Loading...
HomeMy WebLinkAbout13-7295 Supreme Co- - nnsylvania Cou a leas For Prothonotary Use Only. 1 Docket No: C UlrYlb�Y1G�. County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: EM Complaint ® Writ of Summons ® Petition `S ® Transfer from Another Jurisdiction ® Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: PNC Bank, National Association Matthew Dalinsky a /k/a Matthew A. Dalinsky; et al T Dollar Amount Requested: ®within arbitration limits I Are money damages requested? ® Yes 0 No (check one) ®x outside arbitration limits 0, Is this a Class Action Suit? ® Yes 0 No Is this an MDJAppeal? ® Yes IM No A Name of Plaintiff /Appellant's Attorney: Salvatore Carollo ® Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ® Intentional ® Buyer Plaintiff Administrative Agencies ® Malicious Prosecution ® Debt Collection: Credit Card ® Board of Assessment ® Motor Vehicle ® Debt Collection: Other [3 Board of Elections ® Nuisance Dept. of Transportation Premises Liability 8 Statutory Appeal: Other S ® Product Liability (does not include E mass tort) ®Employment Dispute: Slander/Libel /Defamation Discrimination ® ® C ® Other: Employment Dispute: Other ® Zoning Board , ®Other: I ' ® Other: O MASS TORT ® Asbestos N [3 Tobacco ® Toxic Tort - DES ® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other: ®Ejectment ®Common Law /Statutory Arbitration B ® Eminent Domain/Condemnation ® Declaratory Judgment ® Ground Rent ® Mandamus ® Landlord/Tenant Dispute ® Non- Domestic Relations ®x Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Commercial ® Quo Warranto ® Dental 0 Partition ® Replevin ® Legal o Quiet Title ® Other: ® Medical ® Other: ® Other Professional: Updated 1/1/2011 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302, STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576, SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 0" HARRY B. REESE, ESQUIRE - ID#310501,r i ELIZABETH L. WASSALL, ESQUIRE - ID#77788 -^� =-- JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 p JORDAN DAVID, ESQUIRE - ID#311968 AMANDA RAVER, ESQUIRE - ID #307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 669 - 5400 p PNC Bank, National Association COURT OF COMMON PLEAS C/O PNC Bank, N.A. CIVIL DIVISION 3232 Newmark Drive CUMBERLAND County Miamisburg, OH 45342 V. Plaintiff NO. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY 113 PEARL DRIVE CARLISLE, PA 17013 MATTHEW DALINSKY VIVA MATTHEW A. DALINSKY 113 PEARL DRIVE CARLISLE, PA 17013 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. SQS 31 �qotDok YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las 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 SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: N/A Assignee: N/A Date of Assignment: N/A Recorded Date: N/A Book/Instrument #: N/A Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: Matthew Dalinsky a/k/a Matthew A. Dalinsky and Jessica Dalinsky a/k/a Jessica A. Dalinsky (hereinafter "Defendants "), are the owners of property located at 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013, by virtue of Deed dated 08/21/2007 and recorded 08/23/2007 in Official Records Book Instrument # 200732987 at Page n/a of the Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property "). 3. On 08/21/2007, Defendant(s) and/or their predecessor: MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY AND JESSICA DALINSKY A/K/A JESSICA A. DALINSKY promised to pay to the order of National City Mortgage a Division of National City Bank , the principal sum of $191,000.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 08/21/2007, Defendant(s) and/or their predecessor: MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY AND JESSICA DALINSKY A/K/A JESSICA A. DALINSKY to secure the Note, mortgaged to National City Mortgage a Division of National City Bank, the Property which is the subject of this action. The Mortgage was recorded on 08/23/2007 in Official Records Book Instrument # 200732988 at Page n/a . Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 02/01/2013, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $179,136.57 Accumulated Interest $11,475.44 Accumulated Late.Charges $128.68 Escrow Deficit /(Reserve) $4,434.29 Grand Total $195,174.98 The above figures are calculated to 11/25/2013: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 7.12500 %. The per diem interest accruing on this debt is $34.9700 and that sum should be added to the above date and each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $64.34. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A ". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $ 195,174.98 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: SALVATORE CAROLLO, ESQUIRE PA ID 311050 VERIFICATION The undersigned states that he /she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: P ff m w 3 L zo l J b% Name: Brittany Sloneker Title: Authorized Signer Company: PNC Bank, National Association MJU #: 13050274 CASE #: 13050274 -1 05- 22 -'13 12;35 FROM -ABLE ABSTRACTS T -457 P0023/0024 F -335 FIRST AMERICAN TITLE INSURANCE CO. Commitment Number. DAL163 -07 SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows ALL THAT CERTAIN tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 7 on Plan No. 6 of Noll Manor, as recorded in the Office of the Recorder of Deeds for Cumberland county in Plan Book 22, Page 163, containing 85 feet along Pearl Drive, having a depth along the West along Lot No. S of 304.06 feet, having a width in the rear along the North of 89.21 feet, and Raving a depth along the East along Lot No. 6 on Plan No. 5 of Noll Manor of 327.78 feet. ALTA Commument Schedule C (0AL 163 -07. p FDIpAL t 63.07/3 ) REPRESENT NT PN C 7107 8381 6540 2175 2036 1- 749. 92061 -0000060-001 -01 - 000 -000 -000-000 MATTHEW A DALINSKY 113 PEARL DR. CARLISLE PA 17013 Please find enclosed the ACT 91 NOTICE for Loan Number: 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. D R674/10/21 /2013/0005811715 EXHIBIT A INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 10/21/2013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1- 800 - 342 -2397 (Persons with impaired hearing can call (717) 780 -1869)o This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT HOMEOWNER'S NAME(S): Jessica A Dalinsky Matthew A Dalinsky PROPERTY ADDRESS: 113 PEARL DR CARLISLE, PA 17013 LOAN ACCT. NO.: ORIGINAL LENDER: National City Mortgage a division of National City Bank CURRENT LENDER/SERVICER: PNC Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENT IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE DAYS OFF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES - -If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies ncies for the county in which the pro e is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE, IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT YOU HAVE THE RIGHT TO FILE A- HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency wider the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - -The MORTGAGE debt held by the above lender on your property located at: 113 PEARL DR CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $1,746.34 for 2/1/2013 - 11/1/2013. Monthly Payments Accrued: $15,717.06 Late Charges Accrued: $128.68 Non - Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $60.00 Speedpay Fees: $0.00 TOTAL AMOUNT PAST DUE: $15,923.74 HOW TO CURE THE DEFAULT - -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $15,923.74, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: PNC Mortgage, A Division of PNC Bank, NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT IF YOU DO NOT CURE THE DEFAULT - -If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30)D Y period you will not be required to pay attorney's fees OTHER LENDER REMEDIES - -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - -If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writings the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - -It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 10 months from the date of this Notice. A notice of the actual date of the Sheriff s 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg, OH 45342 Phone Number: (800) 523 -8654 Fax Number: (855) 288 -3974 Contact Person: Collections Center E -Mail Address: LossMitigation @pncmortgage.com EFFECT OF SHERIFF'S SALE - -You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - -You may or X may not (CHECK ONE) sell or transfer your home 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 of the mortgage are satisfied. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT YOU MAY ALSO 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. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling Service /CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888 -511 -2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717- 232 -9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York, PA 17401 717 - 855 -2752 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717- 762 -3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717- 334 -1518 PHFA 211 North Front Street Harrisburg, PA 17110 717- 780 -3940 800 - 342 -2397 INTERNET REPRINT REPRESENT NT MORTGAGE 7107 8381 6540 2175 2029 0- 749 - 92061 -0000059-001 -01 - 000 -000 -000-000 JESSICA A DALINSKY 113 PEARL DR. CARLISLE PA 17013 Please find enclosed the ACT 91 NOTICE for Loan Number: 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. DR674/10/21 /2013/0005811715 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 10/21/2013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP ) may be able to help to save your home This Notice explains how the .program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1- 800 - 342 -2397 (Persons with impaired hearing _can call (717) 780 -1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT HOMEOWNER'S NAME(S): Jessica A Dalinsky Matthew A Dalinsky PROPERTY ADDRESS: 113 PEARL DR CARLISLE, PA 17013 LOAN ACCT. NO.: ORIGINAL LENDER: National City Mortgage a division of National City Bank CURRENT LENDEPUSERVICER: PNC Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE .(33)- OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRIN YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES - -If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designate d consumer credit counseling agencies for the couM in which the pro is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - -The MORTGAGE debt held by the above lender on your property located at: 113 PEARL DR CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $1,746.34 for 2/1/2013 - 11/1/2013. Monthly Payments Accrued: $15,717.06 Late Charges Accrued: $128.68 Non - Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $60.00 Speedpay Fees: $0.00 TOTAL AMOUNT PAST DUE: $15,923.74 HOW TO CURE THE DEFAULT - -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $15,923.74, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: PNC Mortgage, A Division of PNC Bank, NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT IF YOU DO NOT CURE THE DEFAULT - -If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that .were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES - -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - -If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then asp t due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by nerfonning any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - -It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 10 months from the date of this Notice. A notice of the actual date of the 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg, OH 45342 Phone Number: (800) 523 -8654 Fax Number: (855) 288 -3974 Contact Person: Collections Center E -Mail Address: LossMitigation @pncmortgage.com EFFECT OF SHERIFF'S SALE - -You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - -You may or X may not (CHECK ONE) sell or transfer your home 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 of the mortgage are satisfied. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT YOU MAY ALSO 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. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling Service /CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888 -511 -2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 1.7104 717 - 232 -9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York, PA 17401 717- 855 -2752 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717 - 762 -3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717- 334 -1518 PHFA 211 North Front Street Harrisburg, PA 17110 717- 780 -3940 800 - 342 -2397 INTERNET REPRINT FORM I I7 THE COURT OF COMMON PLEAS OF PN CC Ran chOff(I CUMBERLAND COUNTY. PENNSYLV n- t A%0d 0c I.iOn Plaintiff(s) c cam'+ vs.� --ri S 7C) JQSS1 Cq D� � i r)Sk a 1 KIa Defendant sl �" ' i Z l (, Civil ^ y NOTICE O� 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 '_'510 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 vour behalf. If you and your legal representative complete a financial work=sheet 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 trust 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully s ed: 2- 6 -i3 Date gnature of Counsel for Plaintiff) SALVATORE CAROLLO, ESQUIRE PA ID 311050 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please proNride the following information to the best of your knowledge.- Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? YINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number.: Date You Closed Your Loan: Second Mortaaae Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: S Included Taxes & Insurance: Date of Last Pavment: Priman! Reason for Default: is the loan in Bankruptcy? Yes ❑ No ❑ ........... ...._ _.............. .... . . .... .... ......... ...... ......... .........._.. . If yes, provide names. location of court, case number & attornev: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: � $ Savings: $ $ Other: S $ Automobile 41: Model: Year: Amount owed: Value: Automobile 42 : Model: Year: Amount owed: Value: Other transportation (automobiles. boats motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: J. 1. Additional Income Description (not wages): 1. monthly amount: monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthiv Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT M.ort2aQe Food I ! 2" MortaQe Utilities CarPayment(s) Cand.o/Nei.ah. Fees Auto Insurance Med. (not covered) 1 Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alien. Spending Money Day /Child Care /Twit. Other Ex eases I Amount Available for Monthly Mortgage. Payments Based on Income & Expenses: i Have you been working with a Housing Counseling Agency? Yes ❑ No If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: _.._ ..... ........ ...... ........_ ........ ..................... _._..._.....-- ................ — - -- Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, .regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I /We, authorize the above named to use/refer this information to my lender / serviccer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and Iend counsel: V Proof of income V Past 2 bank statements YJJ Proof of any expected income for the last 45 days V Copy of a current utility bill �1 Letter explaining reason for delinquency and any supporting documentation I (hardship letter) �l Listing agreement (if property is currently on the market) J .........._ ................... ....._............................... ...._......__._.._......_ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 3 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 _ SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675W SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID #310501 ELIZABETH L. WASSALL, ESQUIRE - ID #77788 .•` ; x z JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 r NICOLE B. LABLETTA, ESQUIRE - ID #202194 DAVID NEEREN, ESQUIRE - ID #204252 JORDAN DAVID, ESQUIRE - ID #311968 -� AMANDA RAVER, ESQUIRE - ID #307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 Pleadings @ udren.com PNC Bank, National Association COURT OF COMMON PLEAS 3232 Newmark Drive, Miamisburg, OH 45342 CIVIL DIVISION Plaintiff CUMBERLAND County v. NO. Jessica Dalinsky a /k/a Jessica A. Dalinsky 113 Pearl Drive Carlisle, PA 17013 Matthew Dalinsky a /k/a Matthew A. Dalinsky 113 Pearl Drive Carlisle, PA 17013 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; Harry B. Reese, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; John Eric Kishbaugh, Esquire; Nicole B. LaBletta, Esquire; David Neeren, Esquire, Jordan David, Esquire, and Amanda Rauer, Esquire on behalf of the Plaintiff, in the above - captioned matter. UDREZLA FF ICES, P. C. BY• SALVATORE CAROLLO, ESQUIRE PA ID 311050 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 PNC Bank,National Association COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION Cumberland County v. JESSICA DALINSKY A/K/A JESSICA A. ' `, DALINSKY; MATTHEW DALINSKY NO. 13-7295 Civil trlre A/K/A MATTHEW A. DALINSKY Defendant(s) 'A - PRAECIPE TO REINSTATE COMPLAINT `c TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: UDREN LAW OFFICES, P.C. BY Att, . eys or Plaintiff HARRY B. REESE, QUIRE PA ID 31 01 4 ctui a Al ll ���(T � SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff t;; 3 ROTHO.10TAt t,0{ l tart :c Jody S Smith Chief Deputy 20 ill FEB -4 PM 3 t Richard W Stewart ,,E1M l.AN€ COUNTY Solicitor - - PENNSYLVANIA PNC Bank, N.A. Case Number vs. Jessica Dalinsky(et al.) 2013-7295 SHERIFF'S RETURN OF SERVICE 01/03/2014 03:51 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jessica Dalinsky, 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 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013. Residence appears to be vacant,there is a water shut off notice on the door and deputies were informed by a neighbor that he has not seen the defendant in about eight months. To this date the Carlisle Postmaster has not provided a good forwarding address for the defendant. 01/13/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Matthew Dalinsky, 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 113 Pearl Drive, North Middleton, Carlisle, PA 17013. Residence appears to be vacant, there is a water shut off notice on the door and deputies were informed by a neighbor that he has not seen the defendant in about eight months. To this date the Carlisle Postmaster has not provided a good forwarding address for the defendant. SHERIFF COST: $81.12 SO ANSWERS, January 13, 2014 RONNY R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff -fly r -r, Jody S Smith ' -ror,; Chief Deputy cnr ' Richard W Stewart Solicitor , . ,.-, - "Ta ZC Vtr°. .1-- N) Q PNC Bank, N.A. Case Number vs. Jessica Dalinsky(et al.) 2013-7295 SHERIFF'S RETURN OF SERVICE 01/23/2014 07:40 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 by handing a true copy to a person representing themselves to be Matthew Dalinsky, Husband, who accepted as "Adult Person in Charge"for Jessica Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013. Al IE DIMAR'PiEPUTY 01/23/2014 07:40 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 by "personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Matthew Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013. lt0 GMIE DIMAR I EPUTY SHERIFF COST: $50.78 SO ANSWERS, January 27, 2014 RONNY R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleadings ' udren.com PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY 43 PLEASANT HALL ROAD CARLISLE, PA 17013 MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY 43 PLEASANT HALL ROAD CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -7295 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), JESSICA DALINSKY A/K/A JESSICA A. DALINSKY; MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY; for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Additional Late Charges Escrow Per Complaint Grand Total FROM TO 11/26/2013 04/04/2014 11/26/2013 04/04/2014 $179,136.57 $11,475.44 $4,546.10 $128.68 $257.36 $4,434.29 $199,978.44 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES ARE H REBY ASSESSED AS INDICATED DATE: 55/7 I T MJU #: 13050274 CASE #: 13050274 -1 O FICES, P.C. RRY B. REESE, ESQUIRE 310501 C.K La 3q 4S # 3a yam \‘iYt m %c UDREN LAW OFk10ES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID4t34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - 1:D011050 HARRY B. REESE, ESQUIRE - ID#310501 ELIZABETH L. WASSALL, ESQUIRE - IDW77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - 1341202194 DAVID NEEREN, ESQUIRE - ID#204252 JORDAN DAVID, ESQUIRE - ID4t311968 AMANDA RAUER, ESQUIRE - 11W307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 @uclren. _ I PNC Bank, National Association CIO PNC Bank, N.A. 3232 Newmark Drive 1VBamisburg, OH 45342 Plaintiff v. XESSICA DALINSKY A/K/A JESSICA A. DALINSKY 113 PEARL DRIVE CARLISLE, PA 17013 MAT iliEW DALINSKY A/K/A MATTHEW A. DALINSKY 113 PEARL DRIVE CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. I 61-S COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. Ronny R Anderson Sheriff SHERIFF'S OFFICE OF CUMBERLAND COUNTY 4_0o at canii,,r, Jody S Smith Chief Deputy c6 Richard W Stewart Solicitor OFF ICE OF THE VERFP PNC Bank, NA. vs. Jessica Dalinsky (et al.) Case Number 2013-7295 SHERIFF'S RETURN OF SERVICE 01/23/2014 07:40 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 by handing a true copy to a person representing themselves to be Matthew Dalinsky, Husband, who accepted as "Adult Person in Charge" for Jessica Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013. 01/23/2014 07:40 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 by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Matthew Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013. SHERIFF COST: $50.78 January 27, 2014 ' ) OrrunKuile Strontr, Toleounl L _L 4111111161111111 111 L _ E DIMAR EPU SO ANSWERS, RONNY R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky, Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -7295 Civil TO: Jessica Dalinsky a/k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Date of Notice: March 24 014 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 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRTTA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. BY: UDREN LAW OFFICES, PC. PAID02114 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003 -3620 MJU #: 13050274 CASE #: 13050274 -1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 -669 -5400 PNC Bank, National Association Plaintiff v. Jessica Dallnsky a/k/a Jessica A. Dalinsky, Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil TO: Matthew Dalinsky a/k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Date of Notice: March 24, 2014 IMPORTANT NOTICE YOU ARE. TN 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 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 N011tfICACION JMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERM1NO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCIUTA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN AT IEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. BY: UDREN LAW OFFICES, PC. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 13050274 CASE#: 13050274-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient infoimation to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: April 3, 2014 MJU#: 13050274 CASE#: 13050274-1 oriiey for Plaint HARRY B. REES ESQUIRE PA ID 3 0501 Department of Defense Manpower Data Center Last Name: DALINSKY First Name: JESSICA Middle Name: A Active Duty Status As Of: Apr-03-2014 Results as of : Apr-03-2014 06:33:57 AM lief Act SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA _ Ir-t.';`JA i -.2g4a- ..t.-',..),c._-,.• ,-.14A\N... NA I t t I *iit ., .,, This response reflects theindividuale'Activeiduty status based`drithe 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 _ Ir-t.';`JA i -.2g4a- - ----% L-- ' '-':1`1l3.'-+ il.-1.9) I NA This response reflects ±..;figettil indPdual left actiNii41statua,withi‘e36 'iays precedi; thelZhielD"uty Status Data The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duly on Active Duty Status Date Order Notification Start Dale Order Notification End Date Status Service Component NA 1';',') .--t--iti NA ;,,.... , eti,:ta,_.,.- . --7,t'V:i3t 4/..al NA This response reflects whetherthe inclividual'or,hisiher-unil has iteceived.early rvalikaticirto report for active duly ) Upon searching the data banks of the Department of Defense ManpOwerData 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 Serf./Zr(Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http: / /www.defenselink.mil /faq /pis /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: 68Q8Q17AWO6B1C0 Department of Defense Manpower Data Center Last Name: DALINSKY First Name: JESSICA Middle Name: Active Duty Status As Of: Apr -03 -2014 Results as ot: Apr -03 -2014 06:35:37 AM lief Act SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Status Service Component NA �Date i NF}'rt 'mot.' }1�, t..t.4_j_: .Not NA This response refects' 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 P :7-7,Y J A . _'F 1, �: fi� -. , '. L_ No y . ;' ./J NA lter^` I. f' tr3 .� • •o-.. This response reflects where the individual left active $uty'status within 36'7 days preceding the Active Duty Status Date Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Member or His /Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End.Date Status Service Component NA 4`NA'!.,,, `� -'F1i, "^ °NO ...- o / J,/A NA This response reflects whetherihe individual or his/her unit ha received early not ,r ionic, report far active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http: / /www.defenselink.mil /faq /pis /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: Z8WAM1CA006CM00 Department of Defense Manpower Data Center Last Name: DALINSKY First Name: MATTHEW Middle Name: A Active Duty Status As Of: Apr -03 -2014 Results as of : Apr-03-2014 06:36:22 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ,�+� NAf"t4)r;! - -t. _i,A_'_r • ,No 'N\. NA This response This response retfbi s c t `e in''d'h vid ualsF rc th v e � dFut l sF t at u rs v b a s'A' ' o n ;the '4.Acti ve p\ Satus Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Status Service Component NA Date_ t +�i:':.l+NA . pis .c1 i ,�..Status t .y f'.�i —„I%' - +No 1`tefi-'q NA This response reflects where he incAdual left ac tive i uty statue within 364 days preceding the Active Duty Status Date The Member or His /Her Unit Was Notified of a Future Cell -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA \'NA'1- i, -nt -_ E '- ; "y - - • i.. ' O ii43,'I NA *t . , - dial -� 7has'r -: ri ' r This response reflects whetherlhe inbtvidual -or. his/her -unit has - received eedy notittuelioMO report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center; based on the Information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed - Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DOD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http: / /www.defenselink.mil /faq /pis /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: G8Q1 H1 DAQ06D070 Department of Defense Manpower Data Center Results as of : Apr -03 -2014 06:37:06 AM SCRA 3.0 Last Name: DALINSKY First Name: MATTHEW Middle Name: Active Duty Status As Of: Apr -03 -2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ^..�.,� NA" 'i, ski �� , ,.t. -t, M ?.r f .! -1,6' ' NA .ef,r\ ',t Yr �'f to ••t.r.F "z,f +rl^+ -/ Fs�,= This response rettects theandividuaIs ctive 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 -- }' } '4 } {, �`-M ._:li.,T.;v'ti No it :I9-/ :] NA }NA ��� Wh��4 i;. ,a?; �r,i ild ,� Mrf,.._i N This response reflects ere h individual left acti e�duty.status�within- 367;days preceding the. Active Duty Status Date The Member or His /Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA kNA j t` 1#' r - ' ,t -- �r,•:1 / rNit ,K,y�/ NA This response reflects whether the individual or- his/herunit has-received eartty notificahonlo report for active duty Upon searching the data banks of the Department of Defense ManpoweData Ceriter, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed - Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http: / /www.defenselink.mil /faq /pis /PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his /her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(0 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: Q8U8Q1 FACO6D930 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleadings @udren.com PNC Bank, National Association Plaintiff v. Jessica Dalinsky a /k/a Jessica A. Dalinsky Matthew Dalinsky a /k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -7295 Civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 199,978.44 Interest From 4/5/2014 to Date of Sale 9/3/2014 Ongoing Per Diem of $34.97 to actual date of sale including if sale is held at a later date $ 5,315.44 (Costs to be added) $ G's.stYvA, atzLiz g�. is cif- MJU #: 13050274 CASE #: 13050274 -1 it <, Le ll,�S UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff tlAr(RY B. REESE ESQUIRE PA ID 311501 CLA L.C.?ci 140 r(-4 ooLi r Pi73zed UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 pleadings ' udren.com PNC Bank, National Association Plaintiff v. Jessica Dalinsky a /k/a Jessica A. Dalinsky Matthew Dalinsky a /k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -7295 Civil CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above - captioned matt es ° 7„ — El Act 91 procedures have been fulfilled T1 Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDRE LAW OFFICES, P.C. BY: U Attov ey or Plainti HARRY B. REESE, ' SQUIRE PA ID 310'01 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: JESSICA DALINSKY A/K/A JESSICA A. DALINSKY 43 PLEASANT HALL ROAD CARLISLE, PA 17013 MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY 43 PLEASANT HALL ROAD CARLISLE, PA 17013 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. UD N LAW OFFICES, P.C. or Plain HARRY B. REESE ESQUIRE PA ID 3 1501 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleadings(aiudren.com PNC Bank, National Association Plaintiff v. Jessica Dalinsky a /k/a Jessica A. Dalinsky Matthew Dalinsky a /k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -7295 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, National Association , Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, 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: 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Jessica Dalinsky a /k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Matthew Dalinsky a /k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Jessica Dalinsky a /k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Matthew Dalinsky a /k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Citibank N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street Suite 501 Philadelphia, PA 19103 "-4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Adams County Domestic Relations Section 123 Baltimore Street Gettysburg, PA 17325 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128 -1230 Tenants /Occupants 113 Pearl Drive, North Middleton Township Carlisle, PA 17013 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: Federal Tax Lien Holders - None Condo/Homeowners Association - None 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. sec. 4904 relating to unsworn falsification to authorities. DATED: �� , - 1 tl MJU #: 13050274 CASE #: 13050274 -1 UDRE LAW OFFICES, P.C. BY: Atto ey or Plaint'. HARRY B. R ' SE, ESQUIRE PA ID 310501 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleadings @udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County r'- MORTGAGE FORECLOSURE e, cf r NO. 13 -7295 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jessica Dalinsky a /k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Your house (real estate) at 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on September 3, 2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $199,978.44, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669 -5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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. 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 on page two 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 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 by calling 856- 669 -5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call 856- 669 -5400. 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 the 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 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -7295 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Matthew Dalinsky a /k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Your house (real estate) at 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on September 3, 2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $199,978.44, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669 -5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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. 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 on page two 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 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 by calling 856- 669 -5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call 856- 669 -5400. 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 the 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 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240 -6195 www.ccpa.net PNC BANK, NATIONAL ASSOCIATION Vs. NO 13 -7295 Civil Term CIVIL ACTION — LAW JESSICA DALINSKY A /K/A JESSICA A. DALINSKY MATTHEW DALINSKY A /K/A MATTHEW A. DALINSKY 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: $199,978.44 L.L.: $.50 Interest FROM 4/5/2014 TO DATE OF SALE 9/3/2014 - ONGOING PER DIEM OF $34.97 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $5,31.5.44 Atty's Comm: Due Prothy: $2.25 Atty Paid: $292.40 Other Costs: Plaintiff Paid: Date: 4/7/14 (Seal) David D. Buell, Prothonotary Deputy P y REQUESTING PARTY: Name: HARRY B. REESE, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 Attorney for: PLAINTIFF Telephone: 856 -669 -5400 Supreme Court ID No. 310501 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY, ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. 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. sec. 4904 relating to unsworn falsification to authorities. 7 Dated: / "11 1V UDREN LAW 1..- IS, P.C. MJU#: 13050274 CASE#: 13050274-1 BY: Attorneys for Plaintiff ELIZABETH L WASSALL, ESQ PA ID 77788 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a�udren.com PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, National Association , Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, 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: 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Jessica Dalinsky a/k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Matthew Dalinsky a/k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Jessica Dalinsky a/k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Matthew Dalinsky a/k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Citibank N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: North Midleton Authority 240 Clearwater Drive Carlisle, PA 17013 North Midleton Authority c/o Hubert X. Gilroy, Solicitor for Authority 10 East High Street Carlisle, PA 17014 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 113 Pearl Drive, North Middleton Township Carlisle, PA 17013 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: Federal Tax Lien Holders - None Condo/Homeowners Association - None 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. sec. 4904 relating to unsworn falsification to authorities. DATED: % 4"l7 MJU#: 13050274 CASE#: 13050274-1 UDREN OFFICES, P.C. BY. Attorney for Plaintiff ELIZABETH L WASSALL, ESC. PA ID 77788 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY; MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): JESSICA DALINSKY A/K/A JESSICA A. DALINSKY; MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY; PROPERTY: 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale 011 09/03/2014 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 13050274 CASE#: 13050274-1 Name Address of Sender and Henrietta Crommarty❑ UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 Registered n Insured El COD Ell Certified p Return Receipt forAffix Merchandise El Int'I Recorded Del. 0 Express Mail Check appropriate block for. Registered Mail: With Postal insurance n Without postal Insurance stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line mbar Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks l Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 2 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, Pa 17013 ..a 3 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 4 13-7295 Tenants/Occupants 113 Pearl Drive, North Middleton Township Carlisle, PA 17013CE 5 Citibank N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501MINA • MR Philadel,hia, PA 19103 6 09/03/2014All 7 U.S. POST) low ZIP 0800; 02 1 V 0001387 �._1 -1 -_N= 8 9 10 11 12 13 14 15 Total - - number of Pieces Listed by Sender Total Number of P" Received at P 0 Postmaster, Per (lane of Receiving Employee) The full declaration of value is required on all domestic and international registered mail, reconstruction of fable documents The maximum indemnity payable for the 5 nonnego under Express Mail document reconstruction insurance is $50,000 per p'ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and 5921 for limitations of coverage on insured and COD mail. See international Mail Manual for limitations of coverage on international mail. Special handling charges apply only to thud and forth PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen class parcels. Jessica Dalinsky a/k/a Jessica A. Dalinsky - MJU# 13050274-1 (Cumberland County) Matthew Dalinsky a/k/a Matthew A. Dalinsky - MJU# 13050274-1 (Cumberland County) Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ❑Registered ❑ Insured ❑ COD ❑Certified ❑ Return Receipt for Merchandise ❑ Int' I Recorded Del. Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance Without postal Insurance Affix stamp certificate of additional copies Postmark and Due Sender If COD here if issued mailing of this Date of R.R. Fee as or for bill. Receipt S.D. Fee S.H. Fee Rst. Del. Fee Remarks Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value i North Middleton Authority, Hubert X. Gilroy, Esquire, Solicitor For Authority, 10 East High St., Carlisle, Pa 17014 2 North Middleton Authority 240 Clearwater Drive/ Carlisle, PA 17013 cN `lily /,,, 3 4 13-7295 5 6 09/03/2014 ICIL Meng7 ■min 8 U.S. POST r ZAP 080( 0 14Y ¢.0200138 •mew 9 10 UPI 11 12 13 1415 \\\ Total number of Pieces Total Numb f Pieces Postmaster, (Nance of Receiving Employee) The full declaration of value is required on all domestic and international registered mail The maximum indemnity payable for the Listed by Sender 2 Received a O t O e rer reconstruction of nonnego iable documents under Express Mail document reconstruction insurance is $50,000 per p ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, 5913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Jessica Dalinsky a/k/a Jessica A. Dalinsky - MJU# 13050274-1 (Cumberland County) Matthew Dalinsky a/k/a Matthew A. Dalinsky - MJU# 13050274-1 (Cumberland County) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OFTRE SKERIFF PNC Bank, N.A. vs. Jessica Dalinsky a/k/a Jessica A. Dalinsky (et al.) Case Number 2013-7295 SHERIFF'S RETURN OF SERVICE 06/16/2014 05:07 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Matthew Dalinsky, husband, who accepted as "Adult Person in Charge" for Jessica Dalinsky a/k/a Jessica A. Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013, Cumberland County. 06/16/2014 05:07 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit:. Matthew Dalinsky a/k/a Matthew A. Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013, Cumberland County. 06/16/2014 05:31 PM - Deputy Shawn Harrison, being dulysworn 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 113 Pearl Drive, Carlisle, PA 17013, Cumberland County. SHERIFF COST: $994.24 SO ANSWERS, July 02, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �3 rv�����/r� /ncPMU(HiN 0TA�� 2014 SEP -Li '''`'v2 CUMBERLAND COUNTY � PENNSYLVANIA OFFICE, OF T8E SR:RIFF PNC Bank, N.A. vs. Jessica Dalinsky a/k/a Jessica A. Dalinsky (et al.) Case Number 2013-7295 SHERIFF'S RETURN OF SERVICE 06/ 16/2014 05:07 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Matthew Dalinsky, husband, who accepted as "Adult Person in Charge" for Jessica Dalinsky a/k/a Jessica A. Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013, Cumberland County. 06/16/2014 05:07 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Matthew Dalinsky a/k/a Matthew A. Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013, Cumberland County. 06/16/2014 05:31 PM - Deputy Shawn Harrison, 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 113 Pearl Drive, Carlisle, PA 17013, Cumberland County. 08/02/2814 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned ^stoymd'', per letter of instruction from Attorney. SHERIFF COST: $874.65 SO ANSWERS, September 04, 2014 RONR ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, tic. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net PNC Bank, National Association Vs. NO 13-7295 Civil Term CIVIL ACTION — LAW Jessica Dalinsky a/k/a Jessica A. Dalinsky Matthew Dalinsky a/k/a Matthew A. Dalinsky 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: $199,978.44 L.L.: Interest From 04/05/2014 $8,497.71 to Date of Sale 12/03/2014 Ongoing Per Diem of $34.97 to actual date of sale including if sale is held at a later date. Atty's Comm: Atty Paid: $1,195.55 Plaintiff Paid: Date: 9/4/2014 (Seal) REQUESTING PARTY:• Name: David Neeren, Esquire Address: UDREN LAW OFFICES, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attorney for: Plaintiff Telephone: 856-669-5400 Supreme Court ID No. 204252 Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary Deputy , UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: pd 9f- 12, sp. rIg bg /03. rt 5 .2- g • —5—° JU#: 1 Amount due Interest From 04/05/2014 to Date of Sale 12/03/2014 Ongoing Per Diem of $34.97 to actual date of sale including if sale is held at a later date. (Costs to be added) p.e2C ci/e 6 050274 C SE#: 13050274-1 N5755- eittloeioV c3/040. Wri-/ oT /ss-aec/ $ 199,978.44 $ 8,497.71 c-) rn <c) z d Neeren, Esquire PA .D 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.corn PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil Defendant(s) SHORT DESCRIPTION FOR ADVERTISING ALL THAT CERTAIN LOT OF LAND SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA: BEING KNOWN AS 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 PARCEL NUMBER: 29-16-1094-066 IMPROVEMENTS: Residential Property D.id Neeren, Esquire PAID 204252 ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO. 7 ON PLAN NO. 6 OF NOLL MANOR, AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 22, PAGE 163, CONTAINING 85 FEET ALONG PEARL DRIVE, HAVING A DEPTH ALONG THE WEST ALONG LOT NO. 8 OF 304.06 FEET, HAVING A WIDTH IN THE REAR ALONG THE NORTH OF 89.21 FEET, AND HAVING A DEPTH ALONG THE EAST ALONG LOT NO. 6 ON PLAN NO. 5 OF NOLL MANOR OF 327.78 FEET. BEING KNOWN AS: 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 PROPERTY ID NO.: 29-16-1094-066 TITLE TO SAID PREMISES IS VESTED IN MATTHEW A. DALINSKY AND JESSICA A. DALINSKY, HUSBAND AND WIFE BY DEED FROM ROBERT T. SCHOLLY AND BRENDA R. SCHOLLY, HUSBAND AND WIFE DATED 08/21/2007 RECORDED 08/23/2007 IN DEED BOOK Instrument # 200732987 PAGE n/a. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County mM MORTGAGE FORECLOSURE v cJ C) c) `vim= -G NO. 13-7295 Civil CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above -captioned matter: Act 91 procedures have been fulfilled j� Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDR Y: Attorney A "r P . ' tiff r\3 Da eeren, Esquire PAID 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s udren.com PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, National Association , Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, 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: 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Jessica Dalinsky a/k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Matthew Dalinsky a/k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Jessica Dalinsky a/k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Matthew Dalinsky a/k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 r, _o cx, P1-- r cp -„ 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Citibank N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street Suite 501 Philadelphia, PA 19103 North Middleton Authority, Hubert X. Gilroy, Esquire, Solicitor for Authority 10 East High Street Carlisle, PA 17014 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Adams County Domestic Relations Section 123 Baltimore Street Gettysburg, PA 17325 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 113 Pearl Drive, North Middleton Township Carlisle, PA 17013 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: Federal Tax Lien Holders - None Condo/Homeowners Association - None 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. sec. 4904 relating to unsworn falsification to authorities. DATED: MJU#: 13050274 CASE#: 13050274-1 i "- UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE rn rn r -o Z c� NO. 13-7295 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Matthew Dalinsky a/k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Your house (real estate) at 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $199,978.44, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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. 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 on page two 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 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 by calling 856-669-5400. 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 856-669-5400. 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 the 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 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s # udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jessica Dalinsky a/k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 • cn Fri Your house (real estate) at 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $199.978.44, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To fmd out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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. 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 on page two on how to obtain an attorney.) 4 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES 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 by calling 856-669-5400. 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 856-669-5400. 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 the 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 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F'L EU -OFF SCE Sheriff �� �F Elu)ra�i s�r E FROTH rt0 1Ati'r; Jody S Smith 2: 33 ��! 4 SEP ! 0 PHChief Deputy r Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA PNC Bank, N.A. vs. Jessica Dalinsky a/k/a Jessica A. Dalinsky (et al.) Case Number 2013-7295 SHERIFF'S RETURN OF SERVICE 06/16/2014 05:07 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Matthew Dalinsky, husband, who accepted as "Adult Person in Charge" for Jessica Dalinsky a/k/a Jessica A. Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013, Cumberland County. 06/16/2014 05:07 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Matthew Dalinsky a/k/a Matthew A. Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013, Cumberland County. 06/16/2014 05:31 PM - Deputy Shawn Harrison, 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 113 Pearl Drive, Carlisle, PA 17013, Cumberland County. 09/02/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $874.65 SO ANSWERS, September 04, 2014 RONNS' R ANDERSON, SHERIFF �s 97f 3 /094 3 c) (lountyS lite Sherif`. 7eleosott, Inc. On May 19, 2014 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Known and numbered as, 113 Pearl Drive, Carlisle, as Exhibit "A" filed with this Writ and by this Reference 14_11' ':-- (f) iftorporated herein. co Ire: May 19, 2014 , By: ket-t-teC‘l- Real Estate Coordinator LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2013-7295 Civil PNC BANK, N.A. vs. JESSICA DALINSKY a/k/a JESSICA A. DALINSKY Matthew Dalinsky a/k/a Matthew A. Dalinsky Atty.: Mark Udren ALL THAT CERTAIN tract of land with the improvements thereo- nerected situate in North Middleton Townsidp, . Cumberland County, Pennsylvania, bounded and de- scribed as follows: Being Lot No.7 on Plan No.6 of Noll Manor, as re- corded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 22, Page 163, containing 85 feet along Pearl Drive, having a depth along the west along Lot No.8 of 304.06 feet, having a width in the rear along the North of 89.21 feet, and having a depth along the east along Lot No.6 on Plan No.5 of Noll Manor of 327.78 feet. BEING KNOWN AS: 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013. PROPERTY ID NO.: 29-16-1094- 066. TITLE TO SAID PREMISES IS VESTED IN MATTHEW A. DALINSKY AND JESSICA A. DALINSKY, HUS- BAND AND WIFE BY DEED FROM ROBERT T. SCHOLLY AND BRENDA R. SCHOLLY, HUSBAND AND WIFE DATED 08/21/2007 RECORDED 08/23/2007 IN DEED BOOK Instru- ment # 200732987. 35 II PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND: Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 11, July 18 and July 25, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. arie Coyne, Edi or SWORN TO AND SUBSCRIBED before me this 25 day of July, 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 The Patriot -News Co. 1900 Pqtriot Drive -.Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 thepatriotaNews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Amy Kotula, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Ci Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place an character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION Ca Y 2013-7295 ChM Ter PNC BANK, N.A. vs. JESSICA DALINSKY A/K/A JESSICA A. DAUNSKY Matthew DalInsky a/k/a Matthew A. Dalinsky Any: Mark Udren ALL THAT CERTAIN TRACT OF IAND WITH THE IMPROVEMENTS THEREONERECIED SITUATE IN NORTH TOWNSHIP, :CUMBERLAND --^~~~~i COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: PLAN NO.6 OF NOLL MANOR, AS RECORDEWili-Trit OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY - IN PLAN BOOK_22.. PAGE 161 This ad ran on the date(s) shown below: 07/13114 07/20/14 07/27/14 subscribed before me this 20 day of August, 2014 A.D. COMMONWEALTH CF PENNSYLVANIA NOTARIAL SEAL Sheryl Marie Leggore,wmarypumic Hampden Twp.. Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA """=°..~. OF ,..'^.^' UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff V. Jessica Dalinsky a/k/a Jessica A. Dalinsky; Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF C - COURT OF COMMON PLEAS c -NA CIVIL DIVISION CUMBERLAND County r) NO. 13-7295 Civil MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the Notice of Sale upon Defendant(s): MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY, by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1 Process was unable to be served at the then last known address of said Defendant(s) as follows: MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY 43 PLEASANT HALL ROAD CARLISLE, PA 17013 A copy of the Return of Service is attached hereto as Exhibit "A". 2. Process was unable to be served at the then last known address of said Defendant(s follows: MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY 113 PEARL DRIVE CARLISLE, PA 17013 A copy of the Return of Service is attached hereto as Exhibit "B". iT C 3. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit "C". 4. Said investigation was unable to determine an alternate address for said Defendant(s). 5. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said in paragraph 1, by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. B Attorneys for Plaintiff ELIZABETH L WASSALL, ESC, PA ID 77788 PNC 13nnk, National Association. et. al.. Plaintiffs) vs. Jessica Dalinsky aka Jessica A. Dalinsky, et. al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003.3620 mer File: N13050274-1 Service of Process by APS International, Ltd. 1-800-328-7171 APS international Plaza 7800 Clenroy Road Minneapolis. MN 55439-31.22 APS File ft: 131186-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Stale o County o Name of Sc Service of Process on: --Matthew Dalinsky, aka Matthew A. Dalinsky Court Case No. Cumberland Co 13-7295 Civil , undersigned, being duly sworn. deposes and says that at all tunes mentioned heein. s/he was of legal age and was not a party to this action; Documents Served: the undersigned attempted to serve the documents described as: Notice of Sheriff's Sale of Real Properly Service of Process on: The undersigned attempted to serve the documents on Matthew Dalinsky, aka Matthew A. Dalinsky Attempts: and after due and diligent efforts. was unable to effect service. The following is a list of the attempts made to effect service: nntesll'imelAddress Attempted: 43 Pleasant Hail Road. Carlisle, PA 11013 Reason for Non-Servier hales rimeliddrrss Aiiempted: Reason for Non -Service? flales/Tinte/Addrtss Attempted: Reason (or Non -Sender: Signature of Server: sed upon the above tlndersi tha arhSe (o/1 (0'114 5n(LP(4- _ CACI atioic ated facts, Affiant beliedes the defendant is avoiding service. laves un• ► alty of perj //�� ubscr.ib d and swo ► to before me this n is -.e and �•rrect. 20 Orr �`H /Xr-ie.gr % Notary Public / (Commission Expires) ntern onal, Ltd. 41✓ p 104 COM •HWS a Public No3AR1A.� SEAQ 11 k'tomcat.L. Ctu a G++tbl oro,Cuinba nd Count,/ ,/ Cottboon Expires Sept. -, 2 ,F o YlVA141A tis EXHIBIT A PNC Bank, National Association, et. at.. Plaintiff(s) vs. Jessica Dalinsky aka Jessica A. Dalinsky. el. al.. Defendants) t1DREN LAW OFFICES Ms. Henni Crommarly 111 Woodcrest Rd., Ste. 200 Cherry Hill. NJ 08003-3620 Customer File: N13050274-1 Service of Process by APS International, Ltd. I-800-328-7171 APS International Plaza 7800 Glenroy Road Minneapolis. MN 55439.3122 APS File N: 131407-0001 AFFIDAVIT OF DUE AND DILIGENT ATTEMPT Service of Process on: —Matthew Dalinsky, aka Matthew A. Dalinsky Court Case No. Cumberland Co 13-7295 Civil Sate o County of: Name of Server: ss. undersigned, being duly sworn, deposes and says that at all times mentioned her i , s/he was of legal age and was not a party to this action: Documents Served: the undersigned anempted to serve the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: The undersigned attempted to serve the documents on Matthew Dalinsky, aka Matthew A. Dalinsky Attempts: and after due and diligent efforts, was unable to effect service. The following is a list of the attempts made to effect service: 1)atrafflmt/Address Attempted:113 Pearl Drive. North Middleton Township. Carlisle. PA 17013 Reason fur Non -Service: Dates/lime/Address Attempted:/? Reason for Non-Senice• Ilntcsfrime/Address Attempted: Reason fur Non -Service: Signature of Server: 4 Based ndersi at ier upon [ile above st Xfirkit believes the defendant is avoiding service. d declares under penal . o/. egoing,is true and cojorx ry Subscr..bed and sworn to before me this *4 da *fI /":• - 11.111111110.1:4... ..4 • r h j C 20 E�ftires) A. Interna CO}dMONWEAL NOTARIAL SES Public Townie L. Crotchet, Notary Dully 9 2015 Carlisle is ion E Aires Sept Berland C ,F tloi My Commission P. OGtA 10 Tonal, L usu.. 1ES EXHIBIT B Affidavit of Good Faith Investigation At the request of the lfirm 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: 13050274'1 Attorney/Law Firm: UDREN LAW OFFICES, P.C. (PA) Subject Name: MATTHEW DALINSKYNK/A MATTHEW A. DALINSKY Property Address: Street: 113 Pearl Drive, North Middleton Township - City: Carlisle State: PA Zip: 17013 Sklp Results: Date of Birth: MS Last Known Address (as of10/1/2014)Street: 43Pleasant Hall Rd City: Carlisle State: PA ProVest File Number: 4109052 Zip: 17013 8627 Death Record Search As of 10/01/2014the Social Security Administrationhmonodeath record on file for Matthew Dalinsky a/k/a Matthew A Dalinsky. Social Security Number DQVehfed[]Not Verified 8SN# Employment Search During a search for employment of our defendant no employment information was provided prior to the investigation or found during the Investigation. Business Records Search No business records found. Creditor Header Inquiry The latest addresses from the credit header info are: AUdrous1:43PLEASANT HALL RD, CARLISLE, PA17O138G27 Address2: 113 PEARL DR, CARLISLE, PA 17013 1045 Department of Motor Vehicle Records Search* Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Drivers License Information Search pq Non-governmental No verifiable information. Professional Licenses Search No records found. Freedom Of Information Act Inquiry Made to U.S Postal Service FREEDOM OF INFORMATION ACT INQUIRY MADE TO U.S. POSTAL SERVICE: THE FOLLOWING ADDRESSES WERE SENT TO THE UNITED STATES POSTAL INSPECTOR AT THE ZIP CODE LISTED WITH NO RETURN INFORMATION TO DATE: 113 PEARL DRIVE, NORTH MIDDLETON TOWNSHIP I CARLISLE PAI17O13ICUMBERLAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty inquiry of Relatives Neighbors, & Friends . Called possible relative, Fay Minich, answering machine answered, no message left. Comments: Called number listed to defendant, Matthew Dalinsky, there was no answer. 4111.1111111. Called number listed to defendant, Matthew Dalinsky, number has been disconnected. CeUednumber listed todefendant, [Nm�hewDo/insky. numberhaobeondio�onnented� A search of Federal Bureau of Prisons resulted in no records for our defendant. A search of Penns | i Department of Corrections resulted in no records for our defendant. Our defendant was not found to be currently incarcerated searching EXHIBIT C Pennsylvania County Jails. A search of Philadelphia Prison Systems resulted in no records for our defendant. Google: no additional records found Facebook: no poe listed LinkedIn: no records found * 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, Ml, 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 unsworn falsification to authorities. Under penalties of perjury, I declare that I have read the foregoing affidavit and that the facts stated in it are true. STATE OF FLORIDA siU.i�r��p,. COUNTY OF HILLSBOROUGH i (. I (� 2014 anna Hemandez ProVest File Number: 9052 Sworn to or affirmed and signed before me on this _ day of Provest Services LLC (Seal) Date: \ 0 1 O a 1 �e t 9 JOEHUA N. PIMENTEL NOtsry Public, State of Florida d'tiumm. Expires May 24, 2015 No. EE 970 Printed Name of Notary Public ersonally Known ( ) Produced as identification UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff V. Jessica Dalinsky a/k/a Jessica A. Dalinsky; Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 13-7295 Civil MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Infoiniation Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Returns of Service marked Exhibits "A" and "B" the Sheriff and/or Process Server has been unable to serve the following Defendant(s) at their last known addresses. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "C". WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale upon Defendant(s) by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. B Attorneys for Plaintiff ELIZABETH L WASSALL, ESQ PA ID 77788 VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to make this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. Date: UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff ELIZABETH L WASSALL, ESc PA ID 77788 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky; Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 13-7295 Civil CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on each of the attached parties or their attorneys this 16TH day of October, 2014. Udren Law Offices, P.C. Attorney for Plaintiff By: ELIZABETH L WASSALL, ESC: PA ID 77788 SERVICE LIST CUMBERLAND COUNTY, PENNSYLVANIA CCP. No. Docket Number: 13-7295 Civil NAME: MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY MAILING ADDRESS: 43 PLEASANT HALL ROAD CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky; Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) NO. 13-7295 Civil ORDER AND NOW, this 2.2.4 day of Otkal-4F , 2011 , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), Matthew Dalinsky a/k/a Matthew A. Dalinsky, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 113 PEARL DRIVE CARLISLE, PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY 43 PLEASANT HALL ROAD CARLISLE, PA 17013 c> r T, C -Cry irtisr.cL 44-ky e. w�SSaLL 1012,05/ BY THE COURT: �-, CD VINVA 11kSNN3d A!NROO QNv32l3OW113 6O:4Wd Z l3a}1IOz k3VIONOH1Odd 3H1 JO 331J.:10-031 -n r rn C3 '11 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin l s i udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: -n 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. 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. sec. 4904 relating to unsworn falsification to authorities. Dated: MJU#: 13050274 CASE#: 13050274-1 UDREN •• • ICES, P.C. l l ii WV BY: Attorn AMANDA L. RAVER. ESQUIRE PA. I.D. # 3O701.: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a�udren.com PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, National Association , Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, 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: 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Jessica Dalinsky a/k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Jessica Dalinsky A/K/A Jessica A. Dalinsky Downey School (POE/3RD Grade Teacher) 1313 Monroe Street, Harrisburg, PA 17103 Matthew Dalinsky a/k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Jessica Dalinsky a/k/a Jessica A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Jessica Dalinsky A/K/A Jessica A. Dalinsky Downey School (POE/3RD Grade Teacher) 1313 Monroe Street, Harrisburg, PA 17103 Matthew Dalinsky a/k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Citibank N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 North Middleton Authority, Hubert X. Gilroy, Esquire, Solicitor for Authority 10 East High Street Carlisle, PA 17014 LVNV Funding LLC 55 Beattie Place, Suite 110 Greenville, SC 29601 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 113 Pearl Drive, North Middleton Township Carlisle, PA 17013 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: Federal Tax Lien Holders - None Condo/Homeowners Association - None 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. sec. 4904 relating to unsworn falsification to authorities. DATED: 14 15 1 el MJU#: 13050274 CASE#: 13050274-1 UD N it ICES, P.C. A Pior; AMAN RAUER. ESQUIRE PA. 6 . D . # 307028 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ' ` : a , `ationa ssociation Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY; MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): JESSICA DALINSKY A/K/A JESSICA A. DALINSKY; MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY; PROPERTY: 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 12/03/2014 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 13050274 CASE#: 13050274-1 EXHIBIT A Name and Address of Sender Venni Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ❑Registered ❑ Insured ❑ COD ❑ Certified ❑ Return Receipt for Merchandise ❑ Int'l Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance ❑ Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 12/03/2014 Citibank N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 2 North Middleton Authority, Hubert X. Gilroy, Esquire, Solicitor for Authority 10 East High Street Carlisle, PA 17014 780 r 4, , li >- 3 3 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013��5, x oz`s 4 13-7295 Civil Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 v� 5 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 PA 17128-1230 J.S. POSTAG ZIP 08003 ) 2 111 )00138709 1 16-,-.1Harrisburg, 6 Tenants/Occupants 113 Pearl Drive, North Middleton Township Carlisle, PA 17013 1--'1 M 7 X Ul8 9 10 11 12 Total number of Pieces Listed by ender Total Nu, ber of Pieces Receiv . at Post Office Post ' er (Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnego iable documents under Express Mail document reconstruction insurance is $50,000 per p'ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, 5913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Jessica Dalinsky a/k/a Jessica A. Dalinsky - MJU# 13050274-1 (Cumberland County) Matthew Dalinsky a/k/a Matthew A. Dalinsky - MJU# 13050274-1 (Cumberland County) Name and Address of Sender i-,—,---,-.- ~-`---,-.-Address Jbulie=lloos❑ UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 Registered ❑ Insured ❑ COD ❑ Certified ❑Return Receipt for p Merchandise ❑ Int'! Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Art. cle Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 13-7295 LVNV Funding LLC, 55 Beattie Place, Suite 110, Greenville, SC 29601 2 3 12/03/2014 _ U.S. POSTAGE» PITNEY BOWES cl �� 0 ZIP 08003 $ 001.30 02 1104OCT02. 2014. "-. 0001387090 . 4 5 6 7 8 9 H M 10CO Fest M 11 Xt!f 12 W 13 14 15 Total number of Pieces Listed by Sender Total Numb - . f P*es Received .. ' ost Office ` Pos c aster, ' • er (Nance of Receiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $50,000 per p'ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, 5913, and S92I for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage international Special handling 1 1r 1; on mail. charges apply only to third and forth class parcels. PS Form 3877, February 1994 / Form Must be Completed by Typewriter, Ink or Ball Point Pen Jessica Dalinsky a/k/a Jessica A. Dalinsky - MJU# 13050274-1 (Cumberland County) Matthew Dalinsky a/k/a Matthew A. Dalinsky - MJU# 13050274-1 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County MORTGAGE FORECLOSURE NO. 13-7295 Civil VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY 43 PLEASANT HALL ROAD, CARLISLE, PA 17013 DATE MAILED: October 24, 2014 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: November , 2014 MJU#: 13050274 CASE#: 13050274-1 EXHIBIT B UD BY: Atto AMAND' . RAUER. ESQUIRE 'P/A. I.I . # 307028 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky; Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) NO. 13-7295 Civil ORDER AND NOW, this Z2 S day of Oddly' , 201'i , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), Matthew Dalinsky a/k/a Matthew A. Dalinsky, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 113 PEARL DRIVE CARLISLE, PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY 43 PLEASANT HALL ROAD CARLISLE, PA 17013 ac.'Y e. W�sraLL. /op* r.� BY THE COURT: \11NVAIASNN3d AiNfl00 QHV1839Wf10 60 ='FWd ZZ 1301iIOZ AMNNCNI0dd 3H1 O 331.430-0311 rt.) EXHIBIT [� Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) # 13050274-1 9. I!99 999, �031.9oa ,�94 MATTHEW DALISNKY A/K/A MATTHEW A. DALINSKY 43 PLEASANT HALL ROAD CARLISLE, PA 17013 U.S. POSTAGE ii PITNEY BOWES ZIP 08003 $ 005.i 30 02 1YV 0001387090 OCT. 24 2014 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings®udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY, MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY Defendant(s) TO: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE j NO. 13-7295 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Matthew Dalinsky a/k/a Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 Your house (real estate) at 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $199,978.44, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. 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: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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. 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 on page two on how to obtain an attorney.) EXHIBIT 13 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES 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 by calling 856-669-5400. 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 856-669-5400. 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 the 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 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO 'YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCJDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 EXHIBIT B ro�Xl/YIh�Y-iii Name and Address�� of Sender / UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 Registered ❑ Insured ❑ COD ❑ Certified Return Receipt for p Merchandise ❑ Intl Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance ❑ Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Art'cle Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 13-7295 Matthew Dalisnky A/K/A Matthew A. Dalinsky 43 Pleasant Hall Road Carlisle, PA 17013 > __; 2 3 12/03/2014 4 5 Site 4IMMINENNi 08003 $ 1v 013870900 z 0 -- 1 6 aa 7 8 f'-- 11 co 9 T1, +L 10 lid il y, *tid. • 11 W 12 13 14 15 Total number of Pieces Listed by Sender 1 Total Nu z.T a c Pieces Receiv ' v Office r_ Postmaster, Per (Name of Receiving Employee) The Poll declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnego iable documents under Express Mail document reconstruction insurance is $50,000 per p ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Jessica Dalinsky a/k/a Jessica A. Dalinsky - MJU# 13050274-1 (Cumberland County) Matthew Dalinsky a/k/a Matthew A. Dalinsky - MJU# 13050274-1 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY; MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY; et al ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 13-7295 Civil Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: t l IC) LY EXHIBIT 13 AMANDA L. RAUER, ESQUIRE PA. I.D. # 307028 PNC' 1lanlq National Association. et. al., Plaintiff(s) vs. Jessica Dalinsky aka Jessica A. Dalinsky. et. al, Defendant(s) UDREN LAW OFFICES Ms. Heniti Crmnmarty 111 1Voodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 S _ _ State )ss. _ County of: 1).O1tLQktn ) Service of Process by „ki, ACp. APS International, Ltd. 'ir 1-800-328-7171 APS INTE.RNATIO,NAI, ; APS International Plaza 7800 Glenroy Rd. �� Rcril� Minneapolis, MN 55439-3122 APS File k: 131517-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: —Jessica Dalinsky, aka Jessica A. Dalinsky Court Case No. Cumberland Co 13-7295 Civil Name of Server: d i�1e+lv'&-r . undersigned, being duly sworn, deposes and says that at the time of service. s/he was of legal age and was not a party to this action; that on the S'4. ,day of Oc cr x . 20 ]L, at 1! 5Fr•o'clock P M Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: at Downey School - 1313 Monroe Street the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property In Harrisburg, PA 17103 A true and correct copy of the aforesaid document(s) was served on: Jessica Dalinsky, aka Jessica A. Dalinsky 13y personally delivering them into the hands of the person to be served. By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated. that he/she resides with Jessica Dalinsky, aka Jessica A. Dalinsky at the place of service. and whose relationship to the person is: The person receiving documents is described as follows: Sex 4 ; Skin Color : Hair Color ?::;t1)-(1511 ; Facial Hair I)Ofl2 Approx. Age 3.7 ; Approx. Height 5.'Oa ; Approx. Weight ,(-10 To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury that the foregoing is true and correct. Subscribed and sworn to before me this / h day of ©c, h, . 20 /y Signature of Server APS International, Ltd. EXHIBIT 13 Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Brittany Edcius, Notary Public Lower Paxton Township, Dauphin County My commission expires April 11, 2018 oil, 6 -et (Commission Expires) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE<200 CHERRY HILL, NJ 08003-3620 856-669-5400 - , leaditi s@udren.com PNC Bank, National Association Plaintiff v. JESSICA DALINSKY A/K/A JESSICA A. DALINSKY,, _ MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-7295 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jessica Dalinsky a/k/a Jessica A. Dalinsky Downey School (POE/3RD Grade Teacher) 1313 Monroe Street Harrisburg, PA 17103 Your house (real estate) at 113 Pearl Drive, North Middleton Township, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, . of $199,978.44, obtained Hearing ROM; 2nd Floor, -Carlisle; PA 17013, to enforce the court judgment; by Plaintiff above(the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF -OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS,SHERIFF'S:SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION PNC Bank, National Association Plaintiff v. Jessica Dalinsky a/k/a Jessica A. Dalinsky; Matthew Dalinsky a/k/a Matthew A. Dalinsky Defendant(s) NO. 13-7295 Civil ORDER AND NOW, this 21 day of O01:01- , 201' , upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale on Defendant(s), Matthew Dalinsky a/k/a Matthew A. Dalinsky, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Notice of Sale by posting the mortgage premises at: 113 PEARL DRIVE CARLISLE, PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MATTHEW DALINSKY A/K/A MATTHEW A. DALINSKY 43 PLEASANT HALL ROAD CARLISLE, PA 17013 Cory irtigcL) e. WbssaLL /op* ,t1) EX%9IB BY THE COURT: VINVAI,kSNN3d AINf100 ONV183$W113 60 :'l old ZZ 1.3Oh10Z A8VION0H108d 3H1 0 301. 30-0311. T PNC Bank. National Association, et. nl., Plaintiff(s) vs. ,Jessica (Minsky alta Jessica A. Dalinsky. et. al.. Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty 11 111'oodcrest Rd„ Ste. 200 Cherry Hill. NJ 08003-3620 State of. I a )S5. County f:C1 Y1 ' (�� 1a'1c ) l Name of Server: 1i 11('-h•F+E ()t„t -cor) undersigned. being duly sworn, deposes and says that at the time of service, slhee was of legal age and was not�a party to this action; that on the �1 day of (� " L��'� ____.._ . 20 �'1s1 . at t +yJ o'clock M Service of Process by APS International, Ltd. 1-800-328-7171. al's ncrFRMflONA1, t APS International Plaza 7- 7800 Glenn)). Rd. � Minneapolis. MN 55439-3122 APS File ft: 131785-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: —Matthew Da Husky, aka Matthew A. Dalinsky by posting Court Case No. Cumberland Co 13-7295 Civil Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents; Signature of Sen al 113 Pearl Drive the undersigned served the documents described as: Notice of Sheriffs Sale of Real Properly w/ Order • in Carlisle. P,1 17013 A. true and correct copy of the aforesaid document(s) was served on: Matthew Dalinsky, nka Matthew A..Dalinsky by posting _ By personally delivering them into the hands of the person to be served. NA By delivering them into the Bands of of suitable age. %vim verified. or who upon question Matthew Dalinsky, aka al thew A. Dalinsky by posting at the place of service. and whose relationship to the person is: _ . a person ated, that he/she resides with The person receiving documents is described as follows: Sex -'Skin Color • - Hair Color 1=at iai J-Jair ... Aee : Approx. Height : Approx. Weight. To the best of my knowIedgg and belief. said person vas not engaged in the US Military at the time of service. Undersigil d declares un r f 7lty of perjury atjthe fregoindlis true !! lll�f;l� /1 iena►urr of Server APS international, Ltd. LT NOTARIAL SEAL Public Teremle L, Ctutebtr, and Cana Cedlsle Bola, Cutribodry 9, county Commission Expires Septi MY .., o ►. coWIMO s VA 6N EXHIBIT B Subscribed and sworn t before me this 1U[ •'D Nolan• ' u'bl is ommission Expires} Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY PNC Bank, N.A. vs. Jessica Dalinsky a/k/a Jessica A. Dalinsky (et al.) Case Number 2013-7295 SHERIFF'S RETURN OF SERVICE 09/26/2014 10:07 AM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Matthew Dalinsky, Husband, who accepted as "Adult Person in Charge" for Jessica Dalinsky a/k/a Jessica A. Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013, Cumberland County. 09/26/2014 10:08 AM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Matthew Dalinsky a/k/a Matthew A. Dalinsky at 43 Pleasant Hall Road, North Middleton, Carlisle, PA 17013, Cumberland County. 09/26/2014 11:54 AM - Deputy Tim Black, 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 113 Pearl Drive, North Middleton - Township, Carlisle, PA 17013, Cumberland County. SHERIFF COST: $975.74 SO ANSWERS, October 16, 2014 RONNY R ANDERSON, SHERIFF EXHIBT nn County&.,e S?ieritt. Teleosott. Inc.