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HomeMy WebLinkAbout14-0527 Supreme Court of Pennsylvania Court bf Common Pleas ` / , ti. 1 FarPaotltonotan Use On1r CA - 1 - 1 , •oi.ei Sheet � � Ir CUlllb @i'l�dll( f Cou nty DockEtNo: The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: X Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: GREEN TREE SERVICING LLC CHAD D. SEIBER C MELISSA R. SEIBER T Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑Yes No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes NO Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented (Pro Se Litigant Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) 11 Employment dispute: C ❑ Slander/Libel Defamation Discrimination ❑ Other ❑Employment Dispute: Other T ❑ Other: 0 MASS TORT ❑ Other N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑ Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 —BNY MELLON INDEPENDENCE CENTR • .�. -y iii' 701 MARKET STREET "' �" 0 T, �l�3��1� (866) 413-2311 PA 19106 29! It j j�H 7 AH 11 : WWW.KMI,LAWGROUP.COM J8 GREEN TREE SERVICING LLC `Et�� H i11) '�oU q � THE COURT OF COMMON PLEAS 345 St Peter Street PE Nt 4 SYLV NIA 1100 Landmark Towers OF Cumberland COUNTY St Paul, MN 55102 Plaintiff CIVIL ACTION - LAW VS. CHAD D. SEIBER ACTION OF MORTGAGE FORECLOSURE MELISSA R. SEIBER Mortgagor(s) and Record Owner(s) 1, 5225 Wertzville Road No. _l' Enola, PA 17026 C1VJL.ACTION: MORTGAGI Defendant(s) NOTICE 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717 - 243 -9400 AVISO Le 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 defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PA glu3 �S� AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. a't , '7 511 U %I e). SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717 - 243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http: / /www.phfa.org/ consumers /homeowners /real.aspx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http: / /www.philadelphiafed.org /foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretention kkmllawgroup.com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and /or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 125406FC. Para informacion en espanol puede communicarse con Loretta a1215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is GREEN TREE SERVICING LLC, 345 St Peter Street, 1100 Landmark Towers St Paul, MN 55102. 2. The name(s) and address(es) of the Defendant(s) is /are CHAD D. SEIBER, 5225 Wertzville Road, Enola, PA 17025 and MELISSA R. SEIBER, 5225 Wertzville Road, Enola, PA 17025, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On April 28, 2003 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR QUICKEN LOANS, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on May 09, 2003 as Book 1810 page 3977. The mortgage has been assigned to: GREEN TREE SERVICING LLC by assignment of Mortgage recorded on July 10, 2013 as Instrument #201322720. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property ") 5. ' The mortgage is in default because the monthly payments of principal and interest are due and unpaid for May 01, 2011 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ............................... ............................... ....................$114,820.74 Interest from 04/01/2011 through 11/08/2013 at 5.8750% .....................$17,556.08 Per Diem interest rate at $18.49 LateCharges ................................................................. ............................... $116.32 Escrow.................................................. ............................... ......................$8,503.27 Unapplied Funds ......................................................... ............................... ($850.17) Corporate Advance ...................:........... ............................... ........................$985.80 Reasonable Attorney's Fee .................. ............................... ............ ..........$1,650.00 $142,782.04 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit `B ". The Defendants have not had the required face -to -face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $142,782.04, together with interest at the rate of $18.49, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: KML LAW GROUP, P. A.II) Michael McKeever 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua 1. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION 1, t �,�'�� as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: #125406FC - CHAD D. SOBER and MELISSA R. SEIBER 5225 Wertzville Road Enola, PA 17025 EythibitA Exhibit A - LEGAL DESCRIPTION Deal Number: 11- 00387548 -RK Title Number: 11- 01117937 REV. NO. Tax ID Number: 10 -14- 0840 -005 Land situated in the County of Cumberland, State of Pennsylvania Beginning at a point in the center of the Enola- Wertzville Road, which point is a corner of Lot No. 4 on the hereinafter mentioned plan of lots; thence along the line of Lot No. 4, South 01 degrees 30 minutes West 404.60 feet to a point in line of land of E. R. Long; thence along land of said E. R. Long, North 84 degrees West 100.40 feet to a point in line of Lot No. 2, on the hereinafter mentioned plan of lots; thence along line of Lot No. 2, North 01 degrees 30 minutes East 385.30 feet to a point in the center of the . aforesaid Enola - Wertzville Road; thence in an Eastwardly direction along the center of said Enola - Wertzville Road, North 85 degrees 11 minutes East 100.00 feet to a point, the place of beginning. Being all of Lot No. 3 on that certain Plan of Lots laid. out and adopted by Harriet S. Raudabaugh on the 3rd day of March, 1955, said plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, Plan Book 7, Page 26. Commonly known as; 5225 Wertzville Rd, Enola, PA 17025 I Certify this to be record - -.. i Cumberland County Y T` w /J l h' Recorder of Deeds 6K 181 OPG3993 Ey� �B *Exhibit has been redacted to remove all personally identifiable information or non-public information HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM Date: 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 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 any 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 NOTIFICATION OBTENGA UNA TRADUCCION IMMEDIATAMENTE 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. i Date: 10/21/2013 HOMEOWNER'S NAME(S): CHAD D. SEIBER and MELISSA R. SEIBER PROPERTY ADDRESS: 5225 Wertzville Road, Enola, PA 17025 LOAN ACCT. NO.: M7342 ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR QUICKEN LOANS, INC. CURRENT LENDER/SERVICER: GREEN TREE SERVICING LLC / GREEN TREE SERVICING 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 (33) DAYS OF 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 agencies 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 for the county in which the property 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. 2 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 HEMAPAPPLICATION SOONAS POSSIBLE IF YOU IM VE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PRE VENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HA VE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS ALA TE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING FORECLOSUREACTION, 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: 5225 Wertzville Road, Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: 3 A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 05/01/2011 thru 10/21/2013 (16 mos. at $1,058.41 /month) $16,934.56 (12 mos. at $1,144.81 /month) $13,737.72 (1 mos. at $1,148.31 /month) $1,148.31 (1 mos. at $1,191.35 /month) $1,191.35 (b) Late charges $116.32 (c) Other charges; Escrow, Inspec., NSF Checks: (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $33,128.26 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 $33,128.26 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: GREEN TREE SERVICING LLC PO Box 94710 Palatine, IL 60094 -4710 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 brings 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. 4 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 writing by 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 four (4) to six (6) 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: GREEN TREE SERVICING LLC Address: PO Box 94710 Palatine, IL 60094 -4710 Phone Number: 800- 643 -0202 Fax Number: 866 -210 -6192 Contact Person: Collection Department 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 Sheriffs 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 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. 5 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. 6 PHF I A Comprehensive Housing Counseling Agencies Agencias de Consejo al Cliente para Vivienda Westmoreland County *CCCS of Western PA One Northgate Square Greensburg PA 15601 888.511.2227 / 888.511.2227 www.adva ntageccs. org *Neighborworks Western PA 710 Fifth Ave Pittsburgh PA 15219 412.281.9773 www.nwwpa.org *Westmoreland Community Action 226 S Maple Ave Greensburg PA 15601 800.816.0022 / 724.834.1260 www.westm orelandca. oro Action - Housing, Inc 425 Sixth Ave; STE 950 Pittsburgh PA 15219 800.792.2801 / 412.281.2102 www.actionhousino.org Fayette Co. Community Action Agency, Inc. 140 N Beeson Ave Uniontown PA 15401 724.430.6557 www.fccaa.ora Indiana County Community Action Program, Inc. 827 Water St Indiana PA 15701 724.465.2657 www.iccap.net Mon Valley Initiative 305 E Eighth Ave Homestead PA 15120 412.464.4000 www.monvalleyinitiative.com NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you. Report last updated: 2/19/2013 10:06:27 AM Page 1 of 1 k r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANJ�. GREEN TREE SERVICING LLC��, c' t Plaintiff vs. Case No. 1q, Sg � C CHAD D. SEIBER MELISSA R. SEIBER Defendants) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfull submitte (Signature of Counsel for tiff) Dat Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWF_R REQUEST FOR HARDSHIP ASSISTANCE To complete -your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to The best of your knowledge: APPLICANT Borrower name(s): Property Address: City State Zip: Is the property for sale? Yes [I No Ej Listing date Price: $ Realtor Name: Realtor Phone: Borrower (occupied? Yes �� Mailing Address (if different ):. City State: — Zip: Phone Numbers: Rome: 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? 'TINANCIAL INFORMATION: First Mortgage Lender: Type of Loan: Loan Number: late 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 CJ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Rome $ Other Real Estate: $ Retirement Funds; $ Investments: $ $ Checking: $ $ Savings: $� $ Other: $� $ Automobile 41 r Model: Year Amount owed: Value: Auto mobile f#2 Model: Year: Amount owed: Value: Other transportation automobiles boats rn tore cles , Model: Year. Amount owed. Value Month!y Income Name of Employers: 1, 3. Additional Income Description (not wages): 1. _ monthly amount: 2. _ monthly amount: Borrower Pay bays: Co- Borrower Pay Days: Monthly Exgoses (Please only include expenses you are currently paying) EXPEN AM OUNT EXPENSE AMOUNT Mortgage Food T Mort a e Utilities Car lea efts Condo/Nei , Fees Auto Insurance Med. not covered Auto fuelfre airs Other prola. payment Install. Loan Payment Cable TV Child Su rt/Alim. Spmding Mone a Da y1Child CarelTuit, Other Exp enses _ Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes 1:1 No ❑ If yes, please provide the following information: Counseling; Agency: Coun..selor: Phone.(Offace): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program _ (HEMAP) assistance? yes [] No 0 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 Contract (Name): ;phone. Servicing Company (Name): Contact: Phone: authorize the above named to uselrefer 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 services provided by the above named Borrower Signature Date Co- Borrower Signature Date Tease forward this document along with the following information to lender and lender's counsel: Proof of income Past Z bank statements Proof of any expected income for the last 45 days: �t Copy of s current utility bill Letter explaining reason for delinquency and any supporting documentation . { (hardship letter) Y Listing agreement (if property is currently on the market) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLANPECOg yTYTY o H SNP 12 PH 2: 1 q , CUMB.'7 ,Lf,140 CC's H TY oS Ctttn(ert,< OFF $H,R1F.= Green Tree Servicing, LLC vs. Chad D. Seiber (et al.) Case Number 2014 -527 SHERIFF'S RETURN OF SERVICE 01/30/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Chad D. Seiber, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 01/30/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Melissa Seiber, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 01/31/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, 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 5225 Wertzville Road, Hampden, Enola, PA 17025. Residence is vacant. 02/07/2014 11:34 AM - The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of York County upon Shirley Shull, Grandmother of defendant, who accepted for Chad D. Seiber, at 830 Fishing Creek Road, Fairview Township, New Cumberland, PA 17070. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 02/26/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of York County, the within named Defendant Melissa Seiber, not found. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $74.95 SO ANSWERS, March 05, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheri Tei oscft, SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber Sheriff Reuben B Zeager Chief Deputy, Operations GREEN TREE SERVICING LLC VS. CHAD D. SEIBER (et al.) PETER J. MANGAN, E` Solici Richard E Rice Chief Deputy, Administrate Case Number 14 -527 CIVIL SHERIFF'S RETURN OF SERVICE 02/07/2014 11:34 AM - DEPUTY COREY STRINE, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE SHIRLEY SHULL, GRANDMOTHER, WHO ACCEPTED AS "ADULT PERSON IN CHARGE" FOR CHAD D. SEIBER AT 830 FISHING CREEK ROAD, NEW CUMBERLAND, PA 17070. 02/07/2014 02/26/2014 REY STRINE, DEPUTY 11:34 AM - DEPUTY COREY STRINE, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: MELISSA SEIBER AT 830 FISHING CREEK ROAD, NEW CUMBERLAND, PA 17070. THE DEFENDANT WAS FOUND TO HAVE MOVED. 1, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: MELISSA SEIBER, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM AS "NOT FOUND" AT 830 FISHING CREEK ROAD, NEW CUMBERLAND, PA 17070. PER POST OFFICE CHECK NOT KNOWN AT ADDRESS GIVEN. SHERIFF COST: $52.89 February 26, 2014 NOTARY Affirmed and subscribed to before me this 26TH day of FEBRUARY 2014 SO ' . RS, RICHARD P KEUERLEBER, SHERIFF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shelia E. Cook, Notary Public City of York, York County My Commission Expires Feb. 1, 2017 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 02/26/2014 I 830 FISHING CREEK ROAD, FAIRVIEW TOWNSHIP, NEW EXP: 02!26/2014 Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY of Clime 4,0* OFFICE OF THE SHERIFF Richard W Stewart Solicitor Green Tree Servicing, LLC vs. Chad D. Seiber Case Number 2014-527 SERVICE COVER SHEET Service Details: Cafegoty Manner: Notes: Civil Action - Notice of Residential Mortgage Foreclosure Diversion Progr Deputize Expires: Zone: Warrant: Serve To: Name: Primary Address: Phone: Alternate Address: Phone: Chad D. Seiber 830 Fishing Creek Road Fairview Township New Cumberland, PA 17070 DOB: (Attorney/ Originator: Name: ] [Final Service: Served: Adult In Charge: Relation: Date: Deputy: Personally - Adult In Charge • Posted • Other Time: Mileage: IKML Law Group, P.C. LService Attempts: Date: r- Time: .. Mileage: IN • Deputy: SEIBER, CHAD D. Phone: 215-627-1322 [Notes / Special Instructions: -n 17, Now, January 30, 2014 t, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of York County to execute service of the documents herewith and make return thereof according to law. Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 (c)CutritySiite Siwciff ,Teleoscf:. loc Ronny R Anderson, Sheriff EXP: 02/26/2014 830 FISHING CREEK ROAD, LEWISBERRY, PA 17070 Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY of Comb, iy? OFFICE OF THE SRERIFF Richard W Stewart Solicitor Green Tree Servicing, LLC vs. Chad D. Seiber (et al.) Case Number 2014-527 SERVICE COVER SHEET Service Details: Category: Manner: Notes: Civil Action - Notice of Residential Mortgage Foreclosure Diversion Progr 1 Expires: 02/26/2014 Deputize Zone: Warrant: [Serve To: Name: Melissa Seiber Primary Address: Phone: Alternate Address: Phone: 830 Fishing Creek Road Lewisberry, PA 17070 DOB: [Attorney / Originator: [Final Service: Served: Adult In Charge: Relation: Date: Deputy: Name: IKML Law Group, P.C. Phone: Personally Adult In Charge Posted Other rIZZI 1-1 Time: Mileage: 215-627-1322 (Service Attempts: Date: Time: Cs1 Mileage: sc.-4 Deputy: J Notes / Special Instructions: ...... ................ .................. ....... ...... ................... . ....... „ .... Now, January 30, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of York County to Al execute service of the documents herewith and make return thereof according to law. w Return To: co Cumberland County Sheriffs Office u) One Courthouse Square Carlisle, PA 17013 (c) COUrdyStrre Sheriff Teleescifi Inc ROnny R Anderson, Sheriff KML Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul, MN 55102 VS. CHAD D SEB3ER MELISSA R SEIBER 5225 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. Term No. 14-527 By: KML LA GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay E. Kivitz Pa. JD 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Ronny R Anderson Shetiff Jody S Smith Chief Depu Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY libcp / r',. |[tiEoRO-HGN5 201.1i APR CUMBE.RLAND PENNSYLVAMA Green Tree Servicing, LLC vs. Chad D. Seiber (et al.) p� Case Number 2014-527 SHERIFF'S RETURN OF SERVICE 04/03/2014 07:02 PM - Deputy Noah Cli being duly 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: Melissa Seiber at 63 Crooked Drive, East Pennsboro, Enola, PA 17025. NOAH CLINE, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, April 04, 2014 (C) COUtliyS11110 Sheriff, Tel6;osoft. �� RONm,RANDERSDN.GHER|FF ~ S In the Court of Common Pleas of Cumberland County GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul,MN 55102 No. 14-527 Plaintiff vs. CHAD D.SEIBER c) MELISSA R.SEIBER (Mortgagor(s)and Record Owner(s)) r . 5225 Wertzville Road Enola,PA 17025 Defendant(s) -- PRAECIPE FOR JUDGMENT Y a THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT.A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against CHAD D.SEIBER and MELISSA R. SEIBER by default for want of an Answer. Assess damages as follows: $146,923.80 Debt Interest from 6/21/2014 to Date of Sale per diem at$18.49 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record,if any,after the default occurre. .nd at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.237.1 By: AEtL KML LAW GROUP, t. Michael McKeever Pa. lir 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 _Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 .i t / _Jill P.Jenkins Pa.ID 306588 7)ill n6.01 I' LtL j 7(6[I(i _Andrew F.Gomall Pa.ID 92382 J Attorneys for Plaintiff YAC, 9� AND NOW '� ,Jud ent is e ed in favor of GREEN TREE SERVICING LLC and against CHAD D.SEIB R and MELISSA R. —IBER de au r want of a Answer and damages assessed in the sum of$146,923.80 as per the above certificati dProttStre44 d eL-s 7t,9v. . 36`7 4 37 . L - VIAS::1n Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul,MN 55102 Plaintiff No. 14-527 vs. CHAD D.SEIBER MELISSA R. SEIBER (Mortgagors and Record Owner(s)) 5225 Wertzville Road Enola,PA 17025 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. • NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle,PA 17013 Prothonotary . C7`..311"AlP By: " Deputy If you have any questions concerning the above,please contact: KML Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 1254 06FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT ' OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: June 5,2014 TO: CHAD D.SEIBER • SEIBER,CHAD D. 5225 Wertzville Road Enola,PA 17025 In the Court of GREEN TREE SERVICING LLC Common Pleas 345 St Peter Street of Cumberland County 1100 Landmark Towers St Paul,MN 55102 Plaintiff CIVIL ACTION-LAW vs. CHAD D SEIBER Action of MELISSA R SOBER Mortgage Foreclosure (Mortgagors and Record Owners) 5225 Wertzville Road No. 14-527 Enola,PA 17025 Defendants TO: CHAD D.SEIBER 5225 Wertzville Road Enola,PA 17025 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A ' JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 r 717-243-9400 h By: KML LA a ROUP,P.C. Micha• cKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 David Fein Pa.ID 82628 Jill P.Jenkins Pa.ID 306588 yk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff • 125406FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT r' OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE I• PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: June 5,2014 TO: MELISSA R.SEIBER SURER,MELISSA R 5225 Wertzville Road Enola,PA 17025 In the Court of GREEN TREE SERVICING LLC Common Pleas 345 St Peter Street of Cumberland County 1100 Landmark Towers St Paul,MN 55102 Plaintiff CIVIL ACTION-LAW vs. CHAD D SEIBER Action of MELISSA R SEIBER Mortgage Foreclosure (Mortgagors and Record Owners) 5225 Wertzville Road - No. 14-527 Enola,PA 17025 Defendants TO: MELISSA R SEIBER 5225 Wertzville Road Enola,PA 17025 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OI'kbR LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-94001110 ' 1 By: KML LA'' OUP,P.C. Mich cKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 David Fein Pa.ID 82628 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 alvatore Filippello Pa.ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff • • • 125406FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: June 5,2014 TO: • CHAD D SEIBER SEIBER,CHAD D. 830 Fishing Creek Road New Cumberland,PA 17070 In the Court of GREEN TREE SERVICING LLC Common Pleas 345 St Peter Street of Cumberland County 1100 Landmark Towers St Paul,MN 55102 Plaintiff CIVIL ACTION-LAW vs. CHAD D SEIBER Action of MELISSA R SEWER Mortgage Foreclosure (Mortgagors and Record Owners) 5225 Wertzville Road No. 14-527 Enola,PA 17025 Defendants TO: CHAD D SURER 830 Fishing Creek Road New Cumberland,PA 17070 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: KML LAW GRO' P.C. Michael Mc er Pa.ID 56129 Lisa Lee Pa.ID 78020 David Fein Pa.ID 82628 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Jennifer Lynn Freebie Pa ID 316160 215-627-1322 Attorneys for Plaintiff 125406FC - THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: June 5,2014 TO: MELISSA R SEIBER SEIBER,MELISSA R. 63 Crooked Drive Enola,PA 17025 In the Court of GREEN TREE SERVICING LLC Common Pleas 345 St Peter Street of Cumberland County 1100 Landmark Towers St Paul,MN 55102 Plaintiff CIVIL ACTION-LAW vs. CHAD D SEIBER Action of MELISSA R SEIBER Mortgage Foreclosure (Mortgagors and Record Owners) 5225 Wertzville Road No. 14-527 Enola,PA 17025 Defendants TO: MELISSA R SEIBER 63 Crooked Drive Enola,PA 17025 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI LIEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 - 717-243-9400 1 ` + By: BlI .r KMLLAW RSI :IV'.C. Michael 1 bi eever Pa.ID 56129 Lisa Lee Pa.ID 78020 David Fein Pa.ID 82628 Jill P.Jenkins Pa.ID 306588 iAlyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA GREEN TREE SERVICING LLC Plaintiff vs. CHAD D.SEIBER NO.14-527 MELISSA R.SEIBER Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group,P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): CHAD D. SEIBER, has a last known residence of 830 Fishing Creek Road,New Cumberland,PA 17070. The following information was used to search the DMDC(check all ' that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date k ),o ((kiBy: KML LAW C4R0 ,P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa.ID 26769 Andrew Gornall Pa. ID 92382 Joshua I.Goldman Pa.ID 205047 Salvatore Filippello Pa. ID 313 897 Jill P.Jenkins Pa. ID 306588 yk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff 1 Department of Defense Manpower Data Center Results as of:Jun-20-2014 09:24:13 AM SCRA 3.0 4ti is .ey' y&'_xl, . ':, stets t$tu Report qo:rt :1' ' Pursuant to Servicernembers Civil Relief Act Last Name: SEIBER First Name: CHAD Middle Name: D. Active Duty Status As Of: Jun-20-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Da s 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 Cell-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. _ • 1 s Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 1- • 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(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: TAQ4X7FCLOC4330 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA GREEN TREE SERVICING LLC Plaintiff vs. CHAD D.SEIBER NO. 14-527 MELISSA R. SEIBER Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the aboye entitled matter,does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): MELISSA R. SEIBER, has a last known residence of 63 Crooked Drive, Enola,PA 17025. The following information was used to search the DMDC(check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the infamiation provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date I ki By: KML LAW G OUP,P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 _..."4/631.k L. Oflazian Pa. ID 312912 nnifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff • Department of Defense Manpower Data Center Results as of:Jun-20.201409:21:52 AM SCRA 3.0 `tel rye. c + S 1"\ SWIM Rqx r_ fr;' Pursuant to Service-members Civil Relief Act Last Name: SEIBER First Name: MELISSA Middle Name: R. Active Duty Status As Of: Jun-20-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component • NA NA No • NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Da s 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. YA 1104 WON,. 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: EAM1G72CX0C4KDO KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff GREEN TREE SERVICING LLC 345 St Peter Street IN THE COURT OF COMMON PLEAS 1100 Landmark Towers St Paul,MN 55102 of Cumberland County Plaintiff vs. CIVIL ACTION LAW CHAD D. SEIBER MELISSA R.SEIBER (Mortgagor(s)and Record owner(s)) ACTION OF MORTGAGE FORECLOSURE 5225 Wertzville Road Enola,PA 17025 Defendant(s) No. 14-527 ORDER FOR JUDGMENT Please enter Judgment in favor of GREEN TREE SERVICING LLC,and against CHAD D. SEIBER and MELISSA R. SEIBER for failure to file an Answer in the above action within(20)days from the date of service of the Complaint,in the sum of$146,923.80. At: By: KML LAW GRO P, :C. Michael McKeeve Pa.ID 56129 Jay E. Kivitz Pa. 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff T�ti'111i1) i' 1AL3' d o I hereby certify that the above names are correct and that the pLecise sidence address ot the judgment creditor is GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul,MN 55102 and that the name(s)and last known address(es)of the Defendant(s)is/are CHAD D. SEIBER, 830 Fishing Creek Road New Cumberland,PA 17070 and MELISSA R. SEIBER,63 Crooked Drive Enola,PA 17025; By: KML LAW GROU,'PJ P.C. Michael McKeever Va.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa. 205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff fiiikurpfVFa/1/(2i/ 3 [(40 4. ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $114,820.74 Interest from 04/01/2011 through $21,697.84 06/20/2014 Reasonable Attorney's Fee $1,650.00 Late Charges $116.32 Escrow $8,503.27 Unapplied Funds ($850.17) Corporate Advance $985.80 $146,923.80 By: fiv,:: KML LAW GRO p.C. Michael McKeev- 'a. D 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 -m mil' for laingf i I ' K f AND NOW,this of day of I n ,2014 damages are assessed as above. 3.,....... 3„...0 Pro Prothy 14-527/125406FC * PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers IN THE COURT OF COMMON PLEAS St Paul,MN 55102 Plaintiff of Cumberland County vs. CIVIL ACTION—LAW CHAD D. SEIBER MELISSA R. SEIBER ACTION OF MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) 5225 Wertzville Road Enola,PA 17025 No. 14-527 -_ Defendant(s) Z r -T, r.a c. C) CD PRAECIPE FOR WRIT OF EXECUTION r ak.1 TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $146,923.80 Interest from 6/21/2014 to Date of Sale per diem at $18.49 (Costs to be added) a pd_CAPV �+ C �[�)1.q/� J By: �. ko3.1S tt " KML LAW G OU ,P.C. S tt I t Michael Mc ver Pa.ID 56129 1 t, Jay E. Kivitz Pa.ID 26769 1 S Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 S David Fein Pa.ID 82628 3 I�aF Thomas Puleo Pa.ID 27615 L/fl, q Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 r gip yd t kAy sa.as�e w Andrew F.Gornall Pa.ID 92382 ‘ Attorneys for Plaintiff a " j704 n t 316162 l3 g � O )`7 a)y d Tax ID Number: 10-14-0840-005 ALL THAT CERTAIN lot of ground situate in Hampden Township,Cumberland County, Pennsylvania,bounded and described as follows: Beginning at a Point in the center of the Enola-Wertzville Road,which point is a corner of Lot No.4 on the hereinafter mentioned plan of lots;thence along the line of Lot No.4, South 01 degrees 30 minutes West 404.6 feet to a point in line of land of E. R. Long;thence along land of said E.R. Long,North 84 degrees West 100.40 feet to a point in line of Lot No. 2,on the hereinafter mentioned plan of lots; thence along line of Lot No. 2, North 01 degrees 30 minutes East 385.3 feet to a point in the center of the aforesaid Enola-Wertzville Road;thence in an Eastwardly direction along the center of said Enola-Wertzville Road,North 85 degrees 11 minutes East 100.00 feet to a point,the place of beginning. Being all of Lot No. 3 on that certain Plan of Lots laid out adopted by Harriet S. Raudabaugh on the 3rd day of March, 1955, said plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, Plan Book 7, Page 26. Commonly known as: 5225 Wertzville Rd, Enola,PA 17025 TAX PARCEL#10-14-0840-005 1 ' o% q \ = ▪ \ cn L) / \ '10 P4 kt \ « 0404 \ x / / ® = / cl 0 & V4 k � �_ &/ k - \ P4o ® , ® ; a� < Cl r % p > / \ \ / % � a � � E % t � - \ Q % Q & k \ 4 1. EN L « 3 � a\. w m ; m t o © e 3 * ■ m 9 \ / I ? �\ k / - \ { \ / / \ 0 \ \ / \/ � � \ � % \ � / Q m » \ � / / 0 0 / / / 2 lL Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 ;1,1' r„•, Attorney for Plaintiff " ` ' ro GREEN TREE SERVICING LLC PNNS 345 St Peter Street IN fIE utiURT OF COMMON PLEAS 1100 Landmark Towers St Paul,MN 55102 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW CHAD D. SEIBER MELISSA R. SEIBER (Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE 5225 Wertzville Road Enola,PA 17025 Defendant(s) No. 14-527 AFFIDAVIT PURSUANT TO RULE 3129 GREEN TREE SERVICING LLC,Plaintiff in the above action,by counsel,KML Law Group,P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 5225 Wertzville Road Enola,PA 17025 1.Name and address of Owner(s)or Reputed Owner(s): CHAD D. SEIBER 830 Fishing Creek Road New Cumberland,PA 17070 MELISSA R. SEIBER 63 Crooked Drive Enola,PA 17025 2.Name and address of Defendant(s)in the judgment: CHAD D.SEIBER 830 Fishing Creek Road New Cumberland,PA 17070 MELISSA R. SEIBER 63 Crooked Drive Enola,PA 17025 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: Hampden Township 230 S. Sporting Hill Road, Mechanicsburg, ,Pa. 17055 4.-rt HSBC Bank Nevada,N.A. 1111 Town Center Drive, Las Vegas,,Nv. 89193 LVNV Funding,LLC 120 N. Keyser Avenue, Scranton,,Pa. 18504 Hampden Township Brenneman Keith O. Snelbaker&Brenneman 44 W.Main Street,PO Box 318 Mechanisburg,PA 17055 LVNV Funding,LLC Ratchford Michael F-Edwin A.Abrahamsen Assoc. 120 N. Keyser Ave Scranton,PA 18504-9701 HSBC Bank Nevada,N.A. Warmbrodt James C;Weltman Weinberg&Reis Co LPA 436 Seventh Ave Suite 1400 Pittsburgh,PA 15219 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 4.Name and address of the last recorded holder of every mortgage of record: Mortgage Electronic Registration Systems as nominee for Countrywide Home Loans,Inc. P.O.Box 2026, Flint„ Mi. 48501-2026 Mortgage Electronic Registration Systems as nominee for Countrywide Home Loans,Inc. 4500 Park Granada, Calabasas„Ca.91302-1613 The Bank of New York Mellon f/k/a The Bank of New York,as successor Trusteeto JP Morgan Chase Bank,N.A.,as Trustee on behalf of the Certificateholders of the CWHEQ Inc.,CWHEQ Revolving Home Equity Loan Trust,Series 2005-1 c/o BAC,M/C:CA6-914-01-43, 1800 Tapo Canyon Road, Simi Valley, ,Ca. 93063 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 1°. 'Tame and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 5225 Wertzville Road Enola,PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATED: / 01 49 I 1 Lt' ,AL) By: KML L• GROUP,P.C. Michae cKeever Pa.ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa. ID 27615 Joshua 1. Goldman Pa. 205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 torneys for Plaintiff AI /1/1 0 0ff(ethi 3 fG(b0 14-527 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 i 14-527 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 125406FC. • Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 14-527 KML Law Group, P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 '`VI 24 (215)627-1322 C/r `�t' IQ: 4 - Attorney for Plaintiff p- .A1 NO GREEN TREE SERVICING LLC 345 St Peter Street IN THE COURT OF COMMON PLEAS 1100 Landmark Towers St Paul,MN 55102 of Cumberland County Plaintiff CIVIL ACTION-LAW vs. CHAD D. SEIBER ACTION OF MORTGAGE MELISSA R. SEIBER FORECLOSURE Mortgagor(s)and Record Owner(s) 5225 Wertzville Road Enola,PA 17025 Docket No. 14-527 Defendants THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SEIBER,MELISSA R. MELISSA R. SEIBER 63 Crooked Drive Enola,PA 17025 Your house at 5225 Wertzville Road,Enola,PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday,December 03,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$146,923.80 obtained by GREEN TREE SERVICING LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to GREEN TREE SERVICING LLC,the back payments, late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. KML Law Group,P.C. r � Suite 5000—BNY Independence Center 204 j u,/Q T . �,,1 it, 701 Market Street Philadelphia,PA 19106CL/I'33'r. Rh/0: 215-627-1322 pF ,pC 0d " Attorney for Plaintiff i(V,4'4111� GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers IN THE COURT OF St Paul,MN 55102 COMMON PLEAS Plaintiff vs. of Cumberland County CHAD D. SEIBER CIVIL ACTION-LAW MELISSA R. SEIBER Mortgagor(s)and Record Owner(s) ACTION OF 5225 Wertzville Road MORTGAGE FORECLOSURE Enola,PA 17025 Defendant(s) NO. 14-527 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff,by counsel,hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. O ) 4t, By: KML LAW GRC� P,14.C. Michael McKeev Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa. ID 92382 Attorneys for Plaintiff JPcata3 /6/G 0 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 5225 Wertzville Road Enola, PA 17025 SOLD as the property of CHAD D. SEIBER and MELISSA R. SEIBER TAX PARCEL#10-14-0840-005 ,..----ls-- \\e THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA :ij ,.1 ll ,-,—. !ji DAVID D. BUELL,PROTHONOTARY \ y ) One Courthouse Square • Suite]00 • Carlisle, PA • 17013 \ --•\10..o, '.•, (717)240-6195 www.ccpa.net GREEN TREE SERVICING LLC Vs. NO 14-527 Civil Term CIVIL ACTION—LAW CHAD D. SEIBER MELISSA R. SEIBER 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: $146,923.80 L.L.: $.50 Interest FROM 6/21/2014 TO DATE OF SALE PER DIEM AT$18.49 Atty's Comm: Due Prothy: $2.25 Atty Paid: $280.45V Other Costs: ' Plaintiff Paid: Date: 6/24/14 . to,t,sitel_i) . Ii/le.. David D. B ell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name: JENNIFER FRECHIE,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 316160 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FILED -OFF OF THE PROTHONOTARY 2011iOCT 10 PM 2: 29 CUPENNSYLVANIA TY GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul, MN 55102 vs. CHAD D. SEIBER and MELISSA R. SEIBER 5225 Wertzville Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 14-527 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY 1aNFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a mortgage upon the premises 5225 Wertzville Road, Enola, PA, 17025, hereinafter, the "mortgaged premises". 2. Defendant, CHAD D. SEIBER and MELISSA R. SEIBER, are the mortgagors and real owners of the mortgaged premises. 3. Pursuant to Cumberland County Local. Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, Alyk Oflazian, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. 4. The last known addresses of Defendant, Chad D. Seiber, are 830 Fishing Creek Road, New Cumberland, PA 17070 and 328 South Enola Drive, 2nd Floor, Enola, PA 17025 from our investigative search. 5. The Sheriff has been unable to effect service of the Notice of Sale upon Defendant, Chad D. Seiber. Service was attempted on Defendant, Chad D. Seiber at the mortgaged premises 5225 Wertzville Road, Enola, PA 17025. The property is vacant. Service was attempted on Defendant, Chad D. Seiber at 830 Fishing Creek Road, New Cumberland, PA 17070. The return of service indicates Defendant, Chad D. Seiber responded to notice left and advised the Process Server that he is aware of the sale date and that he would not arrange to be served. No further information was provided. Service was attempted on Defendant, Chad D. Seiber at 328 South Enola Drive, 2"d Floor, Enola, PA 17025. The return of service indicates per the current tenant, Chris Ensminger, Defendant, Chad D. Seiber does not reside at said address. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Chad D. Seiber. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Notice of Sale upon Defendant, Chad D. Seiber, by posting the premises and certified and regular mail to the Defendant's last known addresses. By: KML LAW ROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 �Alyk Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff Affidavit of Good Faith Investigation At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 125406FC Attorney/Law Firm: KML LAW GROUP, P.C. Subject Name: CHAD D. SEIBER Property Address: Street: 5225 Wertzville Road City: Enola State: PA Zip: 17025 Skip Results: Date of Birth: Last Known Address (as of 8/20/2014) Street: 830 Fishing Creek Rd City: New Cumberland State: PA ProVest File Number: 4071874 Zip: 17070 2705 Death Record Search As of 08/20/2014, the Social Security Administration has no death record on file for Chad D Seiber. Social Security Number [X] Verifed [ ] Not Verified SSN# XXX -XX - 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: Addressl-: 830 FISHING CREEK RD, NEW CUMBERLAND, PA 17070 2705 Address2: 328 S ENOLA DR FL 2ND, ENOLA, PA 17025 2809 Department of Motor Vehicle Records Search* Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Drivers License Information Search [ ] Govemmental**+ [XI Non-govemmental No verifiable information. Professional Licenses Search No records found. 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: PO BOX 70 1 MECHANICSBURG 1 PA 1 17055 0070 ' CUMBERLAND 5225 WERTZVILLE ROAD 1 ENOLA 1 PA 1 17025 1 CUMBERLAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Inquiry of Relatives, Neighbors, & Friends 717-525-9897: Called possible relative, Melissa Seiber, answering machine answered, no message left. Comments: 717-728-3794: Called number listed to defendant, Chad Seiber, number has been disconnected. 717-732-0880: Called number listed to defendant, Chad Seiber, number has been disconnected. 717-610-4180: Called number listed to defendant, Chad Seiber, generic answering machine answered, no message left. A search of Federal Bureau of Prisons resulted in no records for our defendant. A search of Pennsylvania Department of Corrections resulted in no records for our defendant. Our defendant was not found to be currently incarcerated searching Pennsylvania County Jails. A search of Philadelphia Prison Systems resulted in no records for our defendant. Data not available in AL, AR, CA, HI, NH, OR, PA, VA, WA. " Historical data in CO, DE, ID, IL, KY, LA, MD, MA, MS, MO, NH, ND, SC, WV. + Data available in CO, CT, DE, FL, ID, IL, KY, LA, ME, MD, MA, MI, MN, MS, MO, NH, ND, OH, SC, TN, TX, WV, WI, WY. The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Under penalties of perjury, I declare that I have read the foregoing affidavit and that the facts stated in it are true. STATE OF FLORIDAE Via- 1L V LC AUG ( 014 COUNTY OF HILLSBOROUGH Gianna Hemandez ProVest File Number: 40774 Swom to or affirmed and signed before me on this _ day of Provest Services LLC Date:Ga) 2_0 • (Seal) JOSHUA N. PIMENTEL Notary Public, State of Florida My Comm. Expires May 24, 2015 No. EE 97050 Printed Name of Notary Public (Personally Known ( ) Produced as identification IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA GREEN TREE SERVICING LLC; et seq. Plaintiff (Petitioner) V, CHAD D. SEIBER; et al. Defendant (Respondent) CASE and/or DOCKET No.: 14-527 Sheriff's Sale Date: 12/3/2014 AFFIDAVIT OF NON -SERVICE ❑ Complaint ❑ Summons 0 Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I attempted to serve CHAD D. SEIBER the above process on the 24 day of September, 2014, at 1:38 o'clock, PM, at 5225 Wertzville Road Enola, PA 17025 County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: LJ Moved ❑ Unknown ❑ No Answer 0 Vacant 0 Other: PROPERTY IS VACANT, EMPTY INSIDE, PROPERTY IS OVERGROWN, ELECTRIC OFF. Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of 1.4 ) ) SS: County of elf. C r ) Before me, the undersigned notary public, this day, personally, appeared geCr. e c �.tr to me known, who being duly sworn according to law, deposes the following: I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Non -Service are true and correct (Signature of Affiant) File Number:125406FC Subscribed and sworn to before me this 2r day of Case ID #:4103070 Notary Public COMMONWEALTH OF PENNSVLVANtA NOTARIAL SEAL Eric M. Afflerbach, Notary Public Washin0•ton Township, Berks County My Commission Expires November 18, 2017 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA GREEN TREE SERVICING LLC; et seq. Plaintiff (Petitioner) V. CHAD D. SEIBER; et al. Defendant (Respondent) CASE and/or DOCKET No.: 14-527 Sheriffs Sale Date: 12/3/2014 AFFIDAVIT OF NON -SERVICE ❑ Complaint ❑Summons El Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I attempted to serve CHAD D. SEIBER the above process on the 8 day of July, 2014, at 9:20 o'clock, PM, at 830 FISHING CREEK ROAD NEW CUMBERLAND, PA 17070 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: ❑ Moved ❑ Unknown ❑ No Answer 0 Vacant El Other: DEFENDANT CHAD SEIBER RESPONDED TO CARD LEFT ON PROPERTY DOOR TO ARRANGE FOR SERVICE, HE INFORMED SERVER THAT HE IS AWARE OF THE SALE DATE AND STATED HE WOULD NOT ARRANGE FOR SERVICE. Service was attempted on the following dates/times: 1) 6/28/14 9:30 AM 2) 7/2/14 2:31 PM 3) 7/8/14 9:20 PM Commonwealth/State of 44 ) SS: County of ace:/ ) Before me, the undersigned notary public, this day, personally, appeared pcv'. G #'tc to me known, who being duly sworn according to law, deposes the following: I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Non -Service are true and correct. (Signature of Affiant) File Number:125406FC Case ID #:4022096 Subscribed and sworn to befo this 9 day of 20 /j COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflerbach, Notary Public Washington Township, Berks County My Commission Expires November 18, 201 7 Notary Public IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA GREEN TREE SERVICING LLC; et seq. Plaintiff (Petitioner) V. CHAD D. SEIBER; et al. Defendant (Respondent) CASE and/or DOCKET No.: 14-527 Sheriffs Sale Date: 12/3/2014 AFFIDAVIT OF NON -SERVICE ❑ Complaint 0 Summons Li Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I attempted to serve CHAD D. SEIBER the above process on the 3 day of September, 2014, at 1:16 o'clock, PM, at 328 S. ENOLA DR. FL 2ND ENOLA, PA 17025 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: 0 Moved 0 Unknown ❑ No Answer 0 Vacant 0 Other: PER TENANT, CHRIS ENSMINGER, W/M/20/57/150BLK, DEFENDANT DOES NOT RESIDE AT ADDRESS. Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of 9 ) ) SS: County of 13.,4.1 ) Before me, the undersigned notary public, this day, personally, appeared duly sworn according to law, deposes the following: (Carr. 1 1 C. I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Non -Service are true and correct. (Signature of Affiant) to me known, who being Subscribed and sworn to before me this''I day of 1— , 2. 1 Y . File Number:125406FC Case ID 4:4079838 Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflerbach, Notary Public Washington Township, Berks County My Commission Expires November 18, 201 7 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul, MN 55102" vs. CHAD D. SEIBER and MELISSA R. SEIBER 5225 Wertzville Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 14-527 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Notice of Sheriff's Sale against Defendant, Chad D. Seiber, which the Sheriff has been unable to personally serve upon Defendant, Chad D. Seiber. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Notice of Sheriffs Sale upon Defendant, Chad D. Seiber, by posting the premises and certified mail and regular mail to the Defendant's last known addresses. By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 'Alyk Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul, MN 55102 vs. CHAD D. SEIBER MELISSA R. SEIBER 5225 Wertzville Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS of Cumberland County No. 14-527 CERTIFICATE OF SERVICE Marlene Powers, an employee of KML Law Group, P.C., counsel for plaintiff, does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendants, Chad D. Seiber and Melissa R. Seiber this 9 day of October 2014, by first class mail, postage prepaid. CHAD D. SEIBER 5225 Wertzville Road Enola, PA 17025 MELISSA R. SEIBER 63 Crooked Drive Enola, PA 17025 CHAD D. SEIBER 328 S. Enola Dr. Fl 2nd Enola, PA 17025 MELISSA R. SEIBER 5225 Wertzville Road Enola, PA 17025 CHAD D. SEIBER 830 Fishing Creek Road New Cumberland, PA 17070 By: KML Law Group, P.C. Marlene Powers, Legal Secretary Direct Phone: 215-825-6340 GREEN TREE SERVICING LLC IN THE COURT OF COMMON PLEAS., C-) 345 St Peter Street 1100 Landmark Towers OF Cumberland CO co St Paul,MN 55102 Mr-n C:3 F-TI vs. C:) 14-527r"` --n- CHAD D. SE11BER and MELISSA R. SE113ER c:-_ 5225 Wertzville Road Enola,PA 17025 ORDER AND NOW,this day of OX. 2014,upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a)and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, Chad D. Seiber,have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriffs Sale upon Defendant, Chad D. Seiber,by posting a copy of the Notice upon the premises 5225 Wertzville Road,Enola,PA, 17025,and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known addresses at 830 Fishing Creek Road,New Cumberland, PA 17070 and 328 South Enola Drive, 2nd Floor, Enola,PA 17025,and that all further service of legal papers, including but not limited to motions,petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant,Chad D. Seiber, by sending copies of same to Defendant's last known addresses by certified and regular mail and by posting the premises. Service is complete upon mailing. B YT 4; URT:? J. Distribution list: --Michael T. McKeever, Esquire, Suite 5000—BNY Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 CHAD D. SEIBER, 5225 Wertzville Road Enola, PA 17025 KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Centel, __ 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff 7 10: i] - iJ"1T 125406FC CF: 01/27/2014 SD: 12/03/2014 $1.46,923.80 GREEN TREE SERVICING LLC 345 St Peter Street 1 100 Landmark Towers St Paul, MN 55102 vs. CHAD D. SE1BER MELISSA R. SEIBER Mortgagor(s) and Record Owner(s) 5225 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 14-527 Andrew Hauck, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (X) Personal Service by the Sheriffs Office/competent adult (copy of return attached). ( ) Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached). (X) Certified mail by Sheriffs Office. ( ) Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. (X) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). (X) Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, 414,4*47 BY: Andrew Hauck Legal Assistant IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA GREEN TREE SERVICING LLC; et seq. Plaintiff (Petitioner) V. CHAD D. SEIBER; et al. Defendant (Respondent) CASE and/or DOCKET No.: 14-527 Sheriffs Sale Date: 12/3/2014 AFFIDAVIT OF SERVICE ❑ Complaint ❑Summons E1 Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served MELISSA R. SEIBER the above process on the 2 day of July, 2014, at 2:54 o'clock, PM, at 63 Crooked Dr Enola, PA 17025 1522 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: 0 By handing a copy to the Defendant(s) Description: Approximate Age 36-40 Height 5;7 Weight 160 Racc WHITE Scx FEMALE Hair BROWN Military Status: DNo El Yes Branch: Commonwealth/State of f 4 ) SS: County of et r ) Before me, the undersigned notary public, this day, personally, appeared duly sworn according to law, deposes the following: /L t v c. C h r t t to me known, who being 1 hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. (Signature of Affiant) File Number:125406FC Case ID 4:4022096 Not -r/Public Subscribed and sworn this 1_ day of I , 20 if COMMONWEALTH OF PE NOTARIAL SEAL Eric M. Afflerbach, Notary Public Washington Township, Berks County MV Commission 6xpires November 18, 2017 YLVANtA UNITED STATES POSTAL SERVICE. Date: July 15, 2014 kalilah osei: The following is in response to your July 15, 2014 request for delivery information on your Certified Mail TM item number 9171999991703430273562. The delivery record shows that this item was delivered on June 28, 2014 at 11:55 am in NEW CUMBERLAND, PA 17070. The scanned image of the recipient information is provided below. Signature of Recipient : Address of Recipient : • ve *"',"" "*" Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service '11 UNITED STATES POSTAL SERVICE. Date: July 15, 2014 kalilah osei: The following is in response to your July 15, 2014 request for delivery information on your Certified Mail Tm item number 9171999991703430273562. The delivery record shows that this item was delivered on June 28, 2014 at 11:55 am in NEW CUMBERLAND, PA 17070. The scanned image of the recipient information is provided below. Signature of Recipient : Address of Recipient : SOCUOIre 17A4 5;71.61, 11.1•011•=1••••••MMIMINOMMINOI Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul, MN 55102 vs. CHAD D. SEIBER and MELISSA R. SEIBER 5225 Wertzville Road Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 14-527 r -Q3. r*lco O rn r z� —+ r _. ORDER - --< u7 <0 „. r C) AND NOW, this el day of ©cit � 2014, upon consideration of the > Ttiff'- Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs Wood --� faith efforts to ascertain the present whereabouts of Defendant, Chad D. Seiber, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriffs Sale upon Defendant, Chad D. Seiber, by posting a copy of the Notice upon the premises 5225 Wertzville Road, Enola, PA, 17025, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known addresses at 830 Fishing Creek Road, New Cumberland, PA 17070 and 328 South Enola Drive, 2nd Floor, Enola, PA 17025, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Chad D. Seiber, by sending copies of same to Defendant's last known addresses by certified and regular mail and by posting the premises. Service is complete upon mailing. 3. Distribution list: Michael T. McKeever, Esquire, Suite 5000 — BNY Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 CHAD D. SEIBER, 5225 Wertzville Road Enola, PA 17025 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA GREEN TREE SERVICING LLC; et seq. Plaintiff (Petitioner) V. CHAD D. SEIBER; et al. Defendant (Respondent) CASE and/or DOCKET No.: 14-527 Sheriff's Sale Date: 12/3/2014 AFFIDAVIT OF SERVICE El Complaint ❑ Summons Other: NOTICE OF SALE I, KEVEN CHASE, certify that 1 am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served CHAD D. SEIBER the above process on the 30 day of October, 2014, at 11:45 o'clock, AM, at 5225 Wentzville Road Enola, PA 17025 , County of Cumberland,. Commonwealth of Pennsylvania: Manner of Service: j By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of e4 County of 3avis1 ) SS: Before me, the undersigned notary public, this day, personally, appeared SG4.e' a P G Lela duly sworn according to law, deposes the following: 1 hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. fl' to me known, who being Subscribed and sworn to before me (Signature of Affiant) ' this 3 l day,of File Number:125406FC Case ID #:4130449 Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflerbach, Notary Public Washington Township, Barks County My Commission Expires November 18. 201 7 Name and Address of Sender aOLDBECK(If iUITE 5000 '01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service: ❑ Certified ❑ Recorded Delivery (International) ❑ COD ❑ Registered 0 Delivery Confirmation 0 Return Receipt for Merchandise 0 Express Mail 0 Signature Confirmation 0 Insured Affix Stamp Here issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Recei.t Article Number Addressee (Name, Street, City, State, & ZIP Code) Postage Handling Fee Char.e Actual Value if Re.istered Insured Value Due Sender if OD DC Fee SC Fee SH Fee RD Fee RR F:e 1 • Mortgage Electronic Registration Systems as nominee for Countrywide Home Loans, Inc. P.O. Box 2026, Flint„ Mi. 48501-2026x •.i ' Y r U.S. ``f` ,_ POSTAGE ��;��.� )» PITNEY BOWES �ir�� Mortgage Electronic Registration Systems as nominee foe Countrywide Home Loans, Inc. 4500 Park Granada,` 0 i....i ZIP 19106 001.8$ *',1•Po•- 0001391829 JUN. 26 2014 3. The Bank of New York Mellon f/k/a The Bank of New York, as successor Trusteeto JP Morgan Chase Bank, N.A., as Trustee on behalf of the Revolving Horne Equity Loan Trust, Series 2005-1 c/o BAC, M/C: CA6-914-01-43, 1800 Tapo Canyon Road, Imi Ta ey, , a. • 1.3 TENANTS/OCCUPANTS 1. -1 - :.. . Enola, PA 17025 IIIIIIIIIIIIIIIIIIIIIIIIIII MIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII Postmaster, P- of receiving employee) 1111111111111111 IIIIIIIIIIIIIII 1111111111111 See c Privacy Act fl11111/111y Statement on Reverse 4 5 6. 7. 8. Total Number of Pie Listed by Sender Total Number of Pieces Received at Post Office PS Form 3877, February 2002 (Page 1 of 2) Complete by Typewriter, Ink, or Ball Point Pen 125406FC Cumberland County Sale Date: 12/03/2014 CHAD D. SEIBER & MELISSA R. SEIBER 5//''S Name and Address of Sender CML LAW GROUP, P.C. IUITE 5000 '01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service; ❑ Certified ❑ Recorded Delivery (International) ❑ COD ❑ Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail E Signature Confirmation ❑ Insured Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt Article Number Addressee (Name, Street, City, State, 8 ZIP Cade) Postage Fee Handlinc ChargeU.S. 1 ' .7 - `_ SEIR, CHAD 830 Fishing Creek D. Road New Cumberland, PA 17070 POSTAGE>> PITNEY BOWES '� � ��' - ZIP 19106 c . '� '� 02 1 YV $ 002.60° 2 f" a' r SEIBER, CHAD D. 328 S. Enola Dr. Ft 2nd Enola, PA 17025 - .00013918290CT.24,2014 3..,' 4. 5. 6. 7. 8. • Total Number of Pieces Listed by Sender Total Nu ber of Pieces Receiv at st Office Postmaster, Per (Name receiving employee) �% See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) 125406FC Cumberland County CHAD D. SEIBER & MELISSA R. SEIBER Complete by Typewriter, Ink, or Ball Point Pen 03/2014 Print. Your Documents W)S USPS Manifest Mailing System Page 1 of 5 Page 1 Mailer's Name & Address KML Law Group 701 Market Street Permit Number 123 MAC Ver. Number ConnectShip Progistics 6,5 Suite 5000 Sequence Number Class of Mail Philadelphia, PA 19106 2648-2 Mixed Article 11/ Piece ID Addressee Name Delivery Address ES ES Type Postage Fee Insurance Amount Duo/ Sender Total Charge 9171999991703481679016 9171999991703481679023 9171999991703481679030 9171999991703481679047 9171999991703481679054 9171999991703481679061 9171999991703481679078 9171999991703481679085 9171999991703481679092 9171999991703481679115 9171999991703481679122 9171999991703481679139 WATSON. ROBIN 233 North Simpson Street Philadelphia. PA 19139 0.480 ERR 1.35 C 3.30 WATSON. ROBIN 0.480 56 W 51h Sl. ERR 1.35 Pottstown, PA 10464 C 3.30 JORDAN. ROSEMARY 0.480 7400 Roosevelt Boulevard, 0303 ERR 1.35 Philadelphia, PA 19152 C 3.30 HARMON. JOSEPH 0.480 5552 Angora Terrace ERR 1,35 Phlladelphla, PA 19143 C 3.30 HARMON. MARLENE 0.480 5552 Angora Terraco ERR 1.35 Philadelphia. PA 19143 C 3.30 BRUMSKILL, THERESA 0.480 5128 North Carlisle Slim! ERR 1.35 Philadelphia. PA 19141 C 3.30 Paul Overwlse 0.480 4607 Princeton Avenue ERR 1.35 Philadelphia. PA 19135 C 3.30 FARRELL ahJA PATRICIA A. FARRELL. PATRICIA 0.480 142 Wallenpaupack 1/Nee/lira 129 Pickerel Lane ERR 1.35 Greentowrt, PA 18426 C . 3.30 FARRELL aA/a PATRICIA A. FARRELL. PATRICIA 0.480 14 Updyke Road ERR 1.35 Hunlock Creek PA 18621 C 3.30 CHAKEF. ELIAS 0.480 1829 West Stanley Strout, ERR 1.35 Allentown, PA 18104 C 3.30 CHAKEF, ELIAS 0.480 871 N Joromo Street ERR 1.35 Allentown, PA 18109 C 3.30 SEIBER. CHAD D. 0.480 630 Fishing Creek Road ERR 1.35 New Cumherland, PA 17070 C 3.30 5.13 5.13 5.13 5.13 5.13 5.13 5.13 5.13 5.13 Page Totais 12 5.76 55.80 61.56 Cumulative Totals 12 5.76 55.80 61,56 http://pbpc/sendsuite%20live/projects/image.aspx?pd=1 10/24/2014 Print Your Documents USPS Manifest Mailing System Page 2 of 5 Page 2 Mailer's Name & Address KML Law Group 701 Market Street Suite 5000 Philadelphia. PA 19106 Permit Number 123 MAC Ver. Number ConnectShip Progistics 6.5 Sequence Number 2648-2 Class of Mail • Mixed Article #J Piece ID Addressee Name Delivery Address ES ES. Type Postage Fee Insurance Amount Due/ Total Sender Charge SEIBER, CHAD D. 9171999991703481679146 328 S. Enols Dr. R 2nd Enola, PA 17025 ALEOUIN, DAVID 9171999991703481679153 7118Saul Street Philadelphia, PA 19149 JUBILEE. GEORGE 9171999991703481679160 6543 Vandike Street Philadelphia, PA 18135 HUGGINS, DEANNA 9171999991703481679177 525 Bloomfield Ave. Drexel Hill. PA 19026 ERR C ERR C ERR C 0.480 0.480 0.480 1.35 3.30 1.35 3,30 1.35 3.30 5.13 5.13 5.13 0.480 6.13 ERR 1.35 C 3.30 HUGGINS. DEANNA 0.480 9171999991703481679184 6181 82nd Ave. ERR 1.35 Pinellas Park„ PL 33781 C 3.30 BINGHAM. EDUARDO 0.480 9171999991703481679191 4411 Church Avenue Apartment 10 ERR 1.35 Brooklyn. NY 11203 C 3.30 JOACHIM. JUDITH 0.480 9171999991703481679207 4411 Church Avenue Apartment 10 ERR 'Brooklyn. NY 11203 C CLARK. HAROLD E. 0.480 9171999991703481679214 155 Creek Road ERR Greentown, PA 18426 C CLARK. ROSE MARY 0.480 9171999991703481679221 155 Creek Road ERR Greentown. PA 18426 C 1.35 . 3.30 si' ./ O 1.35 f ;:: ....., 3.30 Z 4 N in 1.35 ti 3.30 ` 5.13 5.13 5.13 5.13 5.13 PAGANO, MELLISSA A. 0.480 5.13 9171999991703481679238 77 Govemors Place at Waterford ERR 1.35 York. PA 17402 C 3.30 PAGANO, PAUL J. 0.480 5.13 9171999991703481679245 77 Governors Place at Waterford ERR 1.35 York PA 17402 C 3.30 LITTLE, JAMAR 0.480 9171999991703481679252 PO Box 46861 ERR 1.35 Philadelphia. PA 19160 C 3.30 5.13 Page Totals 12 5.76 55.80 61.56 Cumulative Totals 24 11.52 111.60 123.12 http://pbpc/sendsuite%2Olive/projects/image.aspx?pd=1 10/24/2014 KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul, MN 55102 vs. CHAD D. SEIBER MELISSA R. SEIBER Mortgagor(s) and Record Owner(s) 5225 Wertzville Road Enola, PA 17025 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 14-527 AFFIDAVIT PURSUANT TO RULE 3129 GREEN TREE SERVICING LLC, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 5225 Wertzville Road Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): CHAD D. SEIBER 5225 Wertzville Road Enola, PA 17025 MELISSA R. SEIBER 63 Crooked Drive Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: CHAD D. SEIBER 5225 Wertzville Road Enola, PA 17025 MELISSA R. SEIBER 63 Crooked Drive Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: Hampden Township 230 S. Sporting Hill Road, Mechanicsburg, Pa. 17055 HSBC Bank Nevada, N.A. 1111 Town Center Drive, Las Vegas, Nv. 89193 LVNV Funding, LLC 120 N. Keyser Avenue, Scranton, Pa. 18504 Hampden Township Brenneman Keith O. Snelbaker & Brenneman 44 W. Main Street, PO Box 318 Mechanisburg, PA 17055 LVNV Funding, LLC Ratchford Michael F - Edwin A. Abrahamsen Assoc. 120 N. Keyser Ave Scranton, PA 18504 - 9701 HSBC Bank Nevada, N.A. Warmbrodt James C; Weltman Weinberg & Reis Co LPA 436 Seventh Ave Suite 1400 Pittsburgh, PA 15219 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: Mortgage Electronic Registration Systems as nominee for Countrywide Home Loans, Inc. P.O. Box 2026, Flint, Mi. 48501-2026 Mortgage Electronic Registration Systems as nominee for Countywide Home Loans, Inc. 4500 Park Granada, Calabasas, Ca. 91302-1613 The Bank of New York Mellon f/k/a The Bank of New York, as successor Trusteeto JP Morgan Chase Bank, N.A., as Trustee on behalf of the Certificateholders of the CWHEQ lnc., CWHEQ Revolving Home Equity Loan Trust, Series 2005-1 c/o BAC, M/C: CA6-914-01-43, 1800 Tapo Canyon Road, Simi Valley, Ca. 93063 5. Name and address of eveiy other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 5225 Wertzville Road Enola, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 12, 2014 KML Law Group, P.C. BY: Andrew Hauck Legal Assistant