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Home My WebLink About14-0450 �t Supreme Court: of _Pennsylvania COUP Co Pleas For Prothonotary Use Only: eet C E B 4 County Docket No: rte= ++,� v ( !,� / \ •.�+ �°° =�.. ��,y�'`�Y, ✓ loll" /l./) The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. S Commencement of Action: ❑D Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff s Name: SANTANDER BANK, N.A. Lead Defendant's Name: STEPHANIE J. PITTENGER T I Are money damages requested? El Yes 0 No Dollar Amount Requested: El within arbitration limits 0 (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑ Yes 0 No Is this an MDJ Appeal? ❑ Yes 0 No A Name of Plaintiff/Appellant's Attorney: John D. Krohn, Esq., Id. No.312244, Phelan Hallinan, LLP ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not S include mass tort) ❑ Employment Dispute: ❑ Slander/Libel/ Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T I MASS TORT 0 Other: 0 ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES • Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS • Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY 0 Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical 0 Other: ❑ Other Professional: Pa.R.C.P. 205.5 Updated 01/01/2011 F 0r FI�,r. __`= 1`HE H NO JAN 24 AM ll : 2 l "UI16GRLAN0 COUNTY PENNSYLVANIA PHELAN HALLINAN, LLP John D. Krohn, Esq., Id. No.312244 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 john.krohn@phelanhallinan.com 215 -563 -7000 SANTANDER BANK, N.A. 824 NORTH MARKET STREET, SUITE 100 COURT OF COMMON PLEAS WILMINGTON, DE 19801 CIVIL DIVISION Plaintiff V. TERM STEPHANIE J. PITTENGER NO. q r 1.4 t Vt 5 MATTHEW COURT CARLISLE, PA 17015 -4364 CUMBERLAND COUNTY Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE He #: 937004 1. Plaintiff is SANTANDER BANK, N.A. 824 NORTH MARKET STREET, SUITE 100 WILMINGTON, DE 19801 2. The name(s) and last known address(es) of the Defendant(s) are: STEPHANIE J. PITTENGER 5 MATTHEW COURT CARLISLE, PA 17015 -4364 who is /are the mortgagor(s) and /or real owner(s) of the property hereinafter described. 3. On 01/15/2009 STEPHANIE J. PITTENGER made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR SOVEREIGN BANK, which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200901270. By Assignment of Mortgage recorded 04/08/2013 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Instrument No. 201311073.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. Sovereign Bank is now known as Santander Bank, N.A. 5. The premises subject to said mortgage is described as attached. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2013 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date File #: 937004 specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage as of 11/14/2013: Principal Balance $119,221.1.1. Interest $2,303.02 07/01/2013 through 11/14/2013 Late Charges $424.08 Property Inspections $20.70 TOTAL $121,968.91 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). File #: 937004 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $121,968.91, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: John D. Kroh sq., Id. No.312244 Attorney for Plaintiff He #: 937004 e LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described according to the Plan for Jonathan Park prepared by Stephen G. Fisher, R.S. dated February 3, 1988 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 55, Page 27, to wit: BEGINNING at a point on the dedicated right of way of Matthew Court at the corner of Lot No. 9 of the above referred to Plan of Lots; thence along said Lot No. 9, South 12 degrees 26 minutes 46 seconds East 111.69 feet to an iron pin set; thence along Lot No. 68 as set forth in Cumberland County Plan Book 49, Page 107, South 75 degrees 50 minutes 02 seconds West 35.00 feet to an iron pin set; thence along Lot No. 7 as set forth in Cumberland County Plan Book 55, Page 27, North 61 degrees 49 minutes 38 seconds West 80.00 feet to an iron pin set; thence along said Matthew Court on a line curving to the right having a radius of 178.41 feet and an are distance of 82.95 feet to a point; thence along same, North 54 degrees 48 minutes 44 seconds East 31.72 feet to an iron pin set, the place of Beginning. BEING Lot No. 8 on the Plan for Jonathan Park as set forth in Cumberland County Plan Book 55, Page 27 and containing 6851.67 square feet. PROPERTY ADDRESS: 5 MATTHEW COURT, CARLISLE, PA 17015 -4364 PARCEL #40 -23- 0592 -124 File #: 937004 VERIFICATION an iQd W W A , hereby states that he /she is Pd m-k n wsf y&�Oy" of SANTANDER BANK, N.A., Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: d 1 1 (4> Name : �an�tlt� N� Title: AdAll niOT"v - SANTANDER BANK, N.A. File #: 937004 Name: PITTENGER File #: 937004 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 937004 i a FORM 1 IN THE COURT OF COMMON PLEAS SANTANDER BANK, N.A. OF CUMBERLAND COUNTY, PENNSYLY�1NI 1 - 4 Plaintiff(s) --' VS. r CD STEPHANIE J. PITTENGER Defendant(s) Civil C7 ,i 3 , NOTICE OF RESIDENTIAL MORTGAGE FORECLOS DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: 1123,!f Date John D. Krohn, Esq., Id. No.312244 Attorney for Plaintiff 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 counseling agency. Please provide the following information to the best of your knowledge: CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles ): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: IfWe, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Uwe am/are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson bic=t'tu Sheriff { t� : 1'r;�? } t • o-zi loo Jody S Smith 2094 FE8 I I Ply 3• I t: Chief Deputy Richard W Stewart „U � 1y�AN Y Solicitor PENNSYLVANIA Santander Bank, N.A. Case Number vs. Stephanie J Pittenger 2014-450 SHERIFF'S RETURN OF SERVICE 01/31/2014 02:43 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 Ian Pittenger, Son, who accepted as"Adult Person in Charge"for Stephanie J Pittenger at 5 Matthew Court, South Middleton, Carlisle, PA 17015. IE DIMARTL a UTY SHERIFF COST: $34.78 SO ANSWERS, February 05, 2014 RON R ANDERSON, SHERIFF SANTANDER BANK, N. A. 824 North Market Street, Suite 100 Wilmington, DE 19801 Plaintiff v. STEPHANIE J. PITTENGER 5 Matthew Court Carlisle, PA 17015 Defendant FORM 3 . IN THE COURT OF COMMON . PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 2014-450 CIVIL TERM rrt r- -< > XC) REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated January 23, 2014, governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is Defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that. Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. eorge F. Douglas, III, Esq. Date Defendant's Counsel /Appointed Legal Representative Stepha e J. Pittenger, Defendant Date CERTIFICATE OF SERVICE I, George F. Douglas, III, Esq., of Salzmann Hughes, P.C., hereby certify that a copy of the foregoing document was served this date by depositing the same via United States mail, first class mail, postage prepaid, and addressed as follows: Date: 3 /I °It Lf- John D. Krohn, Esq. 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Danielle Ninfo Foreclosure Administrator Santander Bank, N.A. 824 North Market Street, Suite 100 Wilmington, DE 19801 1 By: eorge F. Douglas, III Esquire SANTANDER BANK, N. A. • IN THE COURT OF COMMON 824 North Market Street, Suite 100 : PLEAS, CUMBERLAND COUNTY, Wilmington, DE 19801 : PENNSYLVANIA Plaintiff V. • • NO. 2014-450 CIVIL TERM --:_. 1.-) r...., ...,, ..... STEPHANIE J. PITTENGER • . 5 Matthew Court .• Carlisle, PA 17015 - . c.nr- — .6._ _.(> ._... Defendant : r- -4- ..... -, , • < C.:../ 3:m• _...77. C_Ic.... _ PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant, Stephanie J. Pittenger, in the above- referenced matter. Date: 3 g Respectfully submitted, SALZMANN HUGHES, P.C. George F. Douglas, III, Esquire Attorney ID #61886 Salzmann Hughes, P.C. 354 Alexander Spring Rd., Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorney for Defendant • CERTIFICATE OF SERVICE I, George F. Douglas, III, Esq., of Salzmann Hughes, P.C., hereby certify that a copy of the foregoing document was served this date by depositing the same via United States mail, first class mail, postage prepaid, and addressed as follows: John D. Krohn, Esq. 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Danielle Ninfo Foreclosure Administrator Santander Bank, N.A. 824 North Market Street, Suite 100 Wilmington, DE 19801 Date: 3/1 tf- By: George F. Douglas, III Esquire In Forma Pauperis Form SANTANDER BANK, N. A. 824 North Market Street, Suite 100 Wilmington, DE 19801 Plaintiff : IN THE COURT OF COMMON : PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2014-450 CIVIL TERM STEPHANIE J. PITTENGER 5 Matthew Court Carlisle, PA 17015 Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: N.) Kindly allow, STEPHANIE J. PITTENGER, single adult individual, Defendant, to proceed in forma pauperis. I, George F. Douglas, III, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. hp_c‘4r, SkTLA9A0_1.— George F. Douglas, III, Esquire, Attorney for Defendant Salzmann Hughes, P.C. 354 Alexander Spring Rd., Suite 1 Carlisle, PA 17015 (717) 249-6333 CERTIFICATE OF SERVICE I, George F. Douglas, III, Esq., of Salzmann Hughes, P.C., hereby certify that a copy of the foregoing document was served this date by depositing the same via United States mail, first class mail, postage prepaid, and addressed as follows: Date: -3 I if John D. Krohn, Esq. 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Danielle Ninfo Foreclosure Administrator Santander Bank, N.A. 824 North Market Street, Suite 100 Wilmington, DE 19801 By: George F. Douglas, III Esquire SANTANDER BANK, N. A. 824 North Market Street, Suite 100 Wilmington, DE 19801 Plaintiff v. STEPHANIE J. PITTENGER 5 Matthew Court Carlisle, PA 17015 . IN THE COURT OF COMMON . PLEAS, CUMBERLAND COUNTY, . PENNSYLVANIA • • . NO. 2014-450 CIVIL TERM • c) r,fc� y Defendant c >n Ci AND NOW, this -..� A /7� day of , 2014, the defendant/borrower the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court- supervised Conciliation Conference on � 0 0 /(at 3 ;60 /° Al in at the Cumberland County Courthouse, Carlisle, CASE MANAGEMENT ORDER 69,,mkno Pennsylvania. 2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and /or the date upon which 3 service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled Conciliation Conference. BY THE COURT co�� 0'6 :Jai 0 041 a:by/6 3pm/ .(Y1 4 4 CERTIFICATE OF SERVICE I, George F. Douglas, III, Esq., of Salzmann Hughes, P.C., hereby certify that a copy of the foregoing document was served this date by depositing the same via United States mail, first class mail, postage prepaid, and addressed as follows: John D. Krohn, Esq. 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Danielle Ninfo Foreclosure Administrator Santander Bank, N.A. 824 North Market Street, Suite 100 Wilmington, DE 19801 By: eorge F. Douglas, III Esquire SANTANDER BANK, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION — LAW : NO. 14-0450 CIVIL STEPHANIE J. PITTENGER, Defendant : MORTGAGE FORECLOSURE ORDER AND NOW, this 23 day of April, 2014, at the request of counsel for the parties, the conciliation conference set for April 25, 2014, is continued to Friday, June 20, 2014, at 2:30 p.m. in Chambers of the undersigned. D. Troy Sellars, Esquire For the Plaintiff rge Douglas, IV, Esquire For the Defendant :rlm p is a1 /If BY THE COURT, SANTANDER BANK, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION — LAW : NO. 14-0450 CIVIL STEPHANIE J. PITTENGER, Defendant : MORTGAGE FORECLOSURE ORDER AND NOW, this 17 day of June, 2014, at the request of counsel for the parties, the conciliation conference set for June 20, 2014, is continued to Friday, September 19, 2014, at 1:30 p.m. in Chambers of the undersigned. seph Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff George F. Douglas, III, Esquire 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 For the Defendant :rim 411Q_S PaAttErt 118fri BY THE COURT, C-7 ry C C :.> .., -0a - --I rn 0:3 rn -, cnt -‹ . c,c • < CD r -- › f. CC CD •F-- - . -- .z'- SANTANDER BANK, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION — LAW : NO. 14-0450 CIVIL STEPHANIE J. PITTENGER, Defendant : MORTGAGE FORECLOSURE ORDER AND NOW, this /41 day of September, 2014, after conciliation conference, this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay entered in this case is lifted. ph Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff ge F. Douglas, III, Esquire 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 For the Defendant :rlm BY THE COURT, `.7" Santander Bank, N.A. ?r Plaintiff Stephanie J. Pittenger Defendant(s) rj 2011i OCT 30 LOU11. PE': i l IS :_'f f'\ t COURT OF COMMON PLEAS CIVIL DIVISION NO.: 14 -450 -CIVIL CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 Santander Bank, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 5 Matthew Court, Carlisle, PA 17015- 4364. 1. Name and address of Owner(s) or reputed Owner(s): Name Address; (if address cannot be reasonably ascertained, please so indicate) Stephanie J. Pittenger 5 Matthew Court Carlisle, PA 17015-4364 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) Stephanie J. Pittenger 5Matthew Court Carlisle, PA 17015-4364 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Namc Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name . Address (if address cannot be reasonably ascertained, please indicate) 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. Name Address (if address cannot be reasonably ascertained, please indicate) Jonathan Park Homeowners Association 6 East High Street Carlisle, PA 17013 PH # 937004 Santander Bank, N.A. _,.., r 7 ,2.1 Stephanie J. Pittenger t TV aiJ 7 S 6 rA vs. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION : NO.: 14 -450 -CIVIL Defendant(s) : CUMBERLAND County NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Stephanie J. Pittenger 5 Matthew Court Carlisle, PA 17015-4364 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 5 Matthew Court, Carlisle, PA 17015-4364 is scheduled to be sold at the Sheriff's Sale on 03/04/2015 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $121,968.91 obtained by Santander Bank, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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. 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 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. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 14 -450 -CIVIL Santander Bank, N.A. v. Stephanie J. Pittenger owner(s) of property situate in SOUTH MIDDLETON TOWNSHIP, CUMBERLAND County, Pennsylvania, being 5 Matthew Court, Carlisle, PA 17015-4364 Parcel No. 40-23-0592-124 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $121,968.91 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described according to the Plan for Jonathan Park prepared by Stephen G. Fisher, R.S. dated February 3, 1988 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 55, Page 27, to wit: BEGINNING at a point on the dedicated right of way of Matthew Court at the corner of Lot No. 9 of the above referred to Plan of Lots; thence along said Lot No. 9, South 12 degrees 26 minutes 46 seconds East 111.69 feet to an iron pin set; thence along Lot No. 68 as set forth in Cumberland County Plan Book 49, Page 107, South 75 degrees 50 minutes 02 seconds West 35.00 feet to an iron pin set; thence along Lot No. 7 as set forth in Cumberland County Plan Book 55, Page 27, North 61 degrees 49 minutes 38 seconds West 80.00 feet to an iron pin set; thence along said Matthew Court on a line curving to the right having a radius of 178.41 feet and an arc distance of 82.95 feet to a point; thence along same, North 54 degrees 48 minutes 44 seconds East 31.72 feet to an iron pin set, the place of Beginning. BEING Lot No. 8 on the Plan for Jonathan Park as set forth in Cumberland County Plan Book 55, Page 27 and containing 6851.67 square feet. UNDER AND SUBJECT to a Declaration of Covenants and Restrictions for Jonathan Park recorded in the Office aforesaid in Misc. Book 321, Page 292. TITLE TO SAID PREMISES IS VESTED IN Stephanie J. Pittenger, adult individual, by Deed from Michael S. Wagner and Linda S. Wagner, his wife, dated 01/15/2009, recorded 01/15/2009 in Instrument Number 200901269. PREMISES BEING: 5 Matthew Court, Carlisle, PA 17015-4364 PARCEL NO. 40-23-0592-124 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 SANTANDER BANK, N.A. Vs. STEPHANIE J. PITTENGER WRIT OF EXECUTION NO 14-450 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $121,968.91 L.L.: $.50 Interest FROM 10/31/2014 TO DATE OF SALE ($20.05 PER DIEM) - $2,506.25 Atty's Comm: Atty Paid: $183.53 Plaintiff Paid: Date: 10/30/14 (Seal) REQUESTING PARTY: Name: JONATHAN LOBB, ESQUIRE Address: PHELAN HALLINAN, LLP 1617 JFK BLVD., SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 312174 Due Prothy: $2.25 Other Costs: David D uell, Prothonotary By: Deputy PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Santander Bank, N.A. Plaintiff v. Stephanie J. Pittenger Defendant(s) , To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 10/31/2014 to Date of Sale ($20.05 per diem) TOTAL Note: Please attach description of property. PH # 937004 4'.�Lpd a ie esk-ou 10 ?.7S 11 1/ d 6 16, s3i a COURT OF COMMON PLEAS : CIVIL DIVISION NO.: 14 -450 -CIVIL CUMBERLAND COUNTY $121,968.91 $2,506.25 $124,475.16 Ph n Hallinan, LLP Jo athan Lobb, Esq., Id. No.312174 Attorney for Plaintiff ,§6_,Psof s--0R# 310-79 GL U.# /VW026S ��d LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described according to the Plan for Jonathan Park prepared by Stephen G. Fisher, R.S. dated February 3, 1988 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 55, Page 27, to wit: BEGINNING at a point on the dedicated right of way of Matthew Court at the corner of Lot No. 9 of the above referred to Plan of Lots; thence along said Lot No. 9, South 12 degrees 26 minutes 46 seconds East 111.69 feet to an iron pin set; thence along Lot No. 68 as set forth in Cumberland County Plan Book 49, Page 107, South 75 degrees 50 minutes 02 seconds West 35.00 feet to an iron pin set; thence along Lot No. 7 as set forth in Cumberland County Plan Book 55, Page 27, North 61 degrees 49 minutes 38 seconds West 80.00 feet to an iron pin set; thence along said Matthew Court on a line curving to the right having a radius of 178.41 feet and an arc distance of 82.95 feet to a point; thence along same, North 54 degrees 48 minutes 44 seconds East 31.72 feet to an iron pin set, the place of Beginning. BEING Lot No. 8 on the Plan for Jonathan Park as set forth in Cumberland County Plan Book 55, Page 27 and containing 6851.67 square feet. UNDER AND SUBJECT to a Declaration of Covenants and Restrictions for Jonathan Park recorded in the Office aforesaid in Misc. Book 321, Page 292. TITLE TO SAID PREMISES IS VESTED IN Stephanie J. Pittenger, adult individual, by Deed from Michael S. Wagner and Linda S. Wagner, his wife, dated 01/15/2009, recorded 01/15/2009 in Instrument Number 200901269. PREMISES BEING: 5 Matthew Court, Carlisle, PA 17015-4364 PARCEL NO. 40-23-0592-124 PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 Santander Bank, N.A. Plaintiff v. Stephanie J. Pittenger Defendant(s) CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 14 -450 -CIVIL . CUMBERLAND County The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: the mortgage is an FHA Mortgage the premises is non -owner occupied the premises is vacant Act 91 procedures have been fulfilled Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Phan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 ` Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 SANTANDER BANK, N.A. vs. STEPHANIE J. PITTENGER ti if : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 14 -450 -CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against STEPHANIE J. PITTENGER, Defendant(s) 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 Plaintiff's damages as follows: As set forth in Complaint $121,968.91 TOTAL $121,968.91 I hereby certify that (1) the Defendant's last known address is 5 MATTHEW COURT, CARLISLE, PA 17015-4364, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date �ohq/14/ athan Lobb, Esq., Id. No.312174 Attorney f•' `laint 7 DAMAGES ARE 1 H REBY ASSESSED AS INDICATED. I C y DATE: j 0 17 PH # 937004 CC: GEORGE F. DOUGLAS, III, ESQUIRE PROTHONOTARY an„--s16.56pACA.any 937004 g 6 3 3Ji9o1 No 'ce /fla e PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 SANTANDER BANK, N.A. vs. STEPHANIE J. PITTENGER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 14 -450 -CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) STEPHANIE J. PITTENGER is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) that defendant STEPHANIE J. PITTENGER is over 18 years of age and resides at 5 MATTHEW COURT, CARLISLE, PA 17015-4364. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date / 2- q 11( Phel . - allinan, LLP Jon. than Lobb, Esq., Id. No.312174 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 937004 Department of Defense Manpower Data Center Stats Report Pursuant to Servicetneinbers Civil Relief Act Last Name: PITTENGER First Name: STEPHANIE Middle Name: J Active Duty Status As Of: Oct -29-2014 Results as of : Oct -29-2014 12:06:09 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No - NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 (Rule of Civil Procedure No. 236) - Revised SANTANDER BANK, N.A. : CUMBERLAND COUNTY vs. : COURT OF COMMON PLEAS STEPHANIE J. PITTENGER • : CIVIL DIVISION : No. 14 -450 -CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on 1O' If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM ISA DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 937004 SANTANDER BANK, N.A. v. STEPHANIE J. PITTENGER Plaintiff Defendant(s) TO. GEORGE F. DOUGLAS, III, ESQUIRE 354 ALEXANDER SPRING ROAD, SUITE] CARLISLE, PA 17015 DATE OF NOTICE: e COURT OF COMMON PLEAS CIVIL DIVISION NO. 14 450 -CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PH # 937004 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 Kenya aces, Esq., Id. No.203664 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 SANTANDER BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. STEPHANIE J. PITTENGER Defendant(s) TO: STEPHANIE .1. PITTENGER 5 MATTHEW COURT CARLISLE, PA 17015-4364 DATE OF NOTICE: �1;?/5"J NO. 14 -450 -CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: PH # 937004 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 Kenya ,B, tes, Esq., Id. No.203664 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PLAINTIFF SANTANDER BANK, N.A. DEFENDANT STEPHANIE J. PITTENGER AFFIDAVIT OF SERVICE (FHLMC) CUMBERLAND COUNTY PH # 937004 SERVICE TEAM/ Ixh COURT NO.: 14 -450 -CIVIL SERVE STEPHANIE J. PITTENGER AT: 5 MATTHEW COURT CARLISLE, PA 17015-4364 TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: March 4, 2015 'i DEC 30 9: , CUMBERLAND co i::: PENNSYLVANIA SERVED Served and made known to STEPHANIE J. P111'hNGER, Defendant on the 3!day of AFek 1/5 EA 20 (4, at 6 : 29 o'clock t' M., at S M4 -r1-1 w ColiRliCkatIsLC f PA in the manner described below: Defendant personally served. ✓Adult family member with whom Defendant(s) reside(s). Relationship is So M . _ Adult in charge of Defendant's residence who refused to give name or relationship. — Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age e26 S Height 55'11 N Weight (Qb_ Race W Sex M Other Ronald Moll . a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: NAME: PRINTED NAME: Ronald Molt TITLE: Process Server NOT SERVED On the day of,20 , at o'clock . M., I, state that Defendant NOT FOUND ecause: — Vacant Does Not Exist , a competent adult hereby Moved , Does Not Reside (Not Vacant) No Answer on at at Service Refused Other. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: r.A-- 222