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Home My WebLink About14-0635 Supreme Court -.of Pennsylvania Cour & Com>aa ,Pleas For Prothonotary Use Only: Ca€v fl C Vv Sheet CU County Docket No:.. The information collected on this form is used solely for court administration purposes. This form does not su lement or repl th e filing and service gLeleadings or other papers as required by law or rules of court. S Commencement of Action: Complaint ❑ Writ of Summons ❑ Petition E Cl Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: WELLS FARGO BANK, N.A. Lead Defendant's Name: CORNELIUS J. RUSNOV T I Dollar Amount Requested: C3 within arbitration limits Are money damages requested? ❑Yes � No 0 (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑ Yes 9 No Is this an MDJ Appeal? ❑ Yes No Name of Plaintiff/Appellant's Attorney: Meredith Wooters Esq Id No 307207 Phelan Halligan, LLP `� ❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important: TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other 0 Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability 0 Statutory Appeal: Other O Product Liability (does not include mass tort) 0 Employment Dispute: S ❑ Slander /Libel/ Defamation Discrimination E ❑ Other: O Employment Dispute: Other O Zoning Board C ❑ Other: T I MASS TORT ❑ Other: 0 ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES — O Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non- Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto • Dental ❑ Partition ❑ Replevin. • Legal ❑ Quiet Title ❑ Other: El Medical ❑ Other: ❑ Other Professional: Pa.R.C.P. 205.5 Updated 01/01/2011 I 'D co VA y N PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF Meredith Wooters, Esq., Id. No.307207 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Meredith.Wooters@phelanhallinan.com 215 -563 -7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD CIVIL DIVISION FORT MILL, SC 29715 )q- Plaintiff, NO.: vs. CORNELIUS J. RUSNOV SANDRA LYNNE BUCKLEY- RUSNOV 1115 CHARLES STREET MECHANICSBURG, PA 17055 -3947 Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes WELLS FARGO BANK, N.A.,, by its attorneys, Phelan Hallinan, LLP and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIE 062 -PA -V4 BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff"). 2. The Defendants are, CORNELIUS J. RUSNOV and SANDRA LYNNE BUCKLEY- RUSNOV, with a last known address of 1115 CHARLES STREET, MECHANICSBURG, PA 17055 -3947. 3. In order to protect the borrower's privacy, certain personal information of the borrower (such as loan account, Social Security numbers and birth dates), may have been partially or completely redacted on the exhibits to this Complaint. 4. WELLS FARGO BANK, N.A., directly or through an agent, has possession of the Promissory Note. WELLS FARGO BANK, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A copy of said Promissory Note is marked Exhibit "A ", attached hereto and made a part hereof. 5. On or about August 15, 2008, CORNELIUS J. RUSNOV and SANDRA LYNNE BUCKLEY - RUSNOV made, executed and delivered to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR HOWARD HANNA MORTGAGE SERVICES a Mortgage in the original principal amount of $161,500.00 on the premises described in the legal description marked Exhibit "B ", attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of CUMBERLAND County on August 19, 2008, in Instrument No. 200828253. The Mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded August 14, 2013, the mortgage was assigned to WELLS FARGO BANK, NA which Assignment is recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 201327074. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 062 -PA -V4 ' 1 7. CORNELIUS J. RUSNOV and SANDRA LYNNE BUCKLEY - RUSNOV are record and real owners of the aforesaid mortgaged premises. 8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the installments of principal and interest due June 1, 2013. 9. As of 01/27/2014, the amount due and owing Plaintiff on the mortgage is as follows: Principal $151,978.47 Interest $7,289.44 From 05/01/2013 to 01/27/2014 Late Charges $306.24 Escrow Advance $1,679.45 Property Inspections $0.00 Property Preservation $0.00 BPO /Appraisals $0.00 Escrow Balance $0.00 Corporate Advance Credit $0.00 . Total $161,253.60 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff 062 -PA -V4 is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $161,253.60, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. By: Date: a 3 y Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff 062 -PA -V4 Exhibit "A" NOTE /S�G PMI CASE August 15th, 2008 CAMPHILL PENNSYLVAN {Date) lciw [State] 1115 CHARLES STREET MECHANICSBURG , PA 17055 [Prop- rrAddf —) 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. S 161,500.00 (this amount is called "Principal "). plus interest. to The order of the Lender.'The Lender is Howard Hanna Mortgage Services, a Pennsylvania Corporation I will make all payments under ibis Note In the form of cash, check or money order. 1 understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who Is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 6.500 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1st day of each month beginning on October 1st 2008 . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on September 1st, 2036 1 still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Dale." 1 will make my monthly payments at 119 Gamma Dr, Pittsburgh, PA 15238 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 1,020.79 4. BORROWER'S RIGHT TO PREPAY 1 have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, 1 will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. 1 may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, (here will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. S. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges. Is finally interpreted so that The interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit: and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. if a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for OverduoPsyments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due. I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and Interest. 1 will pay this late charge promptly but only once on each late payment. (B) Default If 1 do not pay the full amount of each monthly payment on the date it is due. I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice Telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice Is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if 1 am in default at a later lime. MULTISTATE FIXED RATE NOTE - SW&Fsmly- FmniebadFrdeiew< UMFORH INMUMOM Fmm 33001/01- REVISED FOR PENNSYLVAMA G32WPA -01 (04/07) (Page I Of2) Initials. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay Immediately In full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses In enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under This Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note, is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surely or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce Its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some Jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage. Deed of Trust. or Security Deed (the "Security Instrument "), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts 1 owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender If such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not Iess than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. if Borrower falls to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HANDS AND SEAL(S) OF THE UNDERSIGNED This is a contract under seal and may be enf der 42 Pa. C.S. Section 5529(B). CORNELIUS J RUSNOV Borrower (Seal) ALLONGE ATTACHED FOR THE - Borrower PURPOSE OF ENDORSING THE NOTE (Seal) - Borrower (Seal) - Borrower /Sign Original Only) MULTtsTATEFUMD RATE NOTE — tNrrxunrerrr ramr=oo 1101 G3200PA -02 (09 /07) (Page 2 02) � , '� A �' , �� 1. ALLONGE MORTGAGOR: CORNELIUS J RUSNOV ADDRESS OF MORTGAGOR 1115 CHARLES STREET MECHANICSBURG , PA 17055 / MORTGAGE AMOUNT $161,500.00 NOTE DATE: 08/15/2008 / PAY TO THE ORDER OF ECOUFiSE WITHOUT RECOURSE PAY TO THE ORDER OF: Welts Fargo Bank, N.A. FRANKLIN AMERICAN MORTGAGE COMPANY Its Assigns and /or Successors B y ?J Lori K. Venego a Vice President loart Uacumentation HOWARD HANNA MORTGAGE SERVICES Pay to the ogler of Wells Fargo Bank, N.A. By: without recourse vin J L i can Mortgage COY Vice President B �� M&UZA Amy McK , Support Team Lead tl?�" Exhibit "B" LEGAL DESCRIPTION ALL THAT CERTAIN lot in Plan No. 1, of Orchard Crest, nit he Borough of Mechanicsburg, Cumberland County, Pennsylvania, as shown on the survey dated August 10, 1961, by W.G. Rechel, R.E. more fully described as follows: Lot 8, Section 'D'. BEGINNING at a point on the northerly side of Charles Street, where the division line between lots seven (7) and eight (8) intersects with the northerly side of Charles Street; thence north twenty -two (22) degrees forty -seven (47) minutes west, along the division line between lots seven (7) and eight (8), a distance of one hundred forty -one and thirty -eight hundredths (1.41.38) feet to a point; thence north sixty -six (66) degrees forty -three (43) minutes east, a distance of seventy -five (75) feet to a point; thence south twenty -two (22) degrees forty - seven (47) minutes east, along the division line between lots eight (8) and nine (9), a distance of one hundred forty -one and thirty -eight hundredths (141.38) feet to a point; thence south sixty -six (66) degrees forty -three (43) minutes west, along the northerly side of Charles Street, a distance of seventy -five (75) feet to a point, the place of BEGINNING. BEING THE SAME PREMISES which Campbell Luxury Living Homes, Inc., formerly M.R. Campbell, Inc., a Pennsylvania corporation, by deed dated August 7, 1962 and recorded August 16, 1962 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book P, Volume 20, Page 614, granted and conveyed unto Ira Glenn Gilleland, Jr. and Josephine E. Gilleland, husband and wife, Grantors herein. PROPERTY ADDRESS: 1115 CHARLES STREET, MECHANICSBURG, PA 17055 -3947 PARCEL #17 -23 -0561 -150 Filet 938875 e VERIFICATION Linwood Williams , hereby states that&she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that&she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of&her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Linwood Williams Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 01128/2014 086 -PA -V2 File #938875 a ' FORM 1 IN THE COURT OF COMMON PLEAS WELLS FARGO BANK, N.A. OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) • e � —C't vs. < G a W CORNELIUS J. RUSNOV r rr c� SANDRA LYNNE BUCKLEY - RUSNOV S { r Defendant(s) Civil; '" NOTICE OF RESIDENTIAL MORTGAGE FORECLO DIVERSION PROGRAM F yc ° 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 fmancial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff -_ FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles boats motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: I . Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 °d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care /Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: s ' 0 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Uwe am/are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6 Listing agreement (if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 938875 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff tiitr at c ara�[^ t�`i t r' 1� Jody S Smith FED Zp PH 2. Chief Deputy Richard W Stewart Solicitor ` ENNs YLVANIR Wells Fargo Bank, N.A. Case Number vs. Cornelius J Rusnov(et al.) 2014-635 SHERIFF'S RETURN OF SERVICE 02/07/2014 06:54 PM- Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Cornelius J Rusnov at 1115 Charles Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. JASO KINfd SL'EFVDEPUTY 02/07/2014 06:54 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Cornelius J Rusnov, Husband, who accepted as "Adult Person in Charge"for Sandra Lynne Buckly-Rosnov at 1115 Charles Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. JASOPfRINSL PUTY SHERIFF COST: $55.30 SO ANSWERS, x �X� February 10, 2014 RbNW R ANDERSON, SHERIFF Stephen L. Grose, Esquire Attorney I.D. No. 31006 Saidis Sullivan & Rogers 635 North 12th Street, Suite 400 Lemoyne, PA 17043 Phone: (717) 612 -5802 Fax: (717) 612 -5805 Email: sgrose@ssr- attorneys.com Attorneys for Defendants WELLS FARGO BANK, N.A., : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs. : NO.: 14 -635 Civil CORNELIUS J. RUSNOV and SANDRA : LYNNE BUCKLEY - RUSNOV, Defendants ENTRY OF APPEARANCE Please enter my appearance on behalf of the defendants in the above matter for purposes of providing counsel for participation in the Cumberland County Mortgage Foreclosure Diversion Program only and not for the foreclosure action in general. Respectfully submitted, SAIDIS SULLIVAN & ROGERS Dated: March 14, 2014 By: ST PHEN L. GROSE Attorney I.D. #31006 CERTIFICATE OF SERVICE I, Stephen L. Grose, Esquire, attorney for defendants, Cornelius J. Rusnov and Sandra Lynne Buckley - Rusnov, hereby certify that I have served the foregoing paper upon counsel of record this date by depositing a true and correct copy of the same in the United States mail, first -class postage prepaid, addressed as follows: Meredith Wooters, Esquire Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 SAIDIS SULLIVAN & ROGERS By: Dated: March 14, 2014 Steph n L. Grose WELLS FARGO BANK, N.A., : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs. : NO.: 14 -635 Civil CORNELIUS J. RUSNOV and SANDRA : LYNNE BUCKLEY- RUSNOV, Defendants PRAECIPE TO PROCEED IN FORMA PAUPER'S To the Prothonotary: Kindly allow Defendants, Cornelius J. Rusnov and Sandra Lynne Buckley - Rusnov, to proceed in forma pauperis. I, Stephen L. Grose, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Respectfully submitted, SAIDIS SULLIVAN & ROGERS Dated: March 14, 2014 By: /4_ ST 0' HEN L. GROSE Attorney I.D. #31006 635 N. 12th Street, Suite 400 Lemoyne, PA 17043 Telephone: (717) 612 -5802 Facsimile: (717) 612 -5805 Email: sgrose @ssr- attorneys.com Budget Details Case number: 21281 Client: Address: Budget Name: Summary Rusnov, Comelius J 1115 Charles St Mechanicsburg, PA 17055 CCCS of W.PA Budget Incomes u r .�.� Monthly .. Total income 2,783.43 Total expenses 3,199.00 Surplus /Shortfall - 415.57 Incomes u r .�.� ., u �. , -, _.. 1111onthi _. Y, .�_ - - - ... Descnpi+on �` `'�` "� ....,�x Monthly Base Salary 250.00 Housing /Utilities - Water net 42.00 Housing /Utilities - Sewer and trash 2,783.43 Food /Groceries 400.00 Auto/Transportation /Gas and oil 200.00 Total: 2,783.43 Expenses Date: 03/04/2014 Page: 1 a.p .,.w, �� Descn .913 w , ? .a .,,� .- .. 1111onthi _. Y, Housing /Mortgage payment Wells Fargo Home Mortgage 1,468.00 Housing /Utilities - Electric 100.00 ` Housing /Utilities - Heating fuel 250.00 Housing /Utilities - Water 42.00 Housing /Utilities - Sewer and trash 70.00 Food /Groceries 400.00 Auto/Transportation /Gas and oil 200.00 Auto/Transportation /Auto insurance 50.00 Auto/Transportation /Car maintenance 25.00 Health care /Doctors' visits 45.00 Health care /Pharmacy 75.00 Telephone/Telecom /Cell phone 55.00 Telephone/Telecom /Intemet/ISP and cable 59.00 Personal care /Clothing 50.00 Personal care /Haircuts /Barber 25.00 Entertainment/Movies Entertainment/Memberships /Subscriptions professional dues 10.00 Children /Lunch (school) 75.00 PetsNet bills Liabilities /Credit cards /Credit Tine /HELOC Members 1st 100.00 Liabilities /Credit cards /Open 30 day charge account Members 1st 100.00 Total: 3,199.00 Date: 03/04/2014 Page: 1 CERTIFICATE OF SERVICE I, Stephen L. Grose, Esquire, attorney for defendants, Cornelius J. Rusnov and Sandra Lynne Buckley - Rusnov, hereby certify that I have served the foregoing paper upon counsel of record this date by depositing a true and correct copy of the same in the United States mail, first -class postage prepaid, addressed as follows: Meredith Wooters, Esquire Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 SAIDIS SULLIVAN & ROGERS By: Dated: March 14, 2014 Steph €n Grose gas-- Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 F L F 0 FF1CF 0.F THE PROTHONOTARY 2-014 OCT 23 Ail CUMBERLAND COUNTY PENNSYLVANIA Attorney For Plaintiff WELLS FARGO BANK, N.A. Plaintiff v. CORNELIUS J. RUSNOV SANDRA LYNNE BUCKLEY-RUSNOV Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 14 -635 -CIVIL PRAECIPE TO THE PROTHONOTARY: El Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. E Please mark the above referenced case Settled, Discontinued and Ended. E Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. LJ Please mark the in rem judgment Satisfied and the action Discontinued and Ended. E Please Vacate the Judgment entered. Date: /0/2/4/ PFJELANHALLINAN, LLP PH # 938875 By: Kenya Bates, Esq., Id. No.203664 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff WELLS FARGO BANK, N.A. Plaintiff v. CORNELIUS J. RUSNOV SANDRA LYNNE BUCKLEY-RUSNOV Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 14 -635 -CIVIL CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff's Praecipe was served by regular mail to the person(s) on the date listed below: Stephen L. Grose, Esquire Saidis Sullivan & Rogers, P.C. 635 North 12th Street Suite 400 Lemoyne, PA 17043 Date: /d/i /477 PHELAN HALLINAN, LLP By: Kenya Bates, Esq., Id. No.203664 Attorney for Plaintiff