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HomeMy WebLinkAbout14-2193 Supreme Cn nnsylvana � ..{ Con leas E i ratted M ,y ; a k Sifu b r R� v, Y t+ a � T County • a •n k F r s� €� z� w 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: Zt Complaint O Writ of Summons El Petition Transfer from Another-jurisdiction 13 Declaration of Taking. Lead Plaintiffs Name: Lead Defendant's Name: Are money damages requested? E3 Yes R7No Dollar Amount Requested: D within arbitration limits (check one) aoutside arbitration limits Is: this a Class Action Suit? 13 Yes 4� No Is this an "JAppear. 13 Yes No Name of Plaintiff/Appellant's Aitorney: . � Q.l V �� 1 f, C a rN i iri 1 Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Elsa " l�s r � v ` "r,i' { r ' ` �Y u _,� 4 .. s z�s �, � - . r,,N � �' � .:a 3 - -. s� t �• �ou g than one fj►pe ofartniieei� tie5tiine drat �, i �s+rt.- � t. � A r -. •.. s 2 k„� } • '`'Ni E ..i4wa�} ��'� i41�� R 13 -.' � x zT ��. u'xt �•oli Cio�isider.lnOSt Iin pctSU i k�ti � 5 'C} ' L' i l �`l�� �3�.� w ti��SG D� �' L 5 � � " �� tir t 1t4 t, t � y yx0 � t�.�._z. ti.•x �P. 14.,.. '. -,�. :::., ux. «x�: ...r. ,:4... �,. F..,r,.:;n? Y '., .;: ., �> f .;'.`>": . xi 1 t? = .,�. s '.,.iF7 1., ,.� {. ,a c w�� � ..��.'� � �..rt �,l t ;:.. 1� TORT (do not include Mass Tort) CONTRACT (do not include Judgments) `CIVIL APPEALS Q 'Intentional 13 Buyer Plaintiff > Administrative Agencies Malicious Prosecution ® Debt Collection: Credit Card Board of Assessment Q `Motor Vehicle 0 Debt Collection: Other Q Board of Elections Nuisance ; Dept. of Transportation ® Premises Liability Statutory Appeal: Other �: Product Liability (does not include mass. tort) ® Employment Dispute:. 13. `Slander/Libel/ Defamation Discrimination .Other: [3 Employment. Dispute: Other 13 Zoning Board 0 Other: Q Other: MASS' TORT Asbestos Q Tobacco Q Toxic Tort - DES Toxic Tort -Implant Toxic Waste REAL PROPERTY MISCELLANEOUS Q Other.. 13 Ejectment Q Common Law /Statutory Arbitration 13 Eminent Domain/condemnation 0 Declaratory Judgment ® Ground Rent Mandamus ® Landlord/Tenant Dispute Non- Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 13 Mortgage Foreclosure: Commercial. © Quo warranto ': Q Dental ® Partition 13 Replevin 0 Legal 13 Quiet Title [3 Other: Q Medteak [3 Other: r Q Other Professional: Updated 1/1/2011 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID#310501 ELIZABETH L. WASSALL ESQUIRE - ID#77788'' JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID #204252 AMANDA RAVER, ESQUIRE - ID#307028 WOODCREST CORPORATE CENTER m 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 Pleadings@udren.com PNC Bank, National Association COURT OF COMMON PLEAS 3232 Newmark Drive, Miamisburg, OH 45342 CIVIL DIVISION Plaintiff CUMBERLAND County U ,�►�3 C� NO. � l Gregory S Foulds 28 Cold Springs Road Carlisle, PA 17015 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; Harry B. Reese, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; John Eric Kishbaugh, Esquire; Nicole B. LaBletta, Esquire; David Neeren, Esquire, and Amanda Rauer, Esquire on behalf of the Plaintiff, in the above - captioned matter. UDREN LAW OFFICES, P.C. B SALVATORE CAROLLO, ESQUIRE PA ID 311050 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 , HARRY B. REESE, ESQUIRE - ID #310501 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 4 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252r AMANDA RAVER, ESQUIRE - ID#307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 r, CHERRY HILL, NJ 08003 -3620' 856 669 - 5400 pleadings @udren.com PNC Bank, National Association COURT OF COMMON PLEAS C/O PNC Bank, N.A. CIVIL DIVISION 3232 Newmark Drive CUMBERLAND County Miamisburg, OH 45342 r r (2( Plaintiff NO. I a 1 U 1 V. GREGORY S FOULDS 28 COLD SPRINGS ROAD CARLISLE, PA 17015 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 �i BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 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 dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir 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 SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 1. Plaintiff is PNC Bank, National Association. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: N/A Assignee: N/A Date of Assignment:N /A Recorded Date: N/A Book/Instrument #: N/A Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: Gregory S Foulds (hereinafter "Defendants "), are the owners of property located at 19E Allen Street, Mechanicsburg, PA 17050, by virtue of Deed dated 08/15/2007 and recorded 08/17/2007 in Official Records Book Instrument #200732348 at Page n/a of the Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property"). 3. On 08/15/2007, Defendant(s) and/or their predecessor: GREGORY S FOULDS promised to pay to the order of National City Mortgage a division of National City Bank, the principal sum of $ 74,900.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 08/15/2007, Defendant(s) and/or their predecessor: GREGORY S FOULDS to secure the Note, mortgaged to National City Mortgage a division of National City Bank, the Property which is the subject of this action. The Mortgage was recorded on 08/17/2007 in Official Records Book Instrument #200732350 at Page n/a . Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 11/01/2013, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $69,988.90 Accumulated Interest $2,601.85 Accumulated Late Charges $80.49 Escrow Deficit /(Reserve) $- 678.86 Property Inspection Fees $60.00 Grand Total $72,052.38 The above figures are calculated to 3/24/2014: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 7.75000 %. The per diem interest accruing on this debt is $14.8600 and that sum should be added to the above date and each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $26.83. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A" WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $72,052.38 plus ongoing interest, costs and attorney's fees and for sale of the Mortgaged premises. UDREN LA�08S P.C. BY: SALVATORE CAROLLO, ESQUIRE PA ID 311050 VERIFICATION I, Gaynell Bronson as an Authorized Signer of the Plaintiff, PNC Bank, National Association, do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff and that 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. Section 4904 relating to unsworn falsification to authorities. Date: I 1 Name: Gaynelle Bronson Title: Authorized Signer Company: PNC Bank, National Association MJU #: 14020153 CASE #: 14020153 -1 ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a drill mark in side walk concrete over an iron pin on the Northern line of East Allen Street at the Southeast corner of lands now or formerly of Potts Manufacturing Company; thence by lands of said Potts Manufacturing Company, North 23 degrees West 132.00 feet to a point at an iron pin on the Southern line of a 14 foot wide alley; thence North 67 degrees East along the Southern line of said alley, 19 feet to a point at an iron pin; thence South 23 degrees East, by the Western line of lands now or formerly of R.& S. vogelson 132.00 feet partly through the center line of the partition wall with house adjoining on the East to an iron pin on the Northern line of East Allen Street, thence South 67 degrees West by the Northern line of East Allen Street to the point and Place of BEGINNING. BEING improved with a dwelling house known as 19 East Allen Street, Mechanicsburg, Cumberland County, Pennsylvania. REPRESE Nc USPS CERTIFIED MAIL 9207 1969 0043 7100 0260 1731 15 3- 749 - 94648 -0000234-001 -01 -000 -000 -000 -000 GREGORY S FOULDS 19 E ALLEN ST MECHANICSBURG, PA 17050 Please find enclosed the ACT 91 NOTICE for Loan Number: 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. DR670 /1 /3/2014/0005625099 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1/3/2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1- 800 - 342 -2397 (Persons with impaired hearing can call (717) 780 -1869 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT HOMEOWNER'S NAME(S): GREGORY S FOULDS PROPERTY ADDRESS: 19 E ALLEN ST MECHANICSBURG, PA 17050 LOAN ACCT. NO.: ORIGINAL LENDER: National City Mortgage a division of National City Bank CURRENT LENDEPUSERVICER: PNC Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE LOIL DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOVE' TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the pro is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT YOU HAVE THE RIGHT TO FILE A HE" APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACT I N -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date NATURE OF THE DEFAULT - -The MORTGAGE debt held by the above lender on your property located at: 19 E ALLEN ST MECHANICSBURG, PA 17050 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $725.45 for 11/1/2013 - 12/1/2013, $731.80 for 1/1/2014 - 1/1/2014. Monthly Payments Accrued: $2,182.70 Late Charges Accrued: $53.66 Non - Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $36.00 Speedpay Fees: $0.00 TOTAL AMOUNT PAST DUE: $2,272.36 HOW TO CURE THE DEFAULT - -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,272.36, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: PNC Mortgage, A Division of PNC Bank, NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT IF YOU DO NOT CURE THE DEFAULT - -If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED- UPON - -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees OTHER LENDER REMEDIES - -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - -If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at an time up to one hour before the Sheriffs Sale You may do so by paving the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs eomiected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - -It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 10 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg, OH 45342 Phone Number: (800) 523 -8654 Fax Number: (855) 201 -6325 Contact Person: Collections Center E -Mail Address: LossMitigation @pncmortgage.com EFFECT OF SHERIFF'S SALE - -You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSLTA,IPTION OF MORTGAGE - -You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT YOU MAY ALSO HAVE THE RIGHT• • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling Service /CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888 -511 -2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717- 232 -9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York, PA 17401 717 - 855 -2752 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717- 762 -3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717 - 334 -1518 PHFA 211 North Front Street Harrisburg, PA 17110 717- 780 -3940 800 - 342 -2397 INTERNET REPRINT REPRESE PNC USPS CERTIFIED MAIL 4t . T1/IORTGAb & 9 207 1969 0043 7100 0260 1731 08 7- 748 -94648 -0000233 -001 -01 -000 -000 -000 -000 GREGORY S FOULDS 28 COLD SPRINGS RD CARLISLE, PA 17015 Please find enclosed the ACT 91 NOTICE for Loan Number: 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. DR672/1 /3/2014/0005625099 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1/3/2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works. To see if HEMAP can help, you must MEET NVITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT HOMEOWNER'S NAME(S): GREGORY S FOULDS PROPERTY ADDRESS: 19 E ALLEN ST MECHANICSBURG, PA 17050 LOAN ACCT. NO.: ORIGINAL LENDER: National City Mortgage a division of National City Bank CURRENT LENDER/SERVICER: PNC Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES - - you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the pro is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT YOU AVEVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - -The MORTGAGE debt held by the above lender on your property located at: 19 E ALLEN ST MECHANICSBURG, PA 17050 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $725.45 for 11/1/2013 - 12/1/2013, $731.80 for 1/1/2014 - 1/1/2014. Monthly Payments Accrued: $2,182.70 Late Charges Accrued: $53.66 Non - Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $36.00 Speedpay Fees: $0.00 TOTAL AMOUNT PAST DUE: $2,272.36 HOW TO CURE THE DEFAULT - -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,272.36, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check, certified check or money order made payable and sent to: PNC Mortgage, A Division of PNC Bank, NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT IF YOU DO NOT CURE THE DEFAL - LI - -If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged Property. IF THE MORTGAGE IS FORECLOSED UPON - -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - -If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time p to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus anvlate or other charges then due, reasonable attorney's fees and costs comnected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - -It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 10 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg, OH 45342 Phone Number: (800) 523 -8654 Fax Number: (855) 201 -6325 Contact Person: Collections Center E -Mail Address: LossMitigation @pncmortgage.com EFFECT OF SHERIFF'S SALE - -You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - -You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVLNG YOUR COUNTY Advantage Credit Counseling Service /CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888 -511 -2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717 - 232 -9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York, PA 17401 717 - 855 -2752 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717- 762 -3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717 - 334 -1518 PHFA 211 North Front Street Harrisburg, PA 17110 717 - 780 -3940 800 - 342 -2397 INTERNET REPRINT FORM 1 C IN, THE COURT OF COMMON PLEAS OF WC : CUMBERLAND COUNTY, PENNSYLVANIA Y ` Plaintiff(s) vs. Defendants) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSUMA 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 (7l 7) 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 b.e 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 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectf submitted: L Date ignature of Counsel for Plaintiff) SALVATORE CAROLLO, ESQUIRE PA ID 311050 FORM 2 Cumberland County Residential IViortgage 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: CLJSTOMER/PRIMARY 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: $ In.cluded 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 92 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles ): Model: Year: Amount owed: Value Monthly Income Name of Employers: l.. 2. Additional Income Description (not wages): I i 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° Mortgage Utilities Car Pa ens Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child. Su oft /Alim. Spending Mone Day/Child Care/Tuit. Other Expenses i Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes 0 No Q If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 .... .._..._........_..._......... ...... ..... _.__..._..._._. ....._.._ ....... .-- ........ __ .... _ 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 know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION Nor- 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 I /we 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: V Proof of income Past 2 bank statements Proof of any expected income for the last 45 days V Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Y Listing agreement (if property is currently on the market) FORM 3 IN THE COURT O T CUMBERLAND COUNTY PENNSYLVANIA D \ Plaintiff(s) Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken. all of the steps required. in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 1.8 Pa. C.S. §4904 relating to unswom falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson FI D-OFF 1C Sheriff U .r HE PR'O THGNQ TAti'i Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFCE »aFTHE ,INERF= 2014 M Y 13 PM 3.35 CUMBERLAND COUNTY PENNSYLVANIA PNC Bank National Association vs. Gregory S Foulds Case Number 2014-2193 SHERIFF'S RETURN OF SERVICE 04/17/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Gregory S Foulds, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 19 E. Allen Street, Mechanicsburg Borough, Mechanicsburg, PA 17050. Residence is vacant. 05/02/2014 05:45 PM - Deputy Ryan Burgett, 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: Gregory S Foulds at 28 Cold Springs Road, Dickinson Township, Carlisle, PA 17015. RYAN BURGETT, DEPUTY SHERIFF COST: $46.08 SO ANSWERS, May 06, 2014 RONNY R ANDERSON, SHERIFF (C CouniySuite Shontt, TC- eoscft, inc. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association . 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff v. Gregory S Foulds 28 Cold Springs Road Carlisle, PA 17015 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-2193 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), GREGORY S FOULDS; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Additional Late Charges Escrow Per Complaint Property Inspection Fees Grand Total FROM TO 03/25/2014 06/03/2014 03/25/2014 06/03/2014 $69,988.90 $2,601.85 $1,055.06 $80.49 $53.66 $-678.86 $60.00 $73,161.10 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES ARE EREBY ASSESSED AS INDICAT DATE: CQ 13 4 MJU#: 14020153 CASE#: 14020153-1 SQUIRE Sib.Sop UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - II) #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 HARRY B. REESE, ESQUIRE - ID#310501 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 AMANDA RAVER, ESQUIRE - ID#307028 • WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association C/O PNC Bank, N.A. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff v. GREGORY S FOULDS, 28 COLD SPRINGS ROAD CARLISLE, PA 17015 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County No, 14-DkCC3 COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 Co Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r t 4. OFC10E CI 7.14E St,EWF PNC Bank National Association vs. Gregory S Foulds Case Number 2014-2193 SHERIFF'S RETURN OF SERVICE 04/17/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Gregory S Foulds, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 19 E. Allen Street, Mechanicsburg Borough, Mechanicsburg, PA 17050. Residence is vacant 05/02/2014 05:45 PM - Deputy Ryan Burgett, 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: Gregory S Foulds at 28 Cold Springs Road, Dickinson Township, Carlisle, PA 17015. RYAN BURG , DEP SHERIFF COST:. $46.08 SO ANSWERS, May 06, 2014 RONRY R ANDERSON, SHERIFF (c) CcunrySuita Sheriff, Temosoft. Inc. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY MIL, NJ 08003-3620 856-669-5400 PNC Bank, National Association Plaintiff v. Gregory S Foulds Defendant(s) TO: Gregory S Foulds 28 Cold Springs Road Carlisle, PA 17015 Date of Notice: May 23, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE I NO. 14-2193 Civil IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, JMPORTANTES. DEBE LLE VAR ESTA NOTIFICACION A UN ABOGADO 1MMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO TAR FAIR DEBT COLLECTION PRACTICES ACT, TillS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. BY: UDREN LAW OFFICES, PC. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 14020153 CASE#: 14020153-1 • - trk, r t • 11• Pennsylvania Office 100 W. 3rd Ave. Suite 200 Conshohocken, PA 19428 (PH) 215-568-9500 Markj.. Udren, Esq. Licensed: PA, NJ, FL UDREN IA W OFFICES, P. C. New Jersey Office Woodcrest Corporate Center 111 Woodcrest Rd. Suite 200 Cherry Hill NJ 08003 (PH)856-669-5400 (FX) 856-669-5399 www.udren.com Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 Re: PNC Bank, National Association vs. GREGORY S FOULDS, Cumberland County C.C.P. No. 14-2193 Civil MJU#: 14020153 CASE#: 14020153-1 Florida Office 2101 W. Commercial Blvd Suite 5100 Fort Lauderdale, FL 33309 (PH) 954-378-1757 (FX) 954-378-1758 Dear Sir or Madam: Enclosed please find Affidavit of Non -Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non -Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance in this matter. Sincerely yours, Kevin Kerr Foreclosure Specialist MN/ Enclosures MJU#: 14020153 CASE#: 14020153-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. GREGORY S FOULDS, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-2193 Civil AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), GREGORY S FOULDS, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: June 2, 2014 MJU#: 14020153 CASE#: 14020153-1 Attorney foaintiff AMANDA L. RAUER, ESQUIRE PA. 1.D. # 307028 SCRA 3.0 Status Report Pursuant to Servicemembers Civil. Relief Act Last Name: FOULDS First Name: GREGORY Middle Name: S Active Duty Status As Of: Jun -02-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA'rf' .\ . • No. NA This response reflects the individuals'. active duty status based an the Active DutyStatus Date • The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Status Active Duty End Date NA Status Service Component NA This response reflects whether the individual or his/her unit has received early notification to report for active duty I -- NA - -1.K :;tr r -: No • NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA 'NA . -� . . . . . ,,Nd .�. NA This response reflects whether the individual or his/her unit has received early notification to report for active duty •� -r Upon searching the data banks of the Department of Defense Manpower. Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. • The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: LAQ9PF933063V10 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings @a,udren. com PNC Bank, National Association Plaintiff v. Gregory S Foulds ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-2193 Civil PRAECIPE TO ISSUE WRIT OF EXECUTION Defendant(s) TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 06/04/2014 to Date of Sale 09/03/2014 Ongoing Per Diem of $14.86 to actual date of sale including if sale is held at a later date. $ 73,161.10 $ 1367.12 -0 • (Costs to be added) $ MJU#: 14020153 CASE#: 14020153-1 auk a,.sb a °`41 Iors«i, SIO1L •83 UDREN L BY: Attorney W OFFICES, P.C. AMANDA L. RAUER, ESQUIRE PA. LD. # 307028 �,SDLV e.kt L(�su4 of RSd All that certain property situated in the township of Montgomery in the county of Franklin and commonwealth of Pennsylvania, being more fully described in a deed dated 11/19/1992 and recorded 11/20/1992, among the land records of the county and state set forth above in deed volume 1165 and page 523 and and being more fully described in a deed dated 7-25-1983 and recorded 7-25.1983, among the land records of the county and state set forth above in deed volume 884 and page 471. tax map/parcel id 17-J-19-89, 17-J-19-8914 BEING KNOWN AS: 19 E Allen Street, Mechanicsburg, PA 17050 PROPERTY ID NO.: 18-23-0565-038 TITLE TO SAID PREMISES IS VESTED IN Gregory S. Foulds, married man, as and wife tenants by the entirety BY DEED FROM Robert E. Greene and Peggy L. DATED 08/15/2007 RECORDED 08/17/2007 IN DEED BOOK Instrument #200732348 PAGE n/a. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. Gregory S Foulds Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE '0i o Cr NO. 14-2193 Civil z u1.7. c,a r) C CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above -captioned matter: El l Act 91 procedures have been fulfilled F-1 Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDRE , .v 0 FICES, P.C. BY: Attorney for P aintiff AN77.4�.,., A F R. ESQUIRE s . .. 3(.)7028 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, National Association Plaintiff v. Gregory S Foulds Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-2193 Civil AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: GREGORY S FOULDS 28 COLD SPRINGS ROAD CARLISLE, PA 17015 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. UDRENr • F CES, P.C. ri L Attorne 'T Plaintiff AMANDA L. RAUER, ESQUIRE PA. La # 307028 CD rr- UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a�udren.com PNC Bank, National Association Plaintiff v. Gregory S Foulds Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-2193 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, National Association, Plaintiff in the above action, by its undersigned attorney, pc a in "rmation and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 19 E Allen Street, Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Gregory S Foulds 28 Cold Springs Road Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: Gregory S Foulds 28 Cold Springs Road Carlisle, PA 17015 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bureau of Compliance PO Box 280948 Harrisburg, PA 17128 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, National Association 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Tenant/ Occupants 19 E Allen Street Mechanicsburg, PA 17050 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: t L I MJU#: 14020153 CASE#: 14020153-1 UDREN ' A ;;[� �` ICES, P.C. BY: Attorney' in iff AMANDA L. RAIDER, ESQUIRE PA. # 307028 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin l s ' udren.co PNC Bank, National Association Plaintiff v. GREGORY S FOULDS Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-2193 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Gregory S Foulds 28 Cold Springs Road Carlisle, PA 17015 C") c ca' Your house (real estate) at 19 E Allen Street, Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriffs Sale on 09/03/2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $73,161.10, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net PNC BANK, NATIONAL ASSOCIATION Vs. GREGORY S. FOULDS WRIT OF EXECUTION NO 14-2193 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $73,161.10 L.L.: $.50 Interest FROM 6/4/2014 TO DATE OF SALE 9/3/2014 - ONGOING PER DIEM OF $14.86 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $1,367.12 Atty's Comm: Atty Paid: $194.83 Plaintiff Paid: Date: 6/4/14 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name: AMANDA L. RAUER, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 307028 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICEOF TRE S!»ERL FF. AUG29 PSI 2: DI CUMBERLAND COUNTY PENNSYLVANIA PNC Bank National Association vs. Case Number Gregory S Foulds 2014-2193 SHERIFF'S RETURN OF SERVICE 06/16/2014 04:40 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 19 E Allen Street, Mechanicsburg Borough, Mechanicsburg, PA 17050, Cumberland County. 07/08/2014 11:25 AM - Sgt. Jason Vioral, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Gregory S. Foulds at the Cumberland County Sheriffs Office, 1 Courthouse Square, Carlisle, PA 17013. 07/21/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $792.11 SO ANSWERS, August 28, 2014 RONY R ANDERSON, SHERIFF !;=i CountyStvie Sheriff, i"e&eosoft, Inc. [IdL. c_ s7 3/0 Li d_o • LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2014-2193 Civil PNC BANK NATIONAL ASSOCIATION vs. GREGORY S. FOULDS Amanda L. Rauer Atty.: Mark Udren All that certain property situated in the township of Montgomery in the county of Franklin and com- monwealth of Pennsylvania, be- ing more fully described in a deed dated 11/19/1992 and recorded 11/20/1992, among the land re- cords of the county and state set forth above in deed volume 1165 and page 523 and and being more fully described in a deed dated 7-25-1983 add recorded 7-25-1983, among the land records of the county and state set forth above in deed volume 884 and page 471. tax map/parcel id 17- J-19-89, 17 -J -19-89L0. BEING KNOWN AS: 19 E Allen Street, Mechanicsburg, PA 17050. PROPERTY ID NO.: 18-23-0565- 038. TITLE TO SAID PREMISES IS VESTED IN Gregory S. Foulds,a mar- ried man as tenants by the entirety BY DEED FROM Robert E. Greene and Peggy L. Burkett, husband and wife Dated 08/15/2007 RECORDED 08/17/2007 IN DEED BOOK Instru- ment #200 PAGE n/a. 44 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 11 and July 18, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this da Jul 2014 Notary COMMONWEALTH OF PUINSYIVANM► NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28. 2018 The Patriot -News Co. 1900 Patriot Drive Mechanicsburg, PA 1705Q Inquiries - 717-255-8213 • CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the atriotXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Amy Kotula, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as io the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on lehalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the ;tockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds n and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 201 193 Civil Term PNC TANK NATIO SOCIATION vs. GREGORY S FOU Amanda L Rauer Atty: Mark Udren 1 that certain property situated in township of Montgomery in the , unty of Franklin and commonwealth Pennsylvania, being more fully cribed in a deed dated 11/19/1992 1 recorded 11/20/1992, among the d records of the county and state forth above in deed volume 1165 page 523 and being more fully gibed in a deed dated 7-25-1983 recorded 7-25-1983, among the 1 records of the county and state forth above in deed volume 884 page 471. Tell—, 1,4mr l id 17 -l- o t7 T ,o„Qoi This ad ran on the date(s) shown below: 07/13/14 07/20/14 07/27/14 Sworn to and subscribed before me this 20 day of August, 2014 A.D. 04114 0 ryl blic COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Sheryl Marie Leggin, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES