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HomeMy WebLinkAbout13-6257 Supreme Cou _t of Peiuisylvania Cow 46f Go4ffi dn Pleas t I I I ' , For ProthonotaiT Use O id - G iIWC6 - vet• Sheet i . Cu nberta i � ' Count- Do :et d: �C 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 Takin E Lead Plaintiff Name: Lead Defendant's Name: C LAKEVIEW LOAN SERVICING, LLC PETER J. CHRISTMAS T I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Ch eck 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 5 ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Employment dispute: ❑ Statutory Appeal: Other 1 mass tort) Discrimination C ❑ Slander/Libel Defamation ❑ Other ❑Employment Dispute: Other T ❑ Other: I 0 MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco • Toxic Tort - DES REAL PROPERTY MISCELLANEOUS • Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration $ ❑ 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.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. F! L E. � - SUITE 5000 - BNY MELLON INDEPENDENCE CENTER O F � I � E .� D � � � _ 701 MARKET STREET `' i'f ti ij i PHILADELPHIA, PA 19106 ?0`13 OCT 2 4 AN 1 [ t : 4 1 (866) 413 -2311 OCT LAKEVIEW LOAN SERVICING, LLC IN f b "L + � � � A ° bN PLEAS 4425 Ponce De Leon Boulevard MS5/125 OF Cumberland COUNTY Coral Gables, FL 33146 Plaintiff CIVIL ACTION - LAW vs. PETER J. CHRISTMAS ACTION OF MORTGAGE FORECLOSURE Mortgagor(s) and Record Owner(s) 231 Lincoln Street 231 L co 17025 "' iVIL ® O � S v� 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 ban 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 provisions 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 SERVICO. VAYA EN PERSONA O LLAMF�n POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARAb3 7S �1I ��� AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. apUl{ �� Cwt# - 7Sv4o� l2a 0 1 19 - D3 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. 4 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 http: / /w-,vw.phfa.or.iz/ consumers /homeowners /real.aspxx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http: / /wNvw.philadelph_iafed.ora /foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretentionCokmllawaroup.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 11 718717C. 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 LAKEVIEW LOAN SERVICING, LLC, 4425 Ponce De Leon Boulevard, MS5 /125 Coral Gables, FL 33146. 2. The name(s) and address(es) of the Defendant(s) is /are PETER J. CHRISTMAS, 231 Lincoln Street, Enola , PA 17025, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On January 31, 2011 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR FAIRWAY INDEPENDENT MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on February 03, 2011 as Instrument # 201104131. The mortgage has been assigned to: LAKEVIEW LOAN SERVICING, LLC by assignment of Mortgage recorded on September 1.8, 2013 as Instrument # 201330937. 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 March 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: Principal Balance ................................ ............................... .....................$81,415.96 Interest from 02/01/2012 through 10/01/2013 at 4.7500 % . ......................$6,445.40 Monthly interest rate at $322.27 LateCharges ......................................... ............................... .........................$64.52 Escrow.................................................. ............................... ......................$3,455.91 ProRata MIP ......................................... ............................... ........................$118.06 Miscellaneous......................................................... ............................... ......$463.00 Property Preservation ............................ ............................... ........................$420.00 Reasonable Attorney's Fee .................. ............................... ............ ..........$1,300.00 $93,682.85 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. 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. 9. 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 $93,682.85, together with interest at $322.27, 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 until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: KML LAW GROUP, Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 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, Colleen Newton , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation 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: r 15,010I Colleen Newton Vice President #117187FC - PETER J. CHRISTMAS 231 Lincoln Street Enola, PA 17025 Ex,h i 6 i tA ALL THAT CERTAIN lot of ground with the, improvements thereon, erected situate in the Borough of West Fairview (now Township of East Pennsboro), Cumberland County, Pennsylvania, bounded and described . as follows. to wit: BEGINNING at a point on the north side of Lincoln: Street 15 feet, more or less, from the northeast corner of Lincoln and Third Streets; and the center of the partition wall between property No. 231 Lincoln Street and the adjoining property No. 233 Lincoln Street; thence in a northerly direction through the center of said partition wall between properties' 231 and 233 Lincoln Street 96 feet, more or less, to Abolition. Street; thence in a easterly direction along the southern . side of Abolition Street a distance of 15 feet more or less, to a point, the property now or late of Elizabeth A. Gleim; said point the extension of a line through the center of the partition wall between properties No. 231 and 229 Lincoln Street; thence in a southerly direction along the center line extended of the partition between property No. 231 Lincoln Street and property No. 229 Lincoln Street 96 feet, more or less, to the northern side of Lincoln Street, thence in a westerly direction along the northern side of Lincoln :Street.a distance of 15 feet, more or, less to a point, the place of BEGINNING. Parcel Number: 45- 17=10444405 Eyhibit(B *Exhibit has been redacted to remove allpersonally identifiable information or non-public information BANK OF AMERICA PO Box 650070 Dallas, TX 75265 -0070 Phone Number: 800 - 669 -0102 Fax Number: 972 -526 -6235 Contact: General Collections Email: DG Customer SupportCbankofamerica.com 2/25/2013 SENT BY CERTIFIED MAIL PROPERTY: 231 Lincoln Street, Enola , 17025 LOAN NO.: =6896 ORIGINAL MORTGAGEE: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR FAIRWAY INDEPENDENT MORTGAGE CORPORATION CURRENT LENDER/SERVICER: BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP / BANK OF AMERICA, N.A. TO: PETER J. CHRISTMAS 231 Lincoln Street Enola , PA 17025 NOTICE OF INTENTION TO FORECLOSE MORTGAGE under Section 403 of Penna. Act No. 6 of 1974 (READ ALL PAGES OF THIS NOTICE CAREFULLY) The MORTGAGE held by BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP and serviced by BANK OF AMERICA (hereinafter referred to as we, us, or ours) on your property described above is in SERIOUS DEFAULT because you have not made the monthly payments as noted below under (a) and /or because you have failed to comply with or perform the other provisions of the mortgage obligation, if any, as noted below under (d). Previous late charges under (b) and other charges, if any under (c) noted below, have also accrued to this date. 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 NOTED BELOW UNDER (e). (a) Monthly payment from 02/01/2012 thru 2/25/2013 (9 mos. at $642.38 /month) $5,781.42 (3 mos. at $629.32 /month) $1,887.96 (b) Late charges $39.35 (c) Additional Charges Property Inspections: $15.00 (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $7,723.73 You may cure this default within THIRTY (30) DAYS of this letter by paying to us the amount under (e) above, plus any additional monthly payments and late charges (and other charges) WHICH MAY FALL DUE DURING THIS PERIOD. Such payment must be made either by CASH, CASHIER'S CHECK, CERTIFIED CHECK OR MONEY ORDER made payable to: BANK OF AMERICA PO Box 650070 Dallas, TX 75265 -0070 If you do not cure the default with THIRTY (3 0) 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 will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, 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 Sheriffs Sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. If you have not cured the default within the thirty day period, and foreclosure proceedings have begun, you will still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late charges, 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 Sheriffs Sale could be held would be approximately THREE (3) MONTHS FROM THE DATE OF THIS LETTER. A notice of the date of Sheriffs 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: 800 - 669 -0102. 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 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 OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST.) YOU HAVE THE RIGHT TO 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. 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. Contact: General Collections Phone Number: 800 - 669 -0102 Fax Number: 972 -526 -6235 Email: :DG Customer Supportgbankofamerica.com CERTIFIED MAIL - RETURN RECEIPT REQUESTED 2 FEDERAL LAW REQUIRES US TO ADVISE YOU THAT THIS FIRM IS A DEBT COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE NUMBER. 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C r, LAKEVIEW LOAN SERVICING, LLC G�: Plaintiff ' VS. Case No. -;0 v PETER J. CHRISTMAS Defendant(s) G NOTICE OF RESIDENTIAL MORTGAGE FORECLOSE 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. Respect y submi d: . (Signature of Counse f aintiff) 10/23/2013 Date Cumberland County Residential ]Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # 13ORROWER 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 APPLICANT Borrower name(s): Property Address: City State: _ _ _ Zip Is the property for sale? Yes E No Q Lis ting date:. Price: $ Realtor lame: Realtor Phone: Borrower Occupied? Yes No ��— Mailing Address (if different): City: State: Zip: Phone Numbers: Home: 0 T ce: Cell: Other: Email: # of people in household; How long? Mailing Address; City: State: Zip: Phone Numbers: Home: Office: Ceti: Other: ......... _...... . Email; # ofpeople in household: Hove long? ':FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan. Number: mate You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Bate of Last Payment: Prirnajy Reason far Default: is the loan in Bankruptcy? Yes F No El If yas, provide names, location of court, case number & attorney: Assets A mount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: Checking: Savings: $ $ Other: $ S Automobile ri l: Model: Year: Amount owed: Value, Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motoMyclesl: Model: Year Amount owed: Value Month!y Income Name of Employers: 1. 2. I Additional Income Description (not gages ): I. monthly amount- 1 monthly amount:. Borrower Pay hays: Co- Borrower Pay nays: Morstl�ly Exuenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT E)'ENSE AMOUNT mo o F ood 2 Miort a e Utilities Car PayM. ens Condo/Nei . Fees Auto Insurance Med. not cave Auto fuel/repa Other prop, payment Install. Loan Payment Cable TV Child Su rt/Alim. Spending Mone ©ay /Child Care)Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Basest on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes D No d ] If yes, please provide the following information: Counseling Agency: Counselor: Phone,(Office): Fax: -- Email Have you made application for Homeowners Emergency Mortgage Assistance Program (14EMAP) assistance? Yes NOD, 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 Q If yes, please indicate the stags of those negotiations: Please provide the following information, if know, regarding your lender or leader's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: 11w , authorize the above named to uselrefer this information to my lendertservicer for the sale purpose of evaluating my financial situation for possible mortgage options. VWe understand that IJwe am/are under no obligation to use the services provided by the above named Borrower Signature. bate Co- Borrower Signature Tate Please forward this document along with the following information to lender and lender's counsel: Y Proof of income Last Z bank statements Y Proof of any expected income for the last 45 clays Copy of a current utility bill Y Letter explaining reason for delinquency and any supporting documentation _ j {bardship letter} Y Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson FILED—OFFICE Sheriff .,,.. r� � : yyxtiltt,ot9taratr,r� ){ g t�iCUi1r'aiill' Jody S Smith 2013 DEC _6 PH 12: 2 Chief Deputy A r Richard W Stewart r � CUMBERLAND COUNTY Solicitor OrFll or THEFHERFr PENNSYLVANIA, • Lakeview Loan Servicing, LLC Case Number vs. Peter John Christmas 2013-6257 SHERIFF'S RETURN OF SERVICE 10/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry • for the within named Defendant to wit: Peter John Christmas, 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 231 Lincoln Street, East Pennsboro, Enola, PA 17025. Residence is vacant and the Enola Postmaster has been unable to provide a forwarding address for the defendant and the Complaint has since expired. SHERIFF COST: $44.95 SO ANSWERS, • December 03, 2013 RONF�R ANDERSON, SHERIFF • (c)C,ou^tySuite Sheriff,Te!eosott,L'o. -r r7ci- XML Law Group,P.C. ri T r'Ut4'0 Suite 5000-BNY Independence Center 1013 DEC 701 Market Street - Aso 11 1Q: ; 7 Philadelphia,PA 19106-1532 UBtF�AND CpU 215-627-1322 AEHNSYLVA OUNT Y Attorney for Plaintiff LAKEVIEW LOAN SERVICING,LLC 4425 Ponce De Leon Boulevard IN THE COURT OF COMMON PLEAS MS5/125 Coral Gables,FL 33146 OF Cumberland COUNTY vs. PETER J. CHRISTMAS 231 Lincoln Street No. 13-6257 Enola,PA 17025 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 231 Lincoln Street,Enola,PA, 17025, hereinafter,the "mortgaged premises". 2. Defendant,PETER J. CHRISTMAS, is the mortgagor and real owner of the mortgaged premises. 3. Pursuant to Cumberland County Local Rule 208.3(a)(2)and/or Rule 208.3(a)(9), I hereby certify that the Honorable Kevin A.Hess has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover,due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. 4. The last known address of Defendant,Peter J. Christmas, is 231 Lincoln Street,Enola, PA 17025 from our investigative search. 5. The Sheriff has been unable to effect service of the Complaint upon Defendant,Peter J. Christmas. Service was attempted on Defendant,Peter J. Christmas at the mortgaged premises 231 Lincoln Street,Enola,PA 17025. The property is vacant. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant,Peter J. Christmas. WHEREFORE,Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendant,Peter J. Christmas,by posting the premises and certified and regular mail to the property address. 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 frlyk 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: 117187FC Attorney/Law Firm:KML LAW GROUP, P.0 Subject Name:PETER J. CHRISTMAS Property Address: Street:231 Lincoln Street City: Enola State: PA Zip: 17025 Skip Results: Date of Birth: ProVest File Number:3836517 Last Known Address(as of 12/10/2013)Street:231 Lincoln St City: Enola State: PA Zip: 17025 3242 Death Record Search As of 12/10/2013,the Social Security Administration has no death record on file for Peter J Christmas. Social 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 address from the credit header info is: Address: 231 LINCOLN ST, ENOLA, PA 17025 3242 Department of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Vehide Records Search* Drivers License Information Search No verifiable information. []Governmental'*+ [X]Non-governmental Professional Licenses Search No records found. Freedom Of Information Act Inquiry The following addresses were sent to the United States Postal Made to U.S. Postal Service inspector at the zip code listed with no return information to date: PO BOX 474 I TOWNER I ND 1 58788 0474 I MCHENRY 231 LINCOLN STREET I ENOLA I PA 1 17025 I 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, 717-761-3751: Called possible relative,Jennifer Hande,answering Neighbors,&Friends machine answered, no message left. 717-732-5136:Called possible neighbor, Kenneth Baker,answering machine answered,no message left. Comments: 717-585-5484:Called number listed to defendant, Peter Christmas, recording stated, "The person you are trying to reach has a voicemail box not set up." •Data not available in AL,AR,CA,HI,NH,OR,PA,VA,WA. Historical 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,MO,NH,ND,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 unswom 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. I STATE OF FLORIDA el INAA4— t ` ALLL I COUNTY OF HILLSBOROUGH DEC 1 1 2013 Gianna Hernandez Pro Vest File Number:3'F'• 17 Sworn to or affirmed and signed before me on this_day of Provest Services LLC (Seal) Date: 12 'Ilk 2 0 (J - c JOSHUA N.PIMENTEL Sign t ry Public Notary Public,State of Florida My Comm.Expires May 24,2015 No.EE 97050 — Printed Name of Notary Public Personally Known ( )Produced as identification SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ya1■0) � N.illIlllCf'J,ylt t, Jody S Smith b Chief Deputy F Richard W Stewart Solicitor off ICE;}F TKE ShGh(FF 1 Lakeview Loan Servicing, LLC Case Number vs. 2013-6257 Peter John Christmas SHERIFF'S RETURN OF SERVICE 10/25/2013 Ronny R Anderson, Sheriff,being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Peter John Christmas, 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 231 Lincoln Street, East Pennsboro, Enola, PA 17025. Residence is vacant and the Enola Postmaster has been unable to provide a forwarding address for the defendant and the Complaint has since expired. SHERIFF COST: $44.95 SO ANSWERS, December 03,2013 RONNY R ANDERSON, SHERIFF I 1 1 (W CounlySuilo Shentl,Teleosoft Inc. KNIL Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff LAKEVIEW LOAN SERVICING,LLC 4425 Ponce De Leon Boulevard MS5/125 IN THE COURT OF COMMON PLEAS Coral Gables,FL 33146" OF Cumberland COUNTY vs. PETER J. CHRISTMAS 231 Lincoln Street No. 13-6257 Enola,PA 17025 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 Defendant,Peter J. Christmas,which the Sheriff has been unable to personally serve upon Defendant, Peter J. Christmas. 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 Defendant,Peter J. Christmas,by posting the premises and certified mail and regular mail to the property address. By: `"' 1 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 LAKEVIEW LOAN SERVICING,LLC 4425 Ponce De Leon Boulevard IN THE COURT OF COMMON PLEAS MS5/125 Coral Gables,FL 33146 of Cumberland County vs. PETER J. CHRISTMAS No. 13-6257 231 Lincoln Street Enola,PA 17025 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 Defendant, Peter J. Christmas thisJ ay of December 2013, by first class mail, postage prepaid. PETER J. CHRISTMAS 231 Lincoln Street Enola, PA 17025 1 By: G�c.( vi•� it-c‘ KML aw Group, P.C. Marlene Powers, Legal Secretary Direct Phone: 215-825-6340 y LAKEVIEW LOAN SERVICING,LLC IN THE COURT OF COMMON PLEAS 4425 Ponce De Leon Boulevard MS5/125 OF Cumberland COUNTY Coral Gables,FL 33146 VS. rn 13-6257 PI . .r--- PETER J.CHRISTMAS C'n r ;; 231 Lincoln Street `" T r� ° Enola,PA 17025 <CD ORDER AND NOW,this Z day of I f-M,+ol 201' ,upon consideration of the Pla ntiff s Motion for 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 Defendant,Peter J. Christmas,have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant,Peter J. Christmas,by posting a copy of the Complaint upon the premises 231 Lincoln Street,Enola,PA, 17025,and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendant's last known address at 231 Lincoln Street,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's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant,Peter J. Christmas, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. Service is complete upon mailing. BY THE COURT: A J. D' ution list: Michael T. McKeever, Esquire, Suite 5000 NY Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 PETER J. CHRISTMAS, 231 Lincoln Street Enola, PA 17025 �o A&I LeCL KML Law Group, P.C. 4 jA SUITE 5000—BNY INDEPENDENCE CENTER 1E 2 f AN In v P� 701 MARKET STREET PHILADELPHIA,PA 19106-1532 PENN-AND 000- �, (215)627-1322 ATTORNEY FOR PLAINTIFF LAKEVIEW LOAN SERVICING,LLC 4425 Ponce De Leon Boulevard IN THE COURT OF COMMON PLEAS MS5/125 OF Cumberland COUNTY Coral Gables,FL 33146 Plaintiff CIVIL ACTION -LAW vs. ACTION OF MORTGAGE FORECLOSURE PETER J. CHRISTMAS Term 231 Lincoln Street No. 13-6257 Enola, PA 17025 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: KML LAW ROUP,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 Attorneys for Plaintiff ,x1/. 7 C ►� 7Sla�y P--44 30i)(pSa SHERIFF'S OFFICE OF CUMBERLAND COUNTY-1 Ronny R Anderson -ri Sheriff Zm � r Jody S Smith ' _, c_' Chief Deputy r--z <a -0 a Richard W Stewart 7:0c-) 3 =c-7 E~ Solicitor c'a N T1 Lakeview Loan Servicing, LLC vs. Case Number Peter John Christmas 2013-6257 SHERIFF'S RETURN OF SERVICE 01/24/2014 05:10 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: Peter John Christmas, pursuant to Order of Court by"Posting"the premises located at 231 Lincoln Street, East Pennsboro, Enola, PA 17025 with a true and correct copy according to law. Ig IE DIMART17EPUTY SHERIFF COST: $50.95 SO ANSWERS, January 27, 2014 RONO R ANDERSON, SHERIFF 11 KML Law Group, P.C. T IHE PROTHOHO [1, 1 Suite 5000-BNY Independence Center � '�FEB `Q 46 701 Market Street PM Philadelphia,PA 19106-1532 CUMBERLAND COUNTY 215-627-1322 PENNSYLVANIA Attorney for Plaintiff LAKEVIEW LOAN SERVICING,LLC 4425 Ponce De Leon Boulevard IN THE COURT OF COMMON MS5/125 PLEAS Coral Gables,FL 33146 OF Cumberland COUNTY vs. CIVIL ACTION-LAW PETER J. CHRISTMAS ACTION OF MORTGAGE Mortgagor(s) FORECLOSURE 231 Lincoln Street Enola,PA 17025 Term Defendant(s) No. 13-6257 CERTIFICATE OF SERVICE The undersigned, on behalf of Plaintiff,hereby certifies that on 1 3 /-1 he did serve upon Defendant(s)PETER J. CHRISTMAS a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated January 2nd 2014 . The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, 7 By: 1A4 (3e, KML Law Group, P.C. Nick Barone,Legal Assistant NBarone@kmllawgroup.com 215-825-6365 (Direct Phone) KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Boulevard MS5/125 Coral Gables, FL 33146 vs. PETER J. CHRISTMAS (Mortgagor(s) and Record Owner(s)) 231 Lincoln Street Enola , PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13-6257 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 2013-NPL1 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, 1 lth Floor, Wilmington, Delaware 19801. By: CfvhI\ KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Mm VI nn Thomas Puleo Pa. ID 27615 1 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff avvc\- elocAsq(03, A- *45cIZa KML LAW GROUP, P.C. Suite 5000 — BNY Mellon_ Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Boulevard MS5/125 Coral Gables, FL 33146 vs. PETER J. CHRISTMAS (Mortgagor(s) and Record Owner(s)) 231 Lincoln Street Enola , PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13-6257 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 BRONLE 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 231 Lincoln Street Enola , PA 17025 ("Property"). 2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Instrument # 201104131 in the Office of the Recorder of Deeds for Cumberland County. 3. The original Plaintiff in this action is LAKEVIEW LOAN SERVICING, LLC. 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 December 19, 2014 in Instrument # 201429378 and is hereby voluntarily substituted as Plaintiff in the above -captioned matter. Respectfully submitted, - - 1 By: L LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 j fl } fl a Ly n 11 Con n Q David Fein Pa. ID 82628 31$3 (1)1 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff KML LAW GROUP, P.C. SUITE 5000 — BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 215-627-1322 ATTORNEY FOR PLAIN 11F1. LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Boulevard MS5/125 Coral Gables, FL 33146 Plaintiff vs. PETER J. CHRISTMAS (Mortgagor(s) and Record Owner(s)) 231 Lincoln Street 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. 13-6257 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 QVA r ' coo I S . class mail, postage pre -paid, on PETER J. CHRISTMAS 231 Lincoln Street Enola , PA 17025 By: KML Law Group, P.C. Doris Guzman, Legal Assistant Dguzman@lcmllawgroup.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 TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. PETER J. CHRISTMAS (Mortgagor(s) and Record Owner(s)) 231 Lincoln Street Enola, PA 17025 Plaintiff Defendant(s) r.� ..- No. 1.3-6257 - • r-) C) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against PETER J. CHRISTMAS by default for want of an Answer. Assess damages as follows: Debt Interest from 1/1/2015 to Date of Sale per Monthly diem at $322.27 Total $98,194.63 (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: LAW GROUP, .C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 � _ may, David Fein Pa. ID82628 �/�Ilj4bi nn Co�nar' 3i�3� Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gomall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 _Alyk L. Oflazian Pa. ID 312912 _Jennifer Lynn Frechie Pa ID 316160 Attorneys for Plaintiff AND NOW ' , ( S , Judgment is entered in favorofWILMINGTON SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BR'.. ZE CREEK TITLE TRUST 2013- NPLl and against PETER J. CHRISTMAS by default for want of an Answer and damas assess in t to art of $98,194.63 as per the above certification. aftk "°)Cet‘_ (bit *Zee fF Prothon8l aryrv-N "' 1:77-77- 117187 FC 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. TO: PETER J. CHRISTMAS CHRISTMAS, PETER J. 231 Lincoln Street Enola , PA 17025 LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Boulevard MS5/125 Coral Gables, FL 33146 Plaintiff vs. PE 1'ER J. CHRISTMAS (Mortgagor(s) and Record Owner(s)) 231 Lincoln Street Enola , PA 17025 Defendant(s) TO: PETER J. CHRISTMAS 231 Lincoln Street Enola, PA 17025 DATE OF THIS NOTICE: April 4, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13-6257 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPOPTANT RTQHTC Y(NT CTTfNTI Tl TAKP THIS PAPPR TTl YOUR T AWYFR AT MCP JF YOU PO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: AW G'' P. Michael M ee er Pa. ID 56129 Lisa Lee Pa. ID + 020 David Fein Pa. 11 82628 Ji 1P. Jenkins Pa. ID 306588 lyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Freebie Pa ID 316160 215-627-1322 Attomeys for Plaintiff 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. PETER J. CHRISTMAS Defendant(s) NO. 13-6257 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): PETER J. CHRISTMAS, has a last known residence of 231 Lincoln Street, Enola , PA 17025. 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. 8 �� 1 Date I f5 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 Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 /Jennifer Lynn Frechie Pa. ID 316160 ✓ Cristina Lynn Connor Pa. ID 318389 Victoria W. Chen Pa. ID 317741 Attorneys for Plaintiff Department of Defense Manpower Data Center State .Report Pursuant to Sery cemembers Civil Relief Act. Last Name: CHRISTMAS First Name: PETER Middle Name: J. Active Duty Status As Of: Jan -08-2015 Results as of : Jan -08-2015 09:14:02 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,,. ,, ,'3,, - d N6-4,.., NA ! f i !SNA t � }- i : �' This response reflects the indmduals' active'duty status`based on the Active' Duty;Status Date _ \. I �..%�-.T.-,f, .�Jl ?1;{. . Left Active Duty Within 367 D of Active Duty Status Date - - Aetive Duty Start Date, Order Notification Start Date - . • -Active Duty End Date - _ Status .. Service Component _ NA 4.... �:, NA: ^, ! f i !SNA t � }- i : �' , ..'ri -N-.'4407. } ,, NA `?••••s--,4 '1:1! Y._ e. U"t l .?: 'M "�.r. ,; y �:,`._ .,,,.,:;a This response reflects where.the:Individual left active dutystatus vethie 367 days preceding the`Active Duty Status Date I �..%�-.T.-,f, .�Jl ?1;{. ��� iy i� 1 i! •t. • The Member or HisMer Unit Was Notified of a Future Call -Up to Active Duty on Active Duly Status Date Order Notification Start Date - . Order Notification End Date ' Status .Service Component - - - NA 4.... �:, NA: ^, ... ' {y�^. F' J `No`f'. 5.� NA This response reflects whether the;indivrdual o'',-4.7.-'..".•lfrer:unit has received earty,not tcation to'report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center based one 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�th , 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. Yil- Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 0 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 Dai) 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: Q14AT64AZ115P10 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. PETER J. CHRISTMAS (Mortgagor(s) and Record owner(s)) 231 Lincoln Street 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. 13-6257 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-NPL1, and against PETER J. CHRISTMAS for failure to file an Answer in the above action within (20) days from the date of service of the Complaint, in the sum of $98,194.63. By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 _Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 G�S-11?�l� Lyhn Cann o/ 18'391Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gomall 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 TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 and that the name(s) and last known address(es) of the Defendant(s) is/are PETER J. CHRISTMAS, 231 Lincoln Street Enola , PA 17025; V 6/A11114 By: i KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 .i-CnS- ha L �I� n hn or I� 38' 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 ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance - $81,415.96 Monthly Interest from 02/01/2012 $10,957.18 through 12/01/2014 Reasonable Attorney's Fee $1,300.00 Late Charges $64.52 Escrow $3,455.91 Pro Rata MIP $118.06 Miscellaneous $463.00 Property Preservation $420.00 AND NOW, this A day of 13-6257/117187FC $98,194.63 By: dv et,1w-C G� KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 L/ C rIS'hhc2 Lynn C nnb v Thomas Puleo Pa. ID 27615--7' 2 (� Joshua I. Goldman Pa. 205047 v J �1 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Freebie Pa. ID 316160 Attorneys for Plaintiff an • , 2015 damages are assessed as above. R , ft Pro Prothy PRAECIPE FOR WRIT OF EXECUTION -, (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff WILMINGTON' SAVINGS FUND SOCIETY, FSB, DOING BUSINESS AS CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS LEGAL TITLE TRUSTEE FOR BRONZE CREEK TITLE TRUST 2013-NPL1 500 Delaware Avenue 11th Floor Wilmington, DE 19801 vs. PETER J. CHRISTMAS Mortgagor(s) and Record Owner(s) 231 Lincoln Street Enola, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13-6257 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: aIld . -�V, sapd a L$Lj S �Y Sc tS Il k 2g6.( -I D Amount Due Interest from 1/1/2015 to Date of Sale per Monthly diem at $322.27 (Costs to be added) By: $98,194.63 KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 efisima j i t�n am of 3/230 Thomas Puleo Pa. ID 27615 l�l Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 4,4 .45 vi.Av LO.Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 # 7 Sal Attorneys for Plaintiff RO-3)5Ygt7 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. PETER J. CHRISTMAS (Mortgagor(s) and Record Owner(s)) 231 Lincoln Street Enola, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 No. 13-6257 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 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: 231 Lincoln Street Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): PETER J. CHRISTMAS 231 Lincoln Street Enola , PA 17025 2. Name and address of Defendant(s) in the judgment: PETER J. CHRISTMAS 231 Lincoln Street Enola , PA 17025 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 rY 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 231 Lincoln Street 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: B 61‘44A7 KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 jt, Nigh(� Ly -)n conn( Y Thomas Puleo Pa. 1D 27615 Joshua I. Goldman Pa. 205047 3 1 b3iU1 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 KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff 2:15 J117 1 2 f;, 11: 05 F."'z,,COU`t:1Y ,fl 13-6257 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. PETER J. CHRISTMAS Mortgagor(s) and Record Owner(s) 231 Lincoln Street Enola, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-6257 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: CHRISTMAS, PETER J. PETER J. CHRISTMAS 231 Lincoln Street Enola , PA 17025 Your house at 231 Lincoln Street, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, June 03, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $98,194.63 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: 13-6257 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. 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.ore/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 13-6257 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.ora/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 117187FC. 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 • Suite 100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net 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. NO 2013-6257 Civil Term CIVIL ACTION — LAW PETER J. CHRISTMAS WRIT OF EXECUTION 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: $98,194.63 L.L.: $.50 Interest FROM 1/1/2015 TO DATE OF SALE PER MONTHLY DIEM AT $322.27 Atty's Comm: Atty Paid: $256.40 Plaintiff Paid: Date:;1/14/15 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name:'CRISTINA LYNN CONNOR, 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. 318389