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Home My WebLink About14-1009 Supreme Court of Pennsylvania -- Cou0 C' -moll Pleas - — lj1l;�G01-ei' For F :nfihongtarr Use Onto': , Cum` berlaiid); County Docker d: : 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: PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR JOHN A. MARTIN C IN INTEREST TO NATIONAL CITY REAL ESTATE T SERVICES LLC SUCCESSOR BY MERGER TO I Dollar Amount Requested within arbitration limits 0 Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A 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 r • Premises Liability ❑ Zoning Board • Product Liability (does not include ❑ Employment dispute: ❑ Statutory Appeal: Other E mass tort) Discrimination C ❑ Slander/Libel Defamation ❑ Other ❑Employment Dispute: Other T ❑ Other: CI 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 X Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin • Medical • Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413 -2311 wWl1'.KA4i i.AwGROUP.CONI PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN THE COURT OF COMMON PLEAS IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO OF Cumberland COUNTY NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. CIVIL ACTION - LAW 3232 Newmark Drive Miamisburg, OH 45342 ACTION OF MORTGAGE FORECLOSURE Plaint VS. No. JOHN A. MARTIN - VIL ACTION: MORTGACII Mortgagor(s) and Record Owner(s) 116 East Main Street FO WLOSM Shiremanstown, PA 17011 Defendant(s) 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 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 rz� r 2 Liberty Avenue ?? , Carlisle, PA 17013 c CD CD 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 a otros derechos importantes para usted. S alli 6 %Ib a 3D kgct on 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 PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. 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://xvNvw.phfa.org/consumers/homeowners/real.AVx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http: / /w-�&wv.philadelphiafed.orQ /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 homeretentiongkmllawaroup.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 125374FC. Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO., 3232 Newmark Drive, Miamisburg, OH 45342. 2. The name(s) and address(es) of the Defendant(s) is /are JOHN A. MARTIN, 116 East Main Street, Shiremanstown, PA 17011, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On March 12, 1999 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to FIRST UNITED MORTGAGE SERVICES, INC.,, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on March 16, 1999 as Book # 1526, Page # 681. The mortgage has been assigned to: NATIONAL CITY MORTGAGE CO. by assignment of Mortgage recorded on March 16, 1999 as Book # 606, Page 1004. 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, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of 11/01/2013: Principal Balance ................................ ............................... .....................$58,188.29 Interest from 04/01/2013 to 11/01/2013 at 7.0000 % .......... ......................$2,376.01 Monthly Interest at $339.43 LateCharges ......................................... ............................... ........................$181.44 Escrow /Impound Overdraft .................. ............................... ........................$920.70 ProRata MIP .......................................... ............................... .........................$70.11 UnpaidOther Fees ................................. ............................... .........................$48.00 InspectionCosts ..................................... ............................... .........................$24.00 Appraisal............................................... .:............................. ........... .............$175.00 $61,983.55 7. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. Notice of Intention to Foreclose has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit B ". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $61,983.55, together with interest at the rate of $339.43, per month and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law, including but not limited to attorney fees and costs, until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the property. By: KML LAW UP, Michael McKeever 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. ID 205047 Jill P. Jenkins Pa. ID 306588 drew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION I Sarah C. McClain , as a Authorized Signer , of PNC BANK, NATIONAL ASSOCIATION do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff, and the facts set forth in the foregoing Complaint 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: PNC BANK, NATIONAL ASSOCIATION Nom: Sarah C. McClain TITLE: Authorized Signer 4125374FC - JOHN A. MARTIN 116 East Main Street Shiremanstown, PA 17011 ExhibitA ALL THAT CERTAIN lot of ground situate in the Bcxough of Shiremanstown, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: On the North by Main Street, on the West by lot now or formerly of John L. Miller, on the South by Oak Alley and on the Haut by lot now or formerly of W. Scott Strong, having a width along said Main Street of thirty -one (31) feet and a width along said alley of thirty -one (31) feet, and having thereon erected a two and one -half story double frame dwelling house known as Nos. 116 and lie East Main Street, Shiremanstown, PA; BEING =3 SAME PREMISES which W. Wesley Runkel (erroneously referred to in prior dead as W. Wesley Runkle) and Grace I. Runkel, his wife, by dead dated Jsnuary 17, 1973 and recorded January 23, 1973 in the Cumberland County Office of the Recorder of Feeds in Deed Book Z -24 Page 336 granted and conveyed to W. Wesley Runkel and Grace I. Runkel, his wife. AND THE SAID W. Wesley Runkel thereafter departed this life, whereby and wherein title to the herein described property vested in Grace I. Runkel, his wife by operation of law. AND THE SAID Grace 1. Runkel died testate on April 29, 1998, leaving a will dated January 17, 1973 and duly proven, probated and filed in the Register of Wills Office of Cumberland County, PA in Estate File 41998 -390 and Letters Testamentary were granted to Eva M. Ryder and Faye D. Dunlap, Co- Executors. And being the same premises which Faye D. Dunlap and Eva M. Ryder, Co- Executrixes of the of Grace I_ Runkel, by deed dated March - 12th, 1999 and which is intended to be recorded herewith in the Cumberland County Office of the Recorder of Deeds, granted and conveyed unto John A. Martin, a single man, Mortgagor herein. rl jv yl: f the (eQ �f(dfld Cout?ty, e j j nC:• T jl' A.i it es yban t i �iCy :0 o�lfii�J t� Eyhibit *Exhibit has been redacted to remove all personally identifiable information or non-public information PNC MORTGAGE- Attention: Collection Department (86 - 5) 3232 Ne.aark Orire Miamisburg, ON 45342 Certified Article Nurrter 7196 9009 9111 8684 0000 SEN DERS • ' tr JOHN A MARTIN 116 6 MAIN ST SHIRMNSTOWN, PA 17011 Please find the NOTICE OF INTENTIQ =40 RECLOSE MORTGAGE For Loan Member 063 This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have received a dis in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Hank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. PA001 A D'MSion of PNC Bank, National Assodation T1 937- 910 -1200 T2 800-822.5626 3232 Newmark Dr Miamisbury OH 45342 PO BOX 1820 Dayton OH 45401 -1820 Date: 8 /5/2013 Re: Loan No._7063 NOTICE OF MENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PNC Mortgage a division of PNC Bank, National Association (hereinafter we, us or ours) on your property located at 116 E MAIN ST, SHIREMANSTOWN, PA 17011, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $768.66for the months of 5/1/2013 through 81112013. Tate charges and other charges have also accrued to this date in the amount of $144.96. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $3,219.60. You may cure this default within THRTY (30) DAYS of the date of this letter, by paying to us the above amount of $3,219.60, phis any additional monthly payments and late charge which may fall due during this period Such payment must be made either by cash, cashiers check, certified check or money order, and made at PNC Mortgage /Collections Center, Mail Code B6- YM09 -01 -01, 3232 Newmark Drive, Miamisburg, OH 45342. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $ 50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $ 50.00. Any attorney's fees win be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure stile /and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately mint - ten months. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number. 1. 800-523 -8654. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sherill's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEYS FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED[. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST). YOU HAVE THE RIGHTTO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default the mortgage will be restored to the same position as if no default had occurred However, . you are not entitled to this right to cure your default more than three times in any calendar year. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR 11 / IN INTEREST TO NATIONAL CITY REAL )q- ESTATE SERVICES, LLC, SUCCESSOR BY Case No. v MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. rn � Plaintiff N p`, vs. JOHN A. MARTIN ' o ? Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSIfftE 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 infonnation so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully s d: (Signature of o nsel for Ralntiff.) Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete-your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): 'Property Address: City: State: Zip: Is the property for sale? Yes Ej — No Q 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? First Mortgage'Lender: Type of Loan: Loan Number: Date You Closed Your Lean: Second Mortgage .Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Bate of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes M No ❑ ff yes, provide names, location of court, case numb & attorney: Assets A mount Owed Value: Home: S $ Other Real Estate: $ $ Retirement Funds: S $ Investments: $ $ Checking: $ 1 $ Savings: $ $ Other. $ $ Automobile #l: Model- Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats motoraycles?• Model Year: Amount owed: Value Monthly Income Name of Employers: 1. 2. 3. .Additional Income Description (not wages): I. _...._ monthly amount: 2. monthly amount: Borrower Pay Days: Co Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMO EXPENSE AMOUNT Moo a e Food 2 MortgaLe Utilities Car Pavrnen s CondoNei h. Fees Auto Insurance Ivied. not covered Auto fuel/repairs- Other prop. pzXment Install. Loan Pa rrmcnt Cable TV Child Su rt/Alim. Spending, ony 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 EJ No n If yes, please provide the following information: Counseling Agency: Counselor: Phone.(Office): Fax: r 7 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMA ) assistance? Yes (] No 0 If yes, please indicate the status of the application: Have you had any prior negotiations with your tender 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 leader's loam servicing company: Lender's Contact (blame): ?bone: Servicing Company (Dame): Contact: Phone: l('e, , 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, lfwe understand that Uwe am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income JVF Past 2 bank statements �f Proof of any expected income for the last 45 days } Copy of a current utility bill Y Letter explaining reason for delinquency and any supporting documentation . (hardship letter) Listing agreement (if property is currently on the marl�et) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY os,,,,vp of Cif loot A4' OFFICE OP THE p4ERIFF Kilt MAR 17 AM ID: CUM9ERLAND COUNTY PENNSYLVANIA PNC Bank National Association vs. John A. Martin Case Number 2014-1009 SHERIFF'S RETURN OF SERVICE 03/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: John A. Martin, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 116 E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. Residence is vacant and per the Camp Hill Postmaster the defendant moved and left no forwarding address. SHERIFF COST: $49.95 SO ANSWERS, March 12, 2014 RONNIY R ANDERSON, SHERIFF (c) CountyGuite SPeriff, Te Leos:oft, Inc. KML Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 -1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff vs. JOHN A. MARTIN Mortgagor(s) and Record Owner(s) 116 East Main Street Shiremanstown, PA 17011 Defendant(s) t.t APR titl II: 1r 1M.1E)r_ i;IL't ��fsD CGU;rT,I / I Li Y IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 14 -1009 PRAECIPE TO CORRECT PROPERTY ADDRESS Kindly correct the caption to reflect the correct property address of 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street, Shiremanstown, PA 17011. Respectfully submitted, KML Law Group, P.C. By: KML LAW ROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 6185.8 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jt: Jenkins Pa. ID 306588 yo Alyk L. Oflazian, Pa. ID 312912 Attorneys for Plaintiff KML Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215)627-1322 - ATTORNE Y FOR PLAINTIFF PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg, OH 45342 VS. JOHN A. MARTIN Plaintiff (Mortgagor(s) and Record Owner(s)) 116 East Main Street Shiremanstown, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE Term No. 14-1009 Sarah Jim, hereby certifies that he/she did serve true and correct copies of Praecipe to Correct Property Address and all sup i orting • apers attached hereto upon Defendant, by first class mail, postage pre-paid, on JOHN A. MARTIN 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street, Shiremanstown, PA 17011 By: KML Law Group, P. . Sarah Jim, Legal Assistant sjim@lunllawgroup.com 215-825-6458 (Direct Phone) KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106 -1532 215- 627 -1322 Attorney for Plaintiff -OFF! 'THONG TAM.' 2014 APR -8 •M1IO:51 CUMBERLAND COUNTY PENNS YLVANIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, 1NC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg, OH 45342 vs. JOHN A. MARTIN 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street Shiremanstown, PA 17011 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 14 -1009 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. 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 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street, Shiremanstown, PA, 17011, hereinafter, the "mortgaged premises ". 2. premises. 3. Defendant, JOHN A. MARTIN, is the mortgagor and real owner of the mortgaged 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 address of Defendant, John A. Martin, is 116 East Main Street, Camp Hill, PA 17011 from our investigative search. 5. The Sheriff has been unable to effect service of the Complaint upon Defendant, John A. Martin. Service was attempted on Defendant, John A. Martin at the mortgaged premises 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street, Shiremanstown, PA, 17011. The return of service indicates said address is vacant and that per the Postmaster Defendant, John A. Martin moved from said address and left no forwarding address. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, John A. Martin. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendant, John A. Martin, by posting the premises and certified and regular mail to the property address. 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 )0Alyk 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: 125374FC Attorney /Law Firm: KML LAW GROUP, P.0 Subject Name: JOHN A. MARTIN Property Address: Street: 116 East Main Street City: Shiremanstown State: PA Zip: 17011 Skip Results: Date of Birth: Last Known Address (as of 3/20/2014) Street: 116 E Main St City: Camp Hill State: PA ProVest File Number: 3925699 Zip: 17011 6311 Death Record Search As of 03/20/2014, the Social Security Administration has no death record on file for John A Martin. Social Security Number [X] Vented [ ] Not Verified SSN# 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 address from the credit header info is: Address: 116 E MAIN ST, CAMP HILL, PA 17011 6311 Department of Motor Vehicle Records Search* Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Drivers License Information Search [ ] Govemmental**+ [X] Non-governmental 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: 116 EAST MAIN STREET I SHIREMANSTOWN I PA 1 17011 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 - 957 -4333: Called possible relative, Jerry Wilson, answering machine answered, no message left. 717 - 292 -6985: Called possible relative, Amanda Martin, answering machine answered, no message left. Comments: No records found in the Federal Bureau of Prisons. No records found in the Pennsylvania Department of Corrections. No records found in Vinelink No records found in the Philadelphia Prison System. 717-737 -4847: Called number listed to defendant, John Martin, generic voicemail answered, no message left. 717- 975 -2449: Called number listed to defendant, John Martin, there was no answer. 717 - 761 -3305: Called number listed to defendant, John Martin, there was no answer. • 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 unsworn falsification to authorities. Under penalties of perjury, I declare that I have read the foregoing affidavit and that the facts stated in it are true. anna Hemandez ProVest File Number: 39 STATE OF FLORIDA COUNTY OF HILLSBOROUGH Sworn to or affirmed and signed before me on this _ day of MAR 21 2014 Provest Services LLC L (Seal) Date: O` V \23 V1 JOSHUA N. PIMIpNTEL Notary Public, State of Florida My Comm. Expires May 24, 2015 No. EE 97050 Printed Name of Notary Public ( Personally Known ( ) Produced as identification Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 00, at ti (it OFFICE OF THE $H'ERIFF PNC Bank National Association vs. John A. Martin Case Number 2014 -1009 SHERIFF'S RETURN OF SERVICE 03/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 116 E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. Residence is vacant and per the Camp Hill Postmaster the defendant moved and left no forwarding address. SHERIFF COST: $49.95 March 12, 2014 (c) CountySuite Sheriff, Teleosoft. Inc. SO ANSWERS, RONNW R ANDERSON, SHERIFF ICIVIL Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CllY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg, OH 45342" VS. JOHN A. MARTIN 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street Shiremanstown, PA 17011 THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 14-1009 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant, John A. Martin, which the Sheriff has been unable to personally serve upon Defendant, John A. Martin. 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 Complaint in Mortgage Foreclosure upon Defendant, John A. Martin, by posting the premises and certified mail and regular mail to the property address. 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 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY IN THE COURT OF COMMON PLEAS REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, of Cumberland County INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg, OH 45342 No. 14-1009 VS. JOHN A. MARTIN 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street Shiremanstown, PA 17011 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 Defendant, John A. Martin this postage prepaid. JOHN A. MARTIN 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street Shiremanstown, PA 17011 By: day of April 2014, by first class mail, KML Law Group, P.C. Marlene Powers, Legal Secretary Direct Phone: 215-825-6340 PNC BANK, NATIONAL ASSOCIATION, THE COURT OF COMMON PLEAS SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY OF Cumberland COUNTY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. ct: CD -11 3232 Newmark Drive 14-1009 -13 a _.,--- 4 Miamisburg, OH 45342 ril-T7 --r. r--1 -.,.. -1.7 ..... ---, JOHN A. MARTIN ---147-, 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East _ 1 --T7. Main Street Shiremanstown, PA 17011 z:,..." f 4) , ORDER 4, - 7 - AND NOW, this 15- day of 4.» 2014, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant, John A. Martin, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant, John A. Martin, by posting a copy of the Complaint upon the premises 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street, Shiremanstown, PA, 17011/, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendant's last known address at 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street, Shiremanstown, PA, 17011, 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, John A. Martin, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. Service is complete upon mailing. BY CO D. ibution list: ichael T. McKeever, Esquire, Suite 5000 NY Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 JOHN A. MARTIN, 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street Shiremanstown, PA 17011 KIVIL Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF 11; in:0T,LIONO TA 20/4 4PR 28 g 1 11: L CU/j0[ AND COUNTY PENNS YL VA NIA PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff VS. JOHN A. MARTIN 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street Shiremanstown, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 14-1009 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. 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 Jay E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 Jennifer Lynn Frechie Pa. ID 316160 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Cl1V1/4, e-4 gOblicP 4KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff Epp: 71 S 10. v4, /id PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg, OH 45342 vs. JOHN A. MARTIN Mortgagor(s) 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street Shiremanstown, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CERTIFICATE OF SERVICE The undersigned, on behalf of Plaintiff, hereby certifies that on CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 14-1009 he did serve upon Defendant(s) JOHN A. MARTIN a true and correct copy of the above -captioned Complaint by certified and regular mail in accordance with the Court Order dated April 15th 2014. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. By: Respectfully submitted, 711/b/ KML Law Group, P.C. Nick Barone, Legal Assistant NBarone@kmllawgroup.coin 215-825-6365 (Direct Phone) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF!CE OF TH:E $VER F:F FILED -OFFICE THE PROTHONOTARY 20ill MAY -8 PH 2: 5 CUMBERLAND COUNTY PENNSYLVANIA PNC Bank National Association vs. Case Number John A. Martin 2014-1009 SHERIFF'S RETURN OF SERVICE 05/05/2014 07:01 PM - Ronny R Anderson, Sheriff, who being duly sworn according to law, states this Complaint in Mortgage Foreclosure upon defendant John A. Martin is returned not served per request from KML Law Group. SHERIFF COST: $44.95 SO ANSWERS, May 06, 2014 (c) CountySu Sheriff: Teleosoff, Inc. RONNI 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 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff vs. JOHN A. MARTIN 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street Shiremanstown, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 14-1009 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: KML LAW GfCOUP, 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. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 Jennifer Lynn Frechie Pa. ID 316160 )lyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff II /Sp oogs� 'R,}� 31Py5 KML Law Group; P.C. -- Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 Newmark Drive Miamisburg, OH 45342 vs. JOHN A. MARTIN Mortgagor(s) 116 East Main Street, Camp Hill, PA 17011 a/k/a 116 East Main Street Shiremanstown, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CERTIFICATE OF SERVICE The undersigned, on behalf of Plaintiff, hereby certifies that on CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Tenn No. 14-1009 //-)7c-i he did serve upon Defendant JOHN A. MARTIN a true and correct copy of the above -captioned Complaint by certified and regular mail in accordance with the Court Order dated April 15th 2014. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. By: Respectfully submitted, KML Law Group, P.C. Nick Barone, Legal Assistant NBarone@kmllawgroup.com 215-825-6365 (Direct Phone) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY . HE PRO T HON ; . . . l..OiEs NOV 17 PH 3: 05 CUMBERLAND COUNTY PENNSYLVANIA OFF o(;F 1i; Fr PNC Bank National Association vs. John A. Martin Case Number 2014-1009 SHERIFF'S RETURN OF SERVICE 10/30/2014 04:09 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: John A. Martin, pursuant to Order of Court by "Posting" the premises located at 116 E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011 with a true and correct copy according to law. ISTOP SHERIFF COST: $50.95 SO ANSWERS, November 05, 2014 (c) CountySuito Sheriff, Toleosoft, inc. HARPE, DEPUTY RONR ANDERSON, SHERIFF