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HomeMy WebLinkAbout13-5060 Supreme C, nnsylvania Con trno leas For Prothonotary Use Only: 1 Docket No: CST C , : ran County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: El Complaint ® Writ of Summons ® Petition S ® Transfer from Another Jurisdiction ® Declaration of Taking U Lead Plaintiff's Name: Lead Defendant's Name: C Reverse Mortgage Solutions, Inc. Sherry L. Koppenhaver; Et Al. Dollar Amount Requested: ® within arbitration limits I Are money damages requested? Yes No (check one) ®x outside arbitration limits N Is this a Class Action Suit? ® Yes M No Is this an MDJAppeal? E3 Yes 0 No I Edc,Kishbaugh Esquire A . Name of Plaintiff /Appellant's Attorney: ' " } 13 Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ® Intentional ® Buyer Plaintiff Administrative Agencies ® Malicious Prosecution ® Debt Collection: Credit Card ® Board of Assessment ® Motor Vehicle ® Debt Collection: Other ® Board of Elections © Nuisance Dept. of Transportation © Premises Liability Statutory Appeal: Other S 13 Product Liability (does not include E mass tort) [3 Employment Dispute: ® Slander/Libel/ Defamation Discrimination C ® Other: ® Employment Dispute: Other [3 Zoning Board T [3 Other: I [3 Other: O MASS TORT 13 Asbestos N © Tobacco © Toxic Tort - DES ® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other: ®Ejectment ®Common Law /Statutory Arbitration B © Eminent Domain/Condemnation ® Declaratory Judgment © Ground Rent ® Mandamus ® Landlord/Tenant Dispute ® Non- Domestic Relations El Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Commercial ® Quo Warranto ® Dental ® Partition ® Replevin ® Legal 0 Quiet Title ® Other: ® Medical [3 Other: ® Other Professional: Updated 1/1/2011 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID #310501 ELIZABETH L. WASSALL, ESQUIRE - ID #77788 'r P;:� JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 � r '' N T - NICOLE B. LABLETTA, ESQUIRE - ID #202194 -<? `' a `' DAVID NEEREN, ESQUIRE - ID #204252, JORDAN DAVID, ESQUIRE - ID #311968 WOODCREST CORPORATE CENTER x' C' 111 WOODCREST ROAD, SUITE 200 c CHERRY HILL, NJ 08003 -3620 856 669 - 5400 pleadingsAudren.com Reverse Mortgage Solutions, Inc. COURT OF 2727 Spring Creek Drive, Spring, TX 77373 COMMON PLEAS Plaintiff CIVIL DIVISION V. CUMBERLAND SHERRY L. KOPPENHAVER, PERSONAL REPRESENTATIVE OF County THE ESTATE OF FRED KOPPENHAVER A/K/A FRED J. KOPPENHAVER 350 MIDDLE ROAD, NEWVILLE, PA 17241 NO s� UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER FRED KOPPENHAVER A/K/A FRED J. KOPPENHAVER 350 MIDDLE ROAD, NEWVILLE, PA 17241 DERON H. KOPPENHAVER, KNOWN HEIR OF FRED KOPPENHAVER A/K/A FRED J. KOPPENHAVER 350 MIDDLE ROAD, NEWVILLE, PA 17241 STACIE L. SNOWDEN, KNOWN HEIR OF FRED KOPPENHAVER A/K/A FRED J. KOPPENHAVER 350 MIDDLE ROAD, NEWVILLE, PA 17241 LISA M. BARRICK, KNOWN HEIR OF FRED KOPPENHAVER A/K/A FRED J. KOPPENHAVER 350 MIDDLE ROAD, NEWVILLE, PA 17241 FRED KOPPENHAVER A/K/A FRED J. KOPPENHAVER, C/O SHERRY L. KOPPENHAVER, PERSONAL REPRESENTATIVE 350 MIDDLE ROAD, NEWVILLE, PA 17241 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 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 dafiende, la corte tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u 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 SERVICIO, VAYA . EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Genworth Financial Home Equity Access, Inc. Assignee: Reverse Mortgage Solutions, its Successors or Assigns Date of Assignment: 05/16/2011 Recorded Date: 05/27/2011 Book/Instrument #:Instrument # 201115222 Page: n/a 2. Upon information and belief Defendant(s) and/or their predecessor: Fred Koppenhaver a/k/a Fred J. Koppenhaver (hereinafter "Defendants "), are the owners of property located at 350 Middle Road, (Upper Mifflin Township), Newville, PA 17241, by virtue of Deed dated 06/16/2010 and recorded 07/14/2010 in Official Records Book Instrument # 201018885 at Page n/a of the Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property "). 3. On 06/16/2010, Defendant(s) and/or their predecessor: FRED KOPPENHAVER A/K/A FRED J. KOPPENHAVER promised to pay to the order of Genworth Financial Home Equity Access, Inc., all sums due up to the principal sum of $397,500.00 as provided in the Note, upon default or acceleration, as set forth in the Mortgage Agreement. 4. By Mortgage dated 06/16/2010, Defendant(s): FRED KOPPENHAVER A/K/A FRED J. KOPPENHAVER to secure repayment of sums due under the Note, mortgaged to Genworth Financial Home Equity Access, Inc. , the Property which is the subject of this action. The Mortgage was recorded on 07/14/2010 in Official Records Book Instrument # 201018886 at Page n/a . Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 101.9(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Grounds for acceleration of the debt exist under the Mortgage Agreement because A Borrower died and the Property is not the principal residence of at least one surviving Borrower. 6. There is a default under the Mortgage Agreement because, after notice (a copy of which is attached), the amount due to payoff the obligation secured by the mortgager has not been tendered. The following amounts are due on the said Mortgage as of the date stated below Unpaid Principal Balance $155,025.00 Accumulated Interest $31,022.301--l' 31, 022 .30 Escrow Deficit /(Reserve) $P,238.46-' Property Inspection Fee $257.00 Appraisal Fees $425.00, Attorney Fees $1,448.50 Title Report Fees $325.00 Grand Total $197,741.26 The above figures are calculated as of.08 /17/13: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 5.56000 %. The per diem interest accruing on this debt is $32.78 and that sum should be added each day after the above date. 7. Notices have been sent to Defendant(s) in accordance with the requirements of the subject Mortgage and Act 6 of 1974 and/or Act 91 of 1983, if applicable. Copies of the notices are attached hereto as Exhibit "A ". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $ 197,857.76 plus ongoing interest, costs and attorneys fees and for sale of the property premises_ UDREN LAW OFFICES, P.0 B bVI-FitV-shbaugh, Esquire PA i D 33078 VERIFICATION The undersigned states that he /she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4'904 relating to unsworn falsification to authorities. Date: Z-7- 13 Name: La Uri SM 1 - eq Title: '4 VP Company: Reverse Mortgage Solutions, Inc. MJU #: 13030124 CASE #: 13030124 -1 Exhibit A Tract # 1. All that certain tract of Iand situate in Upper Miff - M To Cumberland County, Pennsylvania, boxinded.and described as follows: BEGINNING at a railroad spike in the centerline of Township Road No. T-402, on the line of Lot No. 3 on the hereinafter mentioned plan. of lots; thence along the - latter; South 63 degrees 56 minutes thence along the same, South 41 degrees 55 minutes 00 seconds Fast, - a distance of 358.55 feet to an iron pin on the fine of Lot. No. 11 on said. plan; thence along the latter, South 48 degrees 05 minutes 00 seconds West, a distance of 322.76 feet to an-iron-pia on the line of Lot No. 9 sala .n o " plan; thence Wong the latter, 5 North 41 degrees '55 minutes 00 seconds West, Ei distance of 450.00 feet to an iron. pin; thence along the same, North 48 deg = 05 minutes 00 seconds � a distance of 522,76 feet to a railroad spike in the centerline of said T-402; thence along the latter. South 41 degrees 55 a 00 seconds East, a, distance :of 148.25 feet to a railroad spike, the place of.BEGINNING. CONTAMING 3.8845 acres according to a subdivision plan for Amon S. Stoltifus by Carl Q. Bert, M., dated October 1977 and recorded in the office of the Recorder �f Deeds for Cumberland County, Pennsylvania, in Plan Book 32, Page 18, and being designated as Lot No. 10 thereon. SUBJECT, NEVERITELESS, to the restrictions contained in prior. deed. Tract 92 All that certain tract of land situate in Upper Mifflin Toumship, Cumberland County, Pennsylvania, bounded and described as follarws: 13EGLNNING at a railroad spike in the centerline of Township Road No- T-402 an the line of Lot No. 3 on the hereinafter mentioned plan. of lots-, thence along the latter, South 6' ) degrees 56 minutes 20 seconds West, a distance of 207.91 feet, to a metal fence post; thence along the same, North 41 degrees 55 minutes 00 -seconds West, a disuince of .1-94.95 . f=t to &I iron pin on the line of Lot. No. 10 on said plan;; thence along, the latter, South 48 degrces 05 minutes 00 seconds West a-&-tance of 322.76 feet to an iron pin on the line of Lot No 9 ort said plan-, thence along the latter and Lot No. 12 on. said plan, South 41 degrees 55 minutes 00 seconds Last, a distanee of 445.07 feet to an iron piw, thence, continuing along Lot No. 12 North 48 degrees 48 ra-mitites 18 swonds a distance of 521.54 fed to a railroad spjke, in the centerline of said township road; thence along th latter, North 41 degrees I I minutes 42 seconds West a distance of 100.00 feet to a railroad spike, the Place of BEGINNING. CONTAIMING3.8952 acres according to a subdivision plan, for Aaron s, Stoltifus by Carl d. Bert R.S., dated October 1977 and recorded in the Office of the Recorder of Deeds for - Cumbarland County, Pennsylvania, in Plan Book 32, Page 18, and being designated as Lot No. I I thereon.. RM ® Reverse Mortgage Solutions, Inc. April 14, 2012 2727 Spring Creek Drive Spring, TX 77373 Sherry L Koppenhaver 350 Middle Road Newville, PA 17241 Property: 350 MIDDLE ROAD NEWVILLE, PA 17241 -8609 Loan #: Dear Sherry L Koppenhaver, We would like to extend our condolences for your loss. Thank you for keeping us informed on the status of the property. If you have not already done so, please forward a copy of the death certificate and proof of probate documents as soon as possible for our file. There will be no further advances made from the account. However, please be aware that Interest and Service Fees will continue to accrue until the mortgage is paid in full. It is in the best interest of the estate to repay the loan as soon as possible. The taxes and homeowners insurance must be current and are the responsibility of the estate. We will need the executor /administrator of the estate to provide us with the estate tax identification number for IRS reporting purposes. As of 04/14/2012, the amount required to payoff the loan balance in full by 05/14/2012 is $181,212.57. If you believe that this figure is more than the value of the property, it is your responsibility to arrange for an appraisal at your expense. We ask that you keep us informed of your efforts to sell the property, as extensions may be granted if it is determined that a good faith effort is being made to sell the property. We may consider accepting a deed -in -lieu of foreclosure provided the property is free or can be freed of any liens or encumbrances other than the Secretary-held mortgage. Should you have any questions, please feel free to contact us. Sincerely, Default Department Exhibit A Loan Skey: 40392 Page # 1 2727 Spring Creek Drive, Spring, TX 77373 Phone (866) 503 -5559 — Fax (866) 790 -3451 -- TTY /TDD (866) 827 -6697 R MS 0 Reverse Mortgage Solutions, Inc. April 14, 2012 2727 Spring Creek Drive Spring, TX 77373 REVERSE MORTGAGE REPAYMENT PROCEDURES AND TIMELINE • The reverse mortgage is due and payable when all borrowers have passed away or moved out of the property on a permanent basis. The mortgage can also be called due and payable upon approval from the Secretary of Housing and Urban Development (HUD) for Tax and /or Insurance Defaults and non - completion of required repairs. • As long as the borrower (or estate) is actively working to satisfy the debt, HUD's preliminary repayment timeline is 6 months after the borrower's Due and Payable date (or date of death). If the case warrants, Reverse Mortgage Solutions, Inc. has the right to begin foreclosure as early as 30 days from the date of this repayment demand letter. • After 6 months, HUD requires written requests for extensions every 90 days. These requests should be sent to Reverse Mortgage Solutions, Inc. 30 days before the expiration date. They should include the reason the extension is needed, the action the estate is taking to repay the loan, and any documentation supporting your claim. With the extensions, the maximum timeline for repayment is one year from the borrower's Due and Payable date (or date of death). • Reverse Mortgage Solutions, Inc. is required to begin foreclosure on Due and Payable reverse mortgages no later than one year after the date of death or default. A reverse mortgage in foreclosure can be paid off, however all expenses related to foreclosure will be added to the payoff figure. There may be a point during the foreclosure process in which a pre - foreclosure sale payoff deadline is set. Please call Reverse Mortgage Solutions, Inc. to find out if such a deadline applies. • To obtain a payoff figure, please submit a written request to our office. By mail: Reverse Mortgage Solutions, Inc. Attn: Reverse Mortgage Payoff Dept. 2727 Spring Creek Drive Spring, TX 77373 By fax: (866) 790 -3451 Loan Skey: 40392 Page # 2 2727 Spring Creek Drive, Spring, TX 77373 Phone (866) 503 -5559 — Fax (866) 790 -3451 — TTY /TDD (866) 827 -6697 �,n 1 FORM I R@ e,,c iel oA1,1t �OI� ��'tS r� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL`'ANI Plaintiff(s) Cc) vs. r - Defendants Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOStRX J 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 -4400 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 outreasonable 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. I.f you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. if you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative o; you; lender in ac. atttempt to worn out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO. SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: 0:z �So 13 Date [Signature of Counsel for Plaintiff] I Eric K shbaugh, Esquire Fib' 10 33078 FORM 2 Cumberland County .Residential Mortgage Foreclosure Diversion Program Financial. Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, .your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: C`tJST0N1ER/PR1AJ1ARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price:. $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing. Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household.: How long? FINANCIAL INFORINIATION First Mortgage Lender: Type of Loan: Loan Number.: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1.: Model: Y Amount owed: Value: Automobile #2 : Model: Y Amount owed: Value: Other transportation. (automobiles, boats motorcycles): .Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. J. 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) ET'Mortgage NSE AMOUNT EXPENSE AMOUNT aoe Food Utilities yment(s Cando/Nei Fees uto nsurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Pa. ment Cable TV Child. Su ort/Alinz. S ending Money Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: _ ,...._.... ...... ....... .. ...-- ............... ....... .__. Email: Have you made.application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or Lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I /We, , authorize the above named to use /refer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of income Past 2 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) J FORM 3 -00 5SV4 -IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. Defendant(s) C1VI:L REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to paitic.ipate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 = -_ LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 LU SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 :�o JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 WOODCREST CORPORATE CENTER 1 `= 111 WOODCREST ROAD, SUITE 200 c - CHERRY HILL, NJ 08003 - 3620,; 856 - 669 -5400 Pleadin udren.com Reverse Mortgage Solutions, Inc. COURT OF COMMON PLEAS 43252 Woodward Avenue, Suite 180, Bloomfield Hills, MI 48302 CIVIL DIVISION Plaintiff CUMBERLAND County V. Sherry L. Koppenhaver, Personal Representative of the Estate of Fred Koppenhaver a/k/a Fred J. Koppenhaver NO. 1 350 Middle Road, Newville, PA 17241 Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest from or under Fred Koppenhaver a/k/a Fred J. Koppenhaver 350 Middle Road, Newville, PA 17241 Deron H. Koppenhaver, Known Heir of Fred Koppenhaver a /k/a Fred J. Koppenhaver 350 Middle Road, Newville, PA 17241 Stacie L. Snowden, Known Heir of Fred Koppenhaver a/k/a Fred J. Koppenhaver 350 Middle Road, Newville, PA 17241 Lisa M. Barrick, Known Heir of Fred Koppenhaver a /k/a Fred J. Koppenhaver 350 Middle Road, Newville, PA 17241 Fred Koppenhaver a /k/a Fred J. Koppenhaver, c/o Sherry L. Koppenhaver, Personal Representative 350 Middle Road, Newville, PA 17241 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; and John Eric Kishbaugh, Esquire on behalf of the Plaintiff, in the above - captioned matter. UDREN LAW OFFICES, P.C. BY , " I Eric Esquire PA i D 33078 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , - ,.. ,. +d a t Sheriff T' R O i :tO N C i,. —. vo, ut at7air r,,r Jody S Smith Chief Deputy 2013 SEP 24 A 9: #, Richard W Stewart is # _ ratslf� 1,� '. 'f Solicitor o��`'E °'-" „�..,:= , PENNSYLVANIA Reverse Mortgage Solutions, Inc. Case Number vs. Sherry L. Koppenhaver(et al.) 2013-5060 SHERIFF'S RETURN OF SERVICE 09/14/2013 05:37 PM-Deputy Shawn Harrison, being duly sworn according to law, sery-• t e requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint i ' ort2age Foreclosure by "personally"handing a true copy to a person representing themselve .: the I efendant,to wit: Sherry L. Koppenhaver at 350 Middle Road, Upper Mifflin Township, Newvill- "' 724 . ? ,t9 AWN'.:RRISON, DEPUTY 09/14/2013 05:37 PM-Deputy Shawn Harrison, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the D-fendant, to wit: Fred J. Koppenhaver c/o Sherry Koppenhaver Personal Representative at 350 Middle ^•a•, Upper Mifflin Township, Newville, PA 17241. Defendant Fred J. Koppenhaver is deceased; served his wife person. 1 , S 'AWN HARRISON, DEPUTY 09/20/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Lisa M Barrick, 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 350 Middle Road, Upper Mifflin, Newville, PA 17241. Per co-defendant Sherry L. Koppenhaver, defendant is her adult daughter who has not resided at this address in many years. 09/20/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Stacie L Snowden, 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 350 Middle Road, Upper Mifflin, Newville, PA 17241. Per co-defendant Sherry L. Koppenhaver, defendant is her adult daughter who has not resided at this address in many years. 09/20/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Deron H Koppenhaver, 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 350 Middle Road, Upper Mifflin, Newville, PA 17241. Per co-defendant Sherry L. Koppenhaver, defendant is her adult step-son who has not resided at this address in many years. (c)CountySuite Shenff,Teleosoft,Inc. SHERIFF COST: $120.56 SO ANSWERS, September 20, 2013 RON(R ANDERSON, SHERIFF (c)CountySuite Sheriff.Teleosoft,Inc. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Reverse Mortgage Solutions,Inc. COURT OF COMMON PLEAS r Plaintiff ' CIVIL DIVISIONr- n : Cumberland County �,. �,, V. A c -ter+, FRED KOPPENHAVER A/K/A FRED J. C/O SHERRY L. NO. 13-5060 Civil KOPPENHAVER, PERSONAL ..<74 .o REPRESENTATIVE; et at Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: 1-1 4 1 3 UDREN LAW OFFI BY ■Ogrtild Att e s for Plaintiff David Neeren, Esquire PA ID 204252 Q ' ‘\.sT'1 Slos �a a GILt 1111 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings @udren.com Reverse Mortgage Solutions, Inc. ! COURT OF COMMON PLEAS Plaintiff ; CIVIL DIVISION v. Cumberland County FRED KOPPENHAVER A/K/A FRED J. MORTGAGE FORECLOSURE .. KOPPENHAVER,C/O SHERRY L. KOPPENHAVER,PERSONAL -.-r co REPRESENTATIVE; et al .r)s= NO. 13-5060 Civil cf3 N.) , Defendant(s) PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE ,_,:3 TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE,upon payment of your costs only. DATED: 1k) . ' ) UDREN LAW OFFICES, P.C. BY: k Atto 'Ty 7r P'intiff H• RY B. REESE SQUIRE PA ID 31.501 MJU#: 13040189 CASE#: 13040189-1 reverse mortgage SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson F LED-OFFICE Sheriff CF THE PROTHONOTARY ,0-1 g;Mliiiert Jody S Smith Chief Deputy x;. 2 f 3 NOV -' PM at v? Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Reverse Mortgage Solutions, Inc. vs. Case Number Sherry L. Koppenhaver(et al.) 2013-5060 SHERIFF'S RETURN OF SERVICE 10/03/2013 11:39 AM- Deputy Brian Grzyboski, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Lisa M Barrick at 111 Mountain Road, Lower Mifflin, Newville, PA 17241. #--31 RIAN GRZY:rd SKI, D r UTY 10/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Deron H Koppenhaver, 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 303 Sample Bridge Road, Silver Spring, Mechanicsburg, PA 17050. Deputies were advised by current resident, Keith Nieweld states he has lived here for over 20 years and has never heard of the defendant. 10/18/2013 05:52 PM- Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Mark Snowden, Husband,who accepted as"Adult Person in Charge"for Stacie L Snowden at 13 Middle Acres, Lower Mifflin, Newville, PA 17241. JAS N KIPL,ER, DEPUTY SHERIFF COST: $112.44 SO ANSWERS, October 21, 2013 RONNY R ANDERSON, SHERIFF Sherri,Teieasefi . ,.