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Home My WebLink About13-7024 a a � Supreme Court of Pennsylvania Coui of Cotn r"On Pleas Civil CoV.er Sheet For Paotlionotarr Use 00 7 1. Cu�inlie .`- Coun Docket No: S o()k� 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: R Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: C PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR SUSAN M. BERTOLOTTI IN INTEREST TO NATIONAL CITY REAL ESTATE T I SERVICES LLC SUCCESSOR BY MERGER TO I Dollar Amount Requested within arbitration limits 0 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 Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented (Pro Se Litigant Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that . you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other � mass tort) ❑Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑Employment Dispute: Other T ❑ Other: I ( MASS TORT ❑ Other ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Other ❑ Eminent Domain/Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 TH��T�� / N�NIL LAW K��KK�0P, P.C. '' ^-^ S/n�, SO0O-BNVnwx/LoNfwuepeNuuNcuComTsu 7f�l1N�� n� K� |/' nM 7*l��AxKsrSruss/� ^~'°``"" �" "^' ''` Pill] AonA/,N,PA 19106 �6 )4]J��» "U��B COUN PENNSYLVANIA 1 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR INTHE COURTOFCOMMON PLEAS IN INTEREST TO NA'FIONAL CITY REAL ESTATE SERVICFS, LLC, SUCCESSOR BY MERGER TO OF CLIniberland COUNTY ,NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. CIVIL ACTION - LAW 3232 Newinark Drive Miarnisburg, OH 45342 ACTION OF MORTGAGE FORECLOSURE vs. wo. ' ~� 8 �~ �/J,�� S08A��&i.8ERTOU3TT/ K�� ' ~=' ' — M»rtgagoqs) and Record On/ner(s) ~uVIL Z77.i|uoDrive ---`�~ Mechanicsburg, PA 17050 ` ---'~~"~"� D�Pnuuol(V | NOTICE You have been sued in court. If you wish to defend against the o|uimy 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 orhyattorney and filing in writing with the court Your defenses or objections to the c}uinon set forth against you. You are vvunmcd that ifyou /ail to do so the case may proceed without you and n judgment may be entered against you by the Court without further notice {br any money c\u[nm in the Complaint of for any other claim oc relief requested by the Plaintiff. You may lose money or property ur other rights important toyou. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D0 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, G() 7O OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PR8\/lDF YOU WITH {NPORyWAT)0W ABOUT] BRING A LAWYER. lF YOU CANNOT &FFOR0TQHIRE A LAWYER. THIS OFFICE MAY BE ABLE TOPROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TOELIGIBLE PERSONS &T/\ REDUCED FUEOR NO PBG. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Cudiu|e,PAl?0l3 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 '17-243-9400 AV I 8O |'ehundemuodadouustudco |ucnrte. Si usbcd quie,cdcfemdcne de csmudcnnunduoexpucxtuoen luo puQinuo uiguicn1cs, ostcd 1ienu vein1c(20) diuo dcp|uzn u| pur6cdc |u fecbado lo dcnounduy |o no6ficucion. Buco {b|tuovocntur uoucorupurcuciu cocritu o en persona ocon un ubogudo ycntrogucu [ucodc en forma euorito sus defenuaso sus objcciones a |us dcmnandasen contra de ou persona. Sea uvimuduquc oi uuted no se defiendc,}ucorte tnnnuranncdidusypuode000douac)udemnanduco contra nuyu sin pncvioaviuououdficuuion. Adcnmuy, |m corto pocdc decider u favor del dcnonnduntc y ncquicmn quo usicd cunnplo con todoo )an provisiones docyiu 6ennondu' Ustod puodu pevdcrdincrou sus pcnyiu6adcu u otros dcrooh*s imny*xunmcs punu uo1 0�� v='='' LLEVE ES TA DEMANDA A UN ABOGADO IMMEDIATAMENTF. Sl NO TIENE ABOGADO O SI NO TIENE El. DINERO SUFICIENTE DE PAGAR TAL SERVCCO. VAYA EN PERSONA O LLAME POR TELF ONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGIIAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. S1 USTED NO PUEDF PA.GARLE A UN ABOGADO, FSTA OFICINA PUEDE PROVF:FRE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SL'RViCIOS LEGAL A PERSONAS ELIGIBLE AQ UN IiONORARIO REDUCLDO 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 FORECLOSURI: 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.liud.gov for l lelp 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.or,/ consumers /homeowners /real.aspx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http: / /ww /foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1 -866- 413 -2311 or via email at homeretention @,,,kmllawtrroup.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 ILomeowner 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 124041 FC. 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. COMI'LAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is PNC BANK, NATIONAL ASSOCIATION. SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO., 3232 Newmark Drive, Miamisburg, OH 45342. 2. The name(s) and address(es) of the Defendant(s) is /are SUSAN M. BERTOL.OTTI., 27 Lilac Drive, Mechanicsburg, PA 17050, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On July 15, 2004 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to NATIONAL CITY MORTGAGE CO., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on July 19, 2004 as Book: 1873 Page: 4725. 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, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of 09/01/2013: PrincipalBalance ............................... ............................... ....................$116,139.82 Interest from 02/01/2013 to 09/01/2013 at 6.0000 % .......... ......................$4,064.90 Monthly interest rate at $580.70 LateCharges ......................................... ............................... ........................$231.80 UnpaidFees ........................................... ............................... .........................$45.00 InspectionCosts ..................................... ............................... .........................$12.00 Appraisal............................................... ............................... ........... .............$175.00 $120,668.52 7. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. Notice of Intention to Foreclose has been sent to Defendants by certified mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copy of such Notice attached and incorporated as Exhibit "B ". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $120,668.52, together with interest at the rate of $580.70, per month and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law, including but not limited to attorney fees and costs, until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. B y : - -- - -- KML LAW GROUP, P.C. ____Michael McKeever Pa. 1D 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. 1D 61858 David Fein Pa. ID 82628 Thomas Pulco Pa. ID 27615 Joshua 1. Goldman Pa. ID 205047 ____Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 __ L. Oflazian Pa. ID 312912 __Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION 1. Luann Jones _ , as a Authorized Signer of PNC BANK, NATIONAL ASSOCIATION do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff, and the facts set forth in the foregoing Complaint arc true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Date � 'y�C i tll PNC BANK, NATIONAL ASSOCIATION NAME: wann Jones TITLE: Authorized Signer #124041 FC - SUSAN M. BERTOLOT'TI 27 Lilac Drive Mechanicsburg, PA 17050 E.xhl*bitA SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTPJN tract or parcel of land and premises, situate, lying and being in the Township, of Silver Spring in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the easterly side of lilac Drive at the dividing line between Lot Nos. 80 and 81 on the hereinafter mentioned Plan of lots; thence along the dividing fine between LotNos. 80 and 81, South 59 degrees 12 minutes 11 seconds East, the distance of 144.26 feet to a point on the northern line of Lot No. 85; thence along the northern fine of Lot No. 85, South 55 degrees 03 minutes 26 seconds West; the distance of 32.34 feet to a point; thence along the westerly line of lot Nos. 84 and83, South 79 degrees 20 minutes 46 seconds West, the d'+stanoe of 133.50 feet to a point thence along the northern line of Lot No. 82, North 59 degrees 12 minutes 11 seconds West, the distance of 30.91 feet to a point in the easterly side of Lilac drive; thence along the said side of Lilac Drive, North 30 degrees 47 minutes 49 seconds east, the distance of 117,86 feet to a point, the place of Beginning. BEING Lot No. 81 on the Plan of Mulberry Crossing as recorded in plan Book 40, Page 142. BEING the same premises which Delia P. Davis and Michael H. Davis, by deed dated December 31, 1998, recorded in the Office of the recorder of deeds in and for Cumberland County, Pennsylvania, granted and conveyed unto Donald K. Underdonk III, and Use R. Underdonk, herein. B 1:873PG 4734 E.X,h i 6 i t (B *Exhibit has been redacted to remove all personally identifiable information or non-public information ( P V C Attention: Collection Department MORTGAGE" (B64)407 -01 -5) 3232 Newmark Drive Miamisburg, ON 45342 7196 9tl08 9111 8255 4420 SUSAN M BERTOLOTTI 27 LILAC DR MECHANICSBURG, PA 17050 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE For Loam Number. 174 This is an attempt to collect a debt Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. PA001 A Division of PNC Bank, National Association T1 937. 910.1200 T2 800- 822 -5626 Date: 615/2013 Re: Loan No�1174 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PNC Mortgage a division of PNC Bank, National Association (hereinafter we, us or ours) on your property located at 27 LILAC DR, MECHANICSBURG, PA 17050, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $1,114.63 for the months of 31112013 through 61112013. Late charges and other charges have also accrued to this date in the amount of $163.62. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $4,622.14. You may cure this default within THIR Y (30) DAYS of the date of this letter, by paying to us the above amount of $4,622.14, plus any additional monthly payments and late charge which may fall due during this period_ Such payment must be made either by cash, cashier's check, certified check or money order, and made at PNC Mortgage /Collections Center, Mail Code B6- YM09 -01 -01, 3232 Newmark Drive, Miamisburg, OH 45342. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $ 50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $ 50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately nine - ten months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait You may find out at any time exactly what the required payment will be by calling us at the following number: 1 -800- 523 -8654. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIEDI. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST). YOU HAVE THE RIGHTTO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred However, you are not entitled to this right to cure your default more than three times in any calendar year_ 4 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR ` = -y IN INTEREST TO NATIONAL CITY REAL C7_ ESTATE SERVICES LLC SUCCESSOR BY Case No. G�9 MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL S C CITY MORTGAGE CO. Plaintiff VS. 5c: t Y SUSAN M. BERTOLOTTI CD w Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: (Signature f Counsel for Plaintiff) Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date _ Cumberland County Court of Common Pleas Docket � BORROW ER 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: ("uSTOMEWPIZI MA RY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes [j No EJ Listing date: Price. $ Realtor Name: Realtor Phone: Borrower Occupied? yes ' No m � — Mailing Address (if different): City State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: Hove long? Mailing Address, City: State: Zip: Phone :Numbers: Home: Office: Cell: Other: Email; # ofpeople in household: How long? First Mortgage Leader: 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. Bate of Last Payment: Primary Reason for Df fault: Is the loan in Bankruptcy? Yes [3 No E] If yes, provide names, location of court, care number & attorney: Asset.-, Amount Owed Value: Home $ $ Other Real Estate: $ $ ... Retirement Funds: $ Investments: $ $ Checking: $ $ Savings: $ $ Usher: $� $ Automobile "l: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation ( automobiles, boats, motorcycles),; Ii odel _ Year: Amount owed: Value Monthly Income Name of Employers: l 2. 3. Additional Income Description (not wages): 1. monthly .amount: 2. monthly amount: Borrower Pay Days Co- Borrower Pay Days: Monthly Exuerrses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Mortgage Utilities Car Pa ens Condo/Nei . lees Auto Insurance Med. not eoveE d Auto fue1Lm airs Other proE. pay ment Install. -Loan Payment Cable TV Child Su rtlAlirrr. Spending Money Ua lCl�ild CatePTuit. Other Exp enses 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 fbllo -A ing information: Counseling Agency: Couriselor. Phone.(Uf ce }: Fax: b Email: Have you made application for Homeowners Emergency Mortgage Assistance Program ,(HEMAP) assistance? Yes" F No[] byes, please indicate the status of the application. Have you had any prior negotiations with your lender or lender's loam servicing company to resolve your delinquency? Yes❑ No F1 If yes, please indicate the status of these 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: IAVO, , authorize the ab named to usetrefer this information to may lenderlservicer for the sale purpose of evaluating my financial situation for possible mortgage options. I/We understand that ilwe 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 11 Past 2 bank statements Proof of arty expected income for the last 45 days �Yp Copy of a current utility bill Y "Letter explaining Treason for delinquency and any supporting documentation j (hardship letter Y Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -��'' THE P 'E RC a, 0[764,4 Sheriff c,�4�� n Jody S Smith C:', �I : Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor OFFICE OF THEsn,Rir= PENNSYLVANIA PNC Bank, National Association Case Number vs. 2013-7024 Susan M. Bertolotti • SHERIFF'S RETURN OF SERVICE 12/03/2013 06:46 PM -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: Susan M. Bertolotti at 27 Lilac Drive, Silver Spring Township, Mechanicsburg, P 17050. / BRIAN GRZY=•SKI,i► PUTY SHERIFF COST: $39.30 SO ANSWERS, December 05, 2013 RONNY R ANDERSON, SHERIFF • (c)CountySuile Sheriff,Tbleosoti,Inc. • In the Court of Common Pleas of Cumberland County PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL No. 13-7024 • CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg,OH 45342 t. R Plaintiff +. vs. ` cr' SUSAN M.BERTOLOTTI r-- =' ' ? (Mortgagor(s)and Record Owner(s)) 27 Lilac Drive Mechanicsburg,PA 17050 -7 eC. Defendant(s) -1 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 SUSAN M.BERTOLOTTI by default for want of an Answer. Assess damages as follows: $123,572.02 Debt Monthly Interest from 3/1/2014 to Date of Sale per diem at$580.70 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record,if any,after the default occurred and at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P. 237.1 , f' By: KML L• 4 GRt�U P.C. Michael eeve 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 ` I Joshua I.Goldman Pa.205047 CAV W .t Jill Jes Pa.ID revF.Gr�. 92 g A� t nle rgaxa ti 6( 0,2 t 1^ �{ ��rp��d AND NOW ` Judgment is entered in favor of BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.and against SUSAN M.BERTOLOTTI by default for want o an A r an ages assessed the sum of$123,572.02 as per the above certification. -rte Prothonotary-` t Rule of Civil Procedure No. 236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg,OH 45342 Plaintiff No. 13-7024 vs. SUSAN M.BERTOLOTTI (Mortgagors and Record Owner(s)) 27 Lilac Drive Mechanicsburg,PA 17050 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle,PA 17013 Prothonotary By: r Des t C. If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 • 124041FC 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 DFAT. DATE OF THIS NOTICE: February 14,2014 TO: SUSAN M.BERTOLOTTI BERTOLOTTI,SUSAN M. 27 Lilac Drive Mechanicsburg,PA 17050 In the Court of PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO Common Pleas NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR BY of Cumberland County MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. CIVIL ACTION-LAW 3232 Newmark Drive Miamisburg,OH 45342 Plaintiff Action of vs. Mortgage Foreclosure SUSAN M.BERTOLOTTI (Mortgagor(s)and Record Owner(s)) No. 13-7024 27 Lilac Drive Mechanicsburg,PA 17050 Defendant(s) TO: SUSAN M.BERTOLOTTI 27 Lilac Drive Mechanicsburg,PA 17050 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 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 ZIAlyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ED 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. Plaintiff NO.13-7024 vs. SUSAN M.BERTOLOTTI Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): SUSAN M. BERTOLOTTI, has a last known residence of 27 Lilac Drive, Mechanicsburg, PA 17050. 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. 22 I / Date 3 `� By: I -me..rA At A AL KML LA i�V iG' _,P.C. Mich.- Mc eever Pa. ID 56129 Lisa : Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gorna11 Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 i11 P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Mar-24-2014 11:33:02 AM SCRA 3.0 i f X t j Status Deport Pursuant to Servieemembers Civil Relief Act Last Name: BERTOLOTTI First Name: SUSAN Middle Name: M. Active Duty Status As Of: Mar-24-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date = Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date - -- - Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date - Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. yhatit � a Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PCO9SLDR.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: Z8C36D95W015MB0 • • KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY IN THE COURT OF COMMON PLEAS REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC., of Cumberland County FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive CIVIL ACTION LAW Miamisburg,OH 45342 Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE SUSAN M.BERTOLOTTI (Mortgagor(s)and Record owner(s)) No. 13-7024 27 Lilac Drive Mechanicsburg,PA 17050 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.,and against SUSAN M.BERTOLOTTI for failure to file an Answer in the above action within(20)days from the dat• of service of the Complaint,in the sum of$123,572.02. By: KML L• 'A G'OU ,P.C. Michael ee'er Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff �� ,t(26 I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg,OH 45342 and that the name(s)and last known address(es)of the Defendant(s)is/are SUSAN M. BERTOLOTTI,27 Lila Drive Mechanicsburg,PA 17050; By: KML W e 'OUP,P.C. Michael cKeever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa. 205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $116,139.82 Monthly Interest from 02/01/2013 $6,968.40 through 02/01/2014 Late Charges $231.80 Unpaid Fees $45.00 Inspection Costs $12.00 Appraisal $175.00 23,572.02• By: 4`L �L KML LA ' RO P,1'.C. Michael -eve, Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa. 205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff ev,X\f-Cr ( )tW 0O AND NOW,this W day of N\ LY O-\,2014 damages are assessed as above. 'AN Pro Prothy 13-7024/124041FC 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 PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY IN THE COURT OF COMMON PLEAS MERGER TO NATIONAL CITY MORTGAGE,INC., FORMERLY KNOWN AS NATIONAL CITY of Cumberland County MORTGAGE CO. 3232 Newmark Drive CIVIL ACTION–LAW Miamisburg,OH 45342 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. SUSAN M.BERTOLOTTI No. 13-7024 • Mortgagor(s)and Record Owner(s) 27 Lilac Drive Mechanicsburg,PA 17050 Defendant(s) c: PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $123,572.02 Monthly Interest from 3/1/2014 to Date of Sale per diem at $580.70 (Costs to be added) P '�S a • Sb pd Q By KML L• ,•R P,P```1`- C. Michael eev Pa. ID 56129 Cr3C Jay E. Kivi z Pa.ID 26769 �r u 1.1 Lisa Lee Pa.ID 78020 J Kristina Murtha Pa. ID 61858 C o 1.L David Fein Pa.ID 82628 J Thomas Puleo Pa.ID 27615 ��}I Joshua I. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 ('v1Q 4-4,- Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff PAL %Mg 9sS v (12 Dyed z x 0w0ao U CID < E" w 0 cn U � wU r., I. W U W O < F. I..4 V) d w H 4. U U O• p P; �. U C E-" 3 0 >C U U o � �. aa .. 00 r W F a ' a o r) '-'01 � ¢ F" R' W>" p o > Q �' w a' � cL) J� �" N c) O UU-IOQU E. � '" Q' 0 °' oa. o � pQM N �.to � 0 ozwH ¢ > � b � � a 3 ~ a o o QOUP= z � � 0 � ¢ v� za ,.. 1p4 0 z �N 0 i o � � '" dN vs 00• ZZU� Q • °ors 0 OW Q off :, ✓ O O , z a W 4 x0 P. W U 0 d E. vi Q • 0 U a) x z � w ¢ w E.* xp4 ~ z3 `" zw � � o a PzcnzU z P. ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Silver Spring in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the easterly side of Lilac Drive at the dividing line between Lot Nos. 80 and 81 on the hereinafter mentioned Plan of Lots; thence along the dividing line between Lot Nos. 80 and 81, South 59 degrees 12 minutes 11 seconds East, the distance of 144.26 feet to a pint on the northern line of Lot No. 85; thence along the northern line of Lot No. 85, South 55 degrees 03 minutes 26 seconds 20 minutes West; the distance of 32.34 feet to a point; thence along the westerly line of lot Nos. 84 and 83, South 79 degrees 20 minutes 46 seconds West, 11 seconds West, the distance of 133.50 feet to a point; thence along the northern line of Lot No. 82, North 59 degrees 12 minutes 11 seconds West, the distance of 30.91 feet to a point in the easterly side of Lilac drive; thence along the said side of Lilac Drive, North 30 degrees 47 minutes 49 seconds east, the distance of 117.86 feet to a point, the place of Beginning. BEING Lot No. 81 on the Plan of Mulberry Crossing as recorded in plan Book 40 Page 142. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY TOWNSHIP OF SILVER SPRING BEING PREMISES: 27 Lilac Drive Mechanicsburg PA 17050 SOLD as the property of SUSAN M. BERTOLOTTI,ADULT INDIVIDUAL TAX PARCEL# 38-22-0146-021 BEING the same premises which DONALD K. UNDERDONK, III AND LISA R. UNDERDONK, HIS WIFE, by deed dated 7/15/2004 and recorded 7/19/2004 in Cumberland County in Deed Book Volume 264 at Page 1035 granted and conveyed unto SUSAN M. BERTOLOTTI, ADULT INDIVIDUAL. KML Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff r k rr i 2: PNC BANK,NATIONAL ASSOCIATION, "' ` )t-r% r�%�L�4NO CoU SUCCESSOR IN INTEREST TO NATIONAL CITY IN THE COURT%--PC PLEAS REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, of Cumberland County INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive CIVIL ACTION-LAW Miamisburg, OH 45342 Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE SUSAN M. BERTOLOTTI (Mortgagor(s) and Record Owner(s)) 27 Lilac Drive No. 13-7024 Mechanicsburg,PA 17050 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.,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: 27 Lilac Drive Mechanicsburg,PA 17050 1.Name and address of Owner(s)or Reputed Owner(s): SUSAN M. BERTOLOTTI 27 Lilac Drive Mechanicsburg,PA 17050 2.Name and address of Defendant(s)in the judgment: SUSAN M.BERTOLOTTI 27 Lilac Drive Mechanicsburg,PA 17050 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 PNC BANK NATIONAL ASSOCIATION 3232 NEWMARK DRIVE MIAMISBURG,OH 45342 ASSET ACCEPTANCE LLC 28405 VAN DYKE AVENUE WARREN,MI 48093 ASSET ACCEPTANCE LLC c/o Joel M.Flink,Esq/Gordon&Weinberg,P.C. 1001 E HECTOR STREET,SUITE 220 CONSHOHOCKEN,PA 19428 PNC BANK NATIONAL ASSOCIATION c/o Lois M.Vitti,Esq/Vitti Vitti&Associates,P.0 215 FOURTH AVENUE PITTSBURGH,PA 15222 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 27 Lilac Drive Mechanicsburg,PA 17050 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: 3 j/2-k[)-o(1- i • By: .A11.1 tr KML LA RO P,P.C. Michael 4eever Pa. ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa. ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff )761il 1---y 1b1,(ab 13-7024 KML Law Group,P.C. Suite 5000-BNY Independence Center`"` 701 Market Street ,vii `,. . > 2 6 F:1 2: U2 Philadelphia,PA 19106 (215)6271322 ( �.lAND COUe ; .; Attorney for Plaintiff 'Ns Y'1 V"'NIA PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES IN THE COURT OF COMMON PLEAS LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL of Cumberland County CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg,OH 45342 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. SUSAN M.BERTOLOTTI Mortgagor(s)and Record Owner(s) Docket No. 13-7024 27 Lilac Drive Mechanicsburg,PA 17050 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BERTOLOTTI,SUSAN M. SUSAN M. BERTOLOTTI 27 Lilac Drive Mechanicsburg,PA 17050 Your house at 27 Lilac Drive,Mechanicsburg,PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday,September 03,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$123,572.02 obtained by PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.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: 13-7024 1. The sale will be cancelled if you pay to PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO.,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.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-7024 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 124041FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Z ?i Fir; ` 26 P f f 2; 132 Philadelphia, PA 19106 215-627-1322 ,,t,i VID v Il�r' Attorney for Plaintiff PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO IN THE COURT OF NATIONAL CITY MORTGAGE, INC.,FORMERLY COMMON PLEAS KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive of Cumberland County Miamisburg, OH 45342 Plaintiff CIVIL ACTION-LAW vs. ACTION OF SUSAN M. BERTOLOTTI MORTGAGE FORECLOSURE Mortgagor(s) and Record Owner(s) 27 Lilac Drive Mechanicsburg,PA 17050 Defendant(s) NO. 13-7024 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff,by counsel,hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. p • By: �� AL A .�_�A_AA KML LA e'OU', . Michael M K. ver I'a.ID 56129 Jay E. Kivi 'a.ID 6769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa. 205047 Jill P.Jenkins Pa. ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff rF 3(6( O ''e\ THE COURT OF COMMON PLEAS \, \ CUMBERLAND COUNTY PA of P1) Z DAVID D.BUELL,PROTHONOTARY tvt v'� 1'« 10 One Courthouse Square• Suite100 • Carlisle,PA • 17013 =. >> (717)240-6195 \ ,_ pso`/ www.ccpa.net PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. Vs. NO 13-7024 Civil Term CIVIL ACTION—LAW SUSAN M. BERTOLOTTI 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: $123,572.02 L.L.: $.50 Interest MONTHLY INTEREST FROM 3/1/2014 TO DATE OF SALE PER DIEM AT$580.70 Atty's Comm: Due Prothy: $2.25 Atty Paid: $188.05 Other Costs: Plaintiff Paid: ., 471y...949)LtAtt Date:3%26/14 David D.Buell, Prothonotary ((e ai) By: Deputy REQUESTING PARTY: Name:JENNIFER FREC)∎e, 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.316160 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY e �t. Pr 0THo!:o Y �ri{\ q, tiirart�r;rf 14 AUG 29 PH 2: G oFFIcEOF CUMBERLAND COUNTY PENNSYLVANIA PNC Bank, National Association vs. Case Number Susan M. Bertolotti 2013-7024 SHERIFF'S RETURN OF SERVICE 06/20/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. 06/20/2014 09:10 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 27 Lilac Drive, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County. SHERIFF COST: $129.03 SO ANSWERS, August 29, 2014 RONNY R ANDERSON, SHERIFF pe -CO - ..0 i_1_,001 - 6k -0 9779 r' _ -L-,,0(-,9779; 3/6 y/? ) County - Sheriff, Teleoso8. Inc, i Cr) 4 N On May 20, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Known and numbered as, 27 Lilac Drive, Mechanicsburg, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: May 20, 2014 By: Real Estate Coordinator