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Home My WebLink About14-1755 Supreme Court of Pennsyl-vania Coui� f f C0 ou. Pleas ` f For Use Only. Gis l...C,6ve2. Sheet Cum - berlan( 'i. cou fy Docker No: } The information collected on this form is used solel or f f 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: R Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: PNC MORTGAGE, A DIVISION OF PNC BANK, JENNIFER L. GREEN C NATIONAL ASSOCIATION JONATHAN M. GREEN T T Dollar Amount Requested within arbitration limits Q Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits 1 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 S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) ❑Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑Employment Dispute: Other T ❑ Other: I 0 MASS TORT ❑ Other ❑ Asbestos N ❑ 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. F SUITE 5000 - BNY MELLON INDEPENDENCE CENT)] k T i E F ! q T H G N 01' `• f % y 701 MARKET STREET PHILADELPHIA, PA 19106 I MTiR 2 5 P I li (866) 413 -2311 PNC MORTGAGE, A DIVISION OF PNC BANK,P IN THE COURT OF COMMON PLEAS NATIONAL ASSOCIATION 3232 Newmark Drive OF Cumberland COUNTY Miamisburg, OH 45342 Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JENNIFER L. GREEN JONATHAN M. GREEN I Mortgagor(s) and Record Owner(s) No. r U 1 Midland Road CPAL A MON: MORTGAGI Newville, PA 17241 Defendant(s) FORE=SM 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 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 # � 20 �. ?yob 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 0 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.gWx 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@kmllawgroup.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 129644FC. 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 MORTGAGE, A DIVISION OF PNC BAND, NATIONAL ASSOCIATION, 3232 Newmark Drive, Miamisburg, OH 45342. 2. The name(s) and address(es) of the Defendant(s) is /are JENNIFER L. GREEN, 1 Midland Road, Newville, PA 17241 and JONATHAN M. GREEN, 1 Midland Road, Newville, PA 17241, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On August 06, 2010 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to HERITAGE HOME MORTGAGE, LLC, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on August 18, 2010 as Instrument #: 201022830. The mortgage has been assigned to: PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION by assignment of Mortgage recorded on November 19, 2010 as Instrument#: 201033892 . 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 101.9(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 October 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 03/01/2014: PrincipalBalance ............................... ............................... ....................$157,249.74 Interest from 09/01/2013 to 03/01/2014 at 4.7500 % .......... ......................$3,734.70 Monthly Interest at $622.45 LateCharges ......................................... ............................... ........................$193.86 Escrow /Impound Overdraft .................. ............................... ........................$792.42 ProRata MIP ......................................... ............................... ........................$139.88 UnpaidOther Fees ................................. ............................... .........................$36.00 InspectionCosts ..................................... ............................... .........................$12.00 Appraisal................................................ ............................... .......... .............$1.75.00 $162,333.60 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 $162,333.60, together with interest at the rate of $622.45, 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 attorne fees and costs, until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale o th Property. By: KML LAW GROUP, P.C. 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 ill 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 I, ® TWwman , as a A dwdzed 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 NAME: Bm Trowtllan TITLE: Authorized Signer #129644FC - JENNIFER L. GREEN and JONATHAN M. GREEN 1 Midland Road Newville, PA 17241 E.xhibitA ALL THOSE CERTAIN lots of ground situate in the Township of West Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as foilo-ms, to wit. BEING Lot Nos. 56 and 57, in the Plan of Lots of the Big Spring Heights Extension, as recorded in Plan Book No. 4, Page 16 and adopted by Andrew McElwain; bounded on the East by adjacent Lot No. 58; on the South by Midland Road (erroneously referred to as Avenue); on the West by adjacent Lot No. 55; and on the North by a 20 foot alley; sa id Lot Nos. 56 and 57 having a combined frontage Of 100-00 feet, and depth of 200.00 feet. ERECTED a ranch house known and numbered as 1 Midland Road, Newville, Pennsylvania. r E-X.,hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information REPRESE PNC USPS CERTIFIED MAIL MORTGAGE 9207 1969 0043 7100 0260 2209 56 6 94714 -0000095 -001- 01 -000 -000 -000 -000 JONATHAN M GREEN 1 MIDLAND RD NEWVILLE, PA 17241 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE for Loan Number: =973 This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. PA001 / 1 /6/2014/8000013973 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT Date: 1/6/2014 Re: Loan No.�973 NOTICE OF INTENTION 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 1 MIDLAND RD, NEWVILLE, PA 17241, IS IN SERIOUS DEFAULT because you have not made the monthly payments $1,203.18 for 10/1/2013 - 12/1/2013, $1,236.73 for 1/1/2014 - 1/1/2014. Late charges and other charges have also accrued to this date in the amount of $168.39. 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 $5,014.66. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $5,014.66, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's 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 will 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 sale [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 nine to 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 Sheriffs 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 Sheriffs 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 ATTORNEY'S 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 RIGHT TO 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. INTERNET REPRINT »I REPRESS ( I USPS CERTIFIED MAIL MORTGAGE'" 9207 1969 0043 7100 0260 2209 63 3 - 74 9- 94714 -0000096 -001- 01 -000 -000 -000 -000 JENNIFER L GREEN 1 MIDLAND RD NEWVILLE, PA 17241 Please find the NOTICE OF INTENTION TO FORECLOSE MORTGAGE for Loan Number: -3973 This is an attempt to collect a debt. Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. PA002 /1 /6/2014/8000013973 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT Date: 1/6/2014 Re: Loan No.�973 NOTICE OF INTENTION 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 1 MIDLAND RD, NEWVILLE, PA 17241, IS IN SERIOUS DEFAULT because you have not made the monthly payments $1,203.18 for 10/1/2013 - 12/1/2013, $1,236.73 for 1/1/2014 - 1/1/2014. Late charges and other charges have also accrued to this date in the amount of $168.39. 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 $5,014.66. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $5,014.66, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's 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 will 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 Sheri)fs 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 sale [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 nine to 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 Sheriffs 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 Sheriffs 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 ATTORNEY'S 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 RIGHT TO 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. INTERNET REPRINT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA A r ri PNC MORTGAGE, A DIVISION OF PNC BANK NATIONAL ASSOCIATION Plaintiff Case No. VS. •� � JENNIFER L. GREEN? JONATHAN M. GREEN Defendant(s) 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. Respectfully miffed (Signature of Cou se for Plaintiff) z �Y Date Cumberland County Residential Mortgage Foreclosure Diversion Program Bate Financial Worksheet Cumberland County Court of Common Pleas Docket # BORROWER REQUEST F R HARDSHIP ASSISTANCE To complete-your request for hardship assistance, your leader must consider your circumstances to determine possible options while 'working with your Please provide the following information to the best of your knowledge: P.IpZ APPLICANT Borrower name(s): Property Address: City: State Zip: Is the property for sale? Yes U No L2 Listing date: Price: S Realtor Name: _ -- Realtor Phone: Borrow =er Occupied? yes Na 4 Mailing Address (if different): City: State: Zip: Phone Numbers: Home: office: FMal: Cell: Other; # of people in household.: How long? Mailing Address; Cit State: Zip: Phone Numbers: Home: Office, Erna%i: Cell: Other: # ofpeople in household: How long? _ First Mortgage Lender: "Type of Loan: Loan Number-. Date You Closed Your Loam: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes eft Insurance; Date of Last Payment: Primary Reasan for Default: Is the loan in Bankruptcy? 'Yes No Y If yes, provide natives, location of court, case nuMber & attorney; .Assets Anrsou Owed: _Value: Borne: — Other heal Estate: Retirement Funds, � Investments. Checking: Savings; $� Other $ Automobile fl: Model: Year: Amount owed: Value: -- Amtpmobile #2 : Model: Year: Amount owed: Value: Other transportation aut )mobiles boats rnotorc�cles - Mo del: Year Amount owed: Value Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not: wages ); 1. monthly amount: 2. monthly amount: Borrower Pay Days: _ Co- Borrower Pay Days: Monthly Exttenses: (Please only include expenses you are Currently paying) EXPENSE AM6 T EXPENSE AMOUNT a e Food 2 halo a e Utilities j Car Pa men s Condo/Neigh, Pees Auto Insurance Med. not covered Auto fueltre irs Other mo a vane — nt Install. Loan. l'a ,ment jCable. TV Child Su rtlAlim, S rdin Mone Ua JlChilii Carel'I'uit. Other Ex erases Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes [l No El If yes, please provide the following information: Counseling .Agency: . Couriselor: . Phone,(Office) Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program , (HEMAP) assistance? Yes'] No If yes, please indicate the status of the application:__ Have you had any prior negotiations with your tender or lender's loan servicing company to resolve your delinquency? Yes [I NoEl If yes, please indicate the status of those negotiations: Please provide the following; information, if know, regarding your lender or leader's loan servicing company: Lender's Contact (blame ): Phone: Servicing Company (dame): Contact: Phone: AUTHO Itwe, authorize the above named to uselrefer this information to my fonderlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. YWe understand that I/we am/are under no obligation to use the services provided by the above named Eorro*er Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of income Past bank statements PrOOf of any expected income for the last 45 days Copy of a current utility bill Letter explaining treason for delinquency and any supporting documentation LL r (hardship ,letter) V lasting agreement (if property is currently on the rnstrket) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY tr a1 C owlet, OFF 10E OF Ti E SHERIFF THE PROTHONO T1 ate , 21..Uti APR --2 PH 4 CUMBERLAND COUNT` PENNSYLVANIA PNC Mortgage, A Division of PNC Bank, National Association vs. Jennifer L Green (et al.) Case Number 2014 -1755 SHERIFF'S RETURN OF SERVICE 03/27/2014 08:37 PM - Deputy Dawn Kell, 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: Jennifer L Green at 1 Midland Road, West Pennsboro, Newville, PA 17241. (11011 DAWN KELL, DEPUTY 03/27/2014 08:37 PM - Deputy Dawn Kell, 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: Jonathan M Green at 1 Midland Road, West Pennsboro, Newville, PA 17241. SHERIFF COST: $57.56 March 28, 2014 (c) CountySuite Sheriff, Te!eosoft, Inc. DAWN KELL, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 PNC MORTGAGE, A DIVISION OF PNC BANK, NATIONAL ASSOCIATION 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff vs. JENNIFER L. GREEN JONATHAN M. GREEN (Mortgagor(s) and Record owner(s)) 1 Midland Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 14-1755 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. cz -z f-" Jrn c KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: 7 JN" l ' Mich el McKeever Pa. ID 56129 Jay . Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, Pa. ID 313897 Jennifer Lynn Frechie, Pa. ID 316160 Attorneys for Plaintiff