McKeever Pa. 6129 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 10 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Department of Defense Manpower Data Center Status .Report Pursuant to Service ntem (L ii ief Act Last Name: ROI First Name: LUCIA Middle Name: J. Active Duty Status As Of: Sep -24-2014 Results as of : Sep -24-2014 11:09:48 AM SCRA 3.0 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 Days 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 HisiHer Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Dale Order Notification End Date Status Service Component NA . NA 4 ' No NA This response reflects whether the individual or hisfher 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, NOM, 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. 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 Soldiersand 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: LDUATA8ABOCORBO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL 1'1 ILE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 Plaintiff vs. NO. 13-5037 KHUN AUNG LUCIA J. ROI JOHN SAILON 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/appyscra/scraHome.do) for the following individual(s): JOHN SAILON, has a last known residence of 5205 Wertzville Road, Enola, PA 17025 and 4060 Sara Dr Apt 204, Union Town OH 4468. 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 By: ft KML LAW GROUP, P.C. Michael McKeever Pa. II 5 29 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 313897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 3] 6160 Attorneys for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant to Servicernerni Civil Relief Act Last Name: SAILON First Name: JOHN Middle Name: Active Duty Status As Of: Sep -24-2014 Results as of : Sep -24-2014 11:10:54 AM SCRA 10 On Active Duty On Active Duty Status Dale Active Duly Stert 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 Days of Active Duty Status Date Active Duty Stan Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual lett active duly 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 Dale 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. 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 (NOM 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: GDVB5A8A5000GC0 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 2]5-627-1322 Attorney for Plaintiff WILMINU ION SAVINUS FUND SOCIhI'Y, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPLI 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON (Mortgagor(s) and Record owner(s)) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) ORDER FOR JUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 13-5037 Please enter Judgment in favor of WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPLI, and against KHUN AUNG, LUCIA J. ROI and JOHN SAILON in accordance with the attached consentjudgment dated 9/22/14 from the date of service of the Complaint, in the sum of $214,608.16. By: KML LAW GRO _Michael McKeever Pa. '.) 16129 _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 Salvatore Filippello Pa. ID 313897 _Alyk L. Oflazian. Pa. ID 312912 _Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK ]TILE TRUST 2013-NPLI 500 Delaware Avenue I lth Floor Wilmington, DE 19801 and that the name(s) and last known address(es) of the Defendant(s) is/are KHUN AUNG, 5205 Wertzville Road Enola, PA 17025, KHUN 3158 29th Street, Astoria NY 11106 and 4060 Sara Dr Apt 204, Union Town OH 44685, LUCIA J. ROI, 5205 Wertzville Road Enola, PA 17025, 2140 Queens Drive, Apt. B3, Harrisburg PA 17110 and 4060 Sara Dr Apt 204, Union Town OH 44685 and JOHN SAILON, 5205 Wertzville Road Enola, PA 1.702 4060 Sara Dr Ap 04, Union Town OH 44685 _ By: KML LAW GROUP, P. _Michael McKeever Pa. I I ' r 129 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 )6 Salvatore Filippello Pa. ID 313897 _A]yk L. Oflazian Pa. ID 312912 _Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance _ Interest from 11/01/2012 through 07/31/2014 Unpaid Late Charges Escrow/Impound Overdraft Property Tax Recoverable Corporate Advances AND NOW, this 13-5037/121089FC $183,514.70 $19,256.41 $444.81 $3,750.48 $1,785.01 $5,856.75 $214,608.16 By: /1 KML LAW GROUP, P Michael McKeever Pa. 29 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 ".Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff day of , 2014 damages are assessed as above. Pro Prothy WILMINGTON SAVINGS FUND.SOCIETY, FSB, DOING BUSINESS AS CHRISTIANATRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRON7F CREEK 111'LE TRUST 2013-NPL1 3232 Newmark Drive Miamisburg, Ohio 45342 Plaintiff vs. . KHUN AUNG LUCIA J. ROI JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 Defendants(s) IN THE COURT OF COMMON PLEAS CONSENT JUDGMENT of Cumberland County Term No. 13-5037 AND NOW, it is hereby stipulated and agreed by and between plaintiff, WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK l'1'1'LE TRUST 2013-NPL1 ("Plaintiff'), and Defendants, KHUN AUNG, LUCIA J. ROI and JOHN SAILON ("Defendants"), as follows: 1. The following amounts are due to Plaintiff as of July 31, 2014: Principal Balance $183,514.70 Interest at 6.00% $19,256.41 Escrow/Impound Overdraft $3,750.48 Unpaid Late Charges $444.81 Property Tax $1,785.01 Recoverable Corporate Advances $5,856.75 $214,608.16. 2. An in rem judgment is entered in favor of the Plaintiff and against the Defendants in the sum of $214,608.16 plus interest from August 01, 2014 and other costs and charges collectible under the Mortgage, and for the foreclosure and Sheriff Sale of the mortgaged property located at 5205 Wertzville Road, Enola, PA 17025. 3. Defendants retain the right to reinstate and/or payoff the mortgage in question at any time prior to a Sheriffs Sale, if any, in accordance with the mortgage documents. 4. Defendants have no defenses to this action and do not intend to interpose any answer herein and specifically waive the right to do so and any and all defenses that might otherwise have been contained therein. 5. The Defendants confirm that they are not presently, nor have been within the last 367 days, an individual on active duty with the United States military. 6. Any sums advanced by Plaintiff after the entry of this judgment in mortgage • foreclosure shall become a part of the judgment lien. 7. This Consent Judgment represents the whole agreement of the parties who, intending to be legally bound, have executed it by and through the undersigned duly authorized counsel. 8. This Consent Judgment may be executed in counterparts, each of which shall be considered an original. 9. A facsimile signature shall have the same effect as an original signature. 10' . This Stipulation is effective upon execution. Date: l Z Z ` (y RUSHMORE LOAN AS SERVICER FOR WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK 1LE TRUST 2013 NPL1 4. Plainti ff By: SENO JOHNSON Date: 4. Date: Date: 9- / Y AUNG Defendant JOHN SAILON Defe . nt LUCIA J. ROI Defendant 3 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF -'S _OFFICE OF CUMBERLAND COUNTY_ uf.ftr.A, f v vHEr•;IFF PNC Bank National Association vs. Khun Aung (et al.) Case Number 2013-5037 SHERIFF'S RETURN OF SERVICE 008/12/2014 06:00 PM - Deputy Jamie DiMartle, being duly-swr m according to!aw, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Lucia J. Roi, pursuant to Order of Court by "Posting" the premises located at 5205 Wertzville Road, Hampden Township, Enola, PA 17025 with a true and correct copy according to law. DIMARTLE, DEPUTY 08/12/2014 06:00 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage. Foreclosure upon the within named Defendant, to wit: John Sailon, pursuant to Order of Court by "Posting" the premises located at 5205 Wertzville Road, Hampden Township, Enola, PA 17025 with a true and correct copy according to law. JP\MIE DIMARTLE, DEPUTY 08/12/2014 06:00 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint. in Mortgage Foreclosure upon the within named Defendant, to wit: Khun Aung, pursuant to Order of Court by "Posting" the premises located at 5205 Wertzville Road, Hampden Township, Enola, PA 17025 with a true and correct copy according to law. SHERIFF COST: $94:95 August 14, 2014 .. .'1 <f. h•d !'z !tom` <2;1r1Ya• •'.It •ii :I.% i.w- �1J, :, I;....lJ-IY \:iLt,-i �.t! _ ::(. , j: ;;°,txl.::lC,J E ,4 C+.:." U.: SuuCI e gniN 2Nu:LU Jf IE DIMARTLE, DEPUTY • MAW (b. 010.6 -- SO ANSWERS, RONf S' R ANDERSON, SHERIFF' (c} Ctxmt}Suite Sheriff, Tcfeosoff hu. KML Law Giouli, 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, Ohio 45342 VS. KHUN AUNG, LUCIA J. ROI and JOHN SAILON Mortgagor(s) 5205 Wertzville Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CERTIFICATE OF SERVICE The undersigned, on behalf of Plaintiff, hereby certifies that on CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13-5037 he did serve upon Defendant(s) KHUN AUNG, LUCIA J. ROI and JOHN SALON a true and correct copy of the above -captioned Complaint by certified and regular mail in accordance with the Court Order dated July 30th 2014. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. By: Respectfully submitted, KML Law Group, P.C. Nick Barone, Legal Assistant NBaronelcmllawgroup.com 215-825-6365 (Direct Phone) me and Address of Sender - LAW GROUP, P.C. rE 5000 MARKET STREET _ADELPHIA, PA ) 6-1532 Check type of mail or service; Cl Certified ❑ COD ❑ Delivery Confirmation ❑ Express Mail Article Number ❑ Insured O Recorded Delivery (International) ❑ Registered O Return Receipt for Merchandise ❑ Signature Confirmation Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt Addressee (Name, Street City, State, & ZIP Ccde) _JO KHUN AUNG AUNG, KHUN 5205 Wertzvilie Road Enola, PA 17025 ro LUCIA ROI ROI, LUCIA J. 5205 Wertzvilie Road Enola, PA 17025 ro JOHN SAILON SAILON, JOHN 5205 Wertzviile Road Enola, PA 17025 • ro KHUN AUNG AUNG, KHUN 3158 29th Street Astoria, NY 11106 Postage Fee Handling Charge —TO . LUCIA ROI ROI, LUCIA J. 2140 Queens Drive, Apt. B3 Harrisburg, PA 17110 Actual Value' if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD RR Fee Fee U.S. POSTAGE» PITNEY BOWES (e14/7" -a.._ r ZIP 19106 $ 002.35° 02 1M 0001391829 AUG 14 2014 Number of Pieces ✓ Total Number of Pieces d by Sender ' ) /? Received at Post Office P:istrrrasterName r elv�ng employee) See Privacy Act Statement on Reverse orm 3877, February 2002 (Page 1 of 2) 089FC Cumberland County Sal JN AUNG, LUCIA J. ROI & JOHN SAILON Complete by Typewriter, Ink, or Ball Point Pen Print Your Documents USPS Manifest Mailing System Page 3 of 4 Page 3 Mailers Name 8, Address KML Law Group 701 Market Street Suite 5000 Philadelphia, PA 19106 Permit Number 123 MAC Ver. Number ConnectShip Progistics 6.5 Sequence Number 2419-2 Class of Mail Mixed Article Ill Piece ID Addressee Name Delivery Address ES Type Postage ES Fee Insurance Amount . Due/ Total Sender Charge 4171999991703431169581 9171999991703431169598 9171999991703431169604 9171999991703431169611 9171999991703431169628 9171999991703431169635 9171999991703431169642 9171999991703431169659 9171999991703431169666 9171999991703431169673 9171999991703431169680 9171999991703431169697 ECHEVARRIA JR., LUIS E. 3506 Dixon Avenue Bristol, PA 19007 ECHEVARRIA, JR.. LUIS E. 405 Matisse Way Williamstown. NJ 08094 1.820 ERR 1.35 C 3.30 1.820 ERR 1.35 C 3.30 Unknown Hairs ol Philip Murena, Deceased 1.820 518 Gibson Street ERR 1.35 Jermyn. PA 1: . C 3.30 ROt, LUCIA J. 2140 Queens Drive. Apt. 83 Harrisburg, PA 17110 AUNG, RHUN 3158 291k Street Astoria, NY 11106 SAILOR. JOHN 5205 Wentzville Road Engle, PA 17025 I, LUCIA J. 5205 Wertzvlte Road nota, PA 17025 AUNG, KHUN 5205 Wenzvllle Road Enols. PA 17025 HARTEIS. THOMAS 10 West King Street Apartment 302 York. PA 17401 HARTEIS, THOMAS 200 Oliver Street Hanover. PA 17331 1.820 ERR 1.35 C 3.30 1.820 ERR 1.35 C 3.30 1.820 ERR C 1.820 ERR 1.35 C 1;35.r� 3.30{1 1.820 ERR 1.35 C 3.30 1.820 ERR 1.35 C 3.30 1.820 ERR 1.35 C 3.30 HARTEIS, SHERRY 1.820 200 Oliver Street ERR 1.35 Hanover. PA 17331 C 3.30 EUOANKS ewe SHRONDA F. EUBANKS. SNRONDA 1,820 5922 North Lawrence Street ERR 1.35 Philadelphia. PA 19120 C 3.30 6.47 6.47 6.47 6.47 6.47 6.47 6.47 6.47 6.47 6.47 6.47 6.47 Page Totals 12 21.84 55.80 77.64 Cumulative Totals 36 65.52 167.40 232.92 1-,rtn•Unhnc/Rendsuite%201ive/projects/image.aspx?pd=1 8/14/2014 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 KHUN AUNG LUCIA J. ROI JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 vs. Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13-5037 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: a Amount Due Interest from 8/1/2014 to Date of Sale per Monthly diem at $917.57 (Costs to be added) `U. So 6. yD P By: C) -17 $214,608.16 KML LAW GROUP, P. Michael McKeever Pa. I 15 a 29 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 JJoshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 4o9. as i)V Salvatore Filippello Pa. ID 313897 U Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Se) LL Attorneys for Plaintiff k-4/77?4,4 /7 . . 1 •r 1 kitrq a 1 No. 13-5037 IN THE COURT OF COMMON PLEAS WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 vs. KHUN AUNG, LUCIA J. ROI and JOHN SAILON (Mortgagor(s) and Record Owner(s)) 5205 Wertzville Road Enola, PA 17025 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) KML Law Group, P.C. Attorney for Plaintiff KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 All that certain parcel of land situated in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania, being known and designated as Lot No.5 on Plan of Lots laid out and adopted by Harriet S. Raudabaugh on March 3, 1955, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book No. 7, Page 20. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Hampden Township BEING PREMISES: 5205 Wertzville Road Enola PA 17025 SOLD as the propertyof J�HN SAILON, LUCIA J. ROI, AND KHUN AoNG TAX PARCEL #lO-l4-D84U-0O3 BEING the same premises which Wayne E. Baker, Jr. And Priscilla M. Baker, Husband and Wife by deed dated 9/14/2006 and recorded in Cumberland County in Deed Book Volume 276 at Page 3484 granted and conveyed unto JOHN SAILON AND LUCIA J. ROI' HUSBAND AND WIFE AND KHUN AUNG. KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) t1F THE FILED -OFFICE HONCL orAr,; 20# SEP29 4fii1: 12 CUMBERLAND PENNSYLVA1DUPrITY IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 13-5037 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. KML LAW GROU', P.C. Michael McKeever Pa. ID 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 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff KA... Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JF t' UT.D-OFFiLL' PE PRO THONO 174 L ail! SEP 29 ALM i o CU/18E I ENNS YLV IN TITE1COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL III LE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 VS. KHUN AUNG LUCIA J. ROI JOHN SALON (Mortgagor(s) and Record Owner(s)) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 13-5037 WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUS l'hE FOR BRONZE CREEK TITLE TRUST 2013- NPL1, 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: 5205 Wertzville Road Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): KHUN AUNG 5205 Wertzville Road Enola, PA 17025 KHUN AUNG 3158 29th Street Astoria NY 11106 KHUN AUNG 4060 Sara Dr Apt 204 Union Town OH 44685 LUCIA J. ROI 5205 Wertzville Road Enola, PA 17025 LUCIA J. ROI 2140 Queens Drive, Apt. B3 Harrisburg PA 17110 LUCIA J. ROI 4060 Sara Dr Apt 204 Union Town OH 44685 JOHN SAILON 5205 Wertzville Road Enola, PA 17025 JOHN SAILON 4060 Sara Dr Apt 204 Union Town OH 44685 2. Name and address of Defendant(s) in the judgment: KHUN AUNG 5205 Wertzville Road Enola, PA 17025 KHUN AUNG 3158 29th Street Astoria NY 11106 KHUN AUNG 4060 Sara Dr Apt 204 Union Town OH 44685 LUCIA J. ROI 5205 Wertzville Road Enola, PA 17025 LUCIA J. ROI 2140 Queens Drive, Apt. B3 Harrisburg PA 17110 LUCIA J. ROI 4060 Sara Dr Apt 204 Union Town OH 44685 JOHN SAILON 5205 Wertzville Road Enola, PA 17025 JOHN SAILON 4060 Sara Dr Apt 204 Union Town OH 44685 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 • FIA CARD SERVICES NA 655 PAPERMILL ROAD NEWARK, DE 19711 CHASE BANK USA NA 200 WHITE CLAY CENTER DRIVE NEWARK, DE 19711 CHASE BANK USA NA C/O JAMES C. WARMBRODT, ESQ 436 SEVENTH AVENUE, SUITE 1400 PITTSBURGH, PA 15219 FIA CARD SERVICES NA C/O DAVID J. APOTHAKER, ESQ 520 FELLOWSHIP ROAD C306 MOUNT LAUREL, NJ 08054 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 5205 Wertzville Road Enola, PA 17025 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: /ozs- 1 By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 5 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 IC Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff I(MI, Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 13-5037 OF THE PRO THONG'-, THONG • 20I4SEP 29 01 II: CUMQERLAND COUF'TY PENNS " VS. KHUN AUNG LUCIA J. ROI JOHN SAILON' Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s Docket No. 13-5037 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: AUNG, KHUN KHUN AUNG 5205 Wertzville Road Enola, PA 17025 Your house at 5205 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $214,608.16 obtained by WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUS FEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 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: 13-5037 1. The sale will be cancelled if you pay to WILMINGTON SAVINGS FUND SOCIETY, FSB, - DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1, the back payments, late charges, costs and reasonable attorney's fees due. To find 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 find 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 find 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. 8. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosured 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 13-5037 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 homeretention@kmllawgroup.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 121089FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff t QED -OFFICE OF THE PRO THONG T};ft 2014 SEP 29 kill: 10 CUMBERLAND COUNTY fEN►. 13-5037 WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s rl IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-5037 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: ROI, LUCIA J. LUCIA J. ROI 5205 Wertzville Road Enola, PA 17025 Your house at 5205 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $214,608.16 obtained by WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 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: 13-5037 1. • The sale will be cancelled if you pay to WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 ort -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 find 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. i 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 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 Sheriff's 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 13-5037 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 PI -IFA 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 homeretention@kmllawgroup.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 121089FC. Para informacion en espanol puede communicarse con Loretta al 215-8256344. HIVIL Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s CF THE PROTH` Nl'� 2014SEP °N° r� CU�-fRE 29 b�11� 1 P . uL H ND C LVANIA THE COURT OF COMMON PLEAS of Cumberland County 13-5037 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-5037 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: SAILON, JOHN JOHN SAILON 5205 Wertzville Road Enola, PA 17025 Your house at 5205 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $214,608.16 obtained by WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 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: 13-5037 1. The sale will be cancelled if you pay to WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1, the back payments, late charges, costs and reasonable attorney's fees due. To find 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 find 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 find 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 sate never happened. 5. You have aright 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.orgifore.closure/ 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 13-5037 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 homeretention@kmllawgroup.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 121089FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KIM Law Group, P.C. Suite 5000 - BNY-Independence Center 701 Market Street Philadelphia, PA 19106-1532 (215) 627-1322 Attorney for Plaintiff WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s OF rNEPRp�I�LNU TA F; 2014 SEP 29 d: f d CUMBERLAND CUuN '- 'RtYIA 13-5037 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-5037 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: AUNG, KHUN KHUN AUNG 3158 29th Street Astoria, NY 11106 Your house at 5205 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $214,608.16 obtained by WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 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: 13-5037 1. The sale will be cancelled if you pay to WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 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 find 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 find 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. 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 13-5037 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 Horne 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 homeretention@kmllawgroup.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 12-1089FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6341. 13-5037 1. The sale will be cancelled if you pay to WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 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 find 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 find 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F 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 13-5037 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 homeretention@kmllawgroup.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 121089FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 (215) 627-1322 Attorney for Plaintiff ElLED-OFF!C'L F THE PROTHONO TAR,i. 2014 SEP 29 fill II: 1 I CUMBERLAND COUNTY o c,V 13-5037 WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, IN THE COURT OF COMMON PLEAS NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-5037 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: ROL, LUCIA J. LUCIA J. ROI 4060 Sara Dr Apt 204 Union Town, OH 44685 Your house at 5205 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $214,608.16 obtained by WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 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: 13-5037 1. The sale will be cancelled if you pay to WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 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 find 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 find 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. 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 13-5037 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 homeretention@kmllawgroup.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 121089FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 (215) 627-1322 Attorney for Plainti r'�`(©j F, he � � � I{,_`. �y0N°rA fc Zdf 1 SEP 29 ,4t1 11 CUMBERLANDC°2 N U1 13-5037 WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS. INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPLI 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s THE COURT OF COMM ON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-5037 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'SSALE OF REAL PROPERTY TO: ROI, LUCIA J. LUCIA J. ROI 2140 Queens Drive, Apt. B3 Harrisburg, PA 17110 Your house at 5205 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $214,608.16 obtained by WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 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: KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 (215) 627-1322 Attorney for Plaintiff t' iLEO-O%EIC. 0.F THE PROTHONOT1\f, - 2Q 14 SEP 29 A 1 11: 12 CUMBERLAND COUNTY ►,,ICV k I L ` P% 11 I.1 WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. KHUN AUNG LUCIA J. ROI JOHN SAILON Mortgagor(s) and Record Owner(s) 5205 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s 13-5037 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-5037 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: SAILON, JOHN JOHN SAILON 4060 Sara Dr Apt 204 Union Town, OH 44685 Your house at 5205 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $214,608.16 obtained by WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 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: 13-5037 1. The sale will be cancelled if you pay to WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 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. ff the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set asidethe 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 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. 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 13-5037 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 homeretention@kmllawgroup.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 121089FC. Para informacion en espanol- puede communicarse con Loretta al 215-825-6344. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN IT'S INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 Vs, KHUN AUNG LUCIA J. ROI JOHN SAILON WRIT OF EXECUTION NO 13-5037 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $214,608.16 L.L.: $.50 Interest FROM 8/1/2014 TO DATE OF SALE PER MONTHLY DIEM AT $917.57 Atty's Comm: Atty Paid: $506.40 Plaintiff Paid: Date: 9/29/14 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothono a Deputy REQUESTING PARTY: Name: SALVATORE FILIPPELLO, 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. 313897