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HomeMy WebLinkAbout14-2317 Supreme Court -of Pennsylvania Cour. off` C.ommo. , .Pleas For Prothonotary Use Only: vi Covet, S eet ? ., �� ��,. -r ixi 1 C County Docket No: / J 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. S Commencement of Action: ❑O Complaint ❑ Writ of Summons ❑ Petition E+ ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: PHH MORTGAGE Lead Defendant's Name: NATHAN P. BEAHM T CORPORATION Dollar Amount Requested: 11 within arbitration limits I Are money damages requested? El Yes 9 No 0 (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑ Yes 0 No Is this an NWJ Appeal? ❑ Yes 0 No A Name of Plaintiff /Appellant's Attorney: Michael Dingerdissen Esq., Id No.317124 Phelan Hallinan, LLP ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVII. APPEALS ❑ 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 • Premises Liability ❑ Statutory Appeal: Other • Product Liability (does not S include mass tort) ❑ Employment Dispute: • Slander/Libel/ Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T I MASS TORT ❑ Other: 0 ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration $ ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin • Dental ❑ Quiet Title ❑ Other: • Legal ❑ Other: • Medical • Other Professional: Pa.RC.P. 205.5 Updated 01/01/2011 y { rfl lam. e l} �JJy tl V 1I1;i`+ PHELAN HALLINAN, LLP Michael Dingerdissen, Esq., Id. No.317124 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 Michael.Dingerdissen@phelanhallinan.com 215 -563 -7000 PHH MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD COURT OF COMMON PLEAS MOUNT LAUREL, NJ 08054 CIVIL DIVISION Plaintiff V. TERM NATHAN P. BEAHM NO. 1 q , 1.9 ANNETTE DRIVE ENOLA, PA 17025 -1802 CUMBERLAND COUNTY AMANDA D. BEAHM 19 ANNETTE DRIVE ENOLA, PA 17025 -1802 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 944726 �(L �t42���( I` 2 ..7�. 4SL4' I . Plaintiff is PHH MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: NATHAN P. BEAHM 19 ANNETTE DRIVE ENOLA, PA 17025 -1802 AMANDA D. BEAHM 19 ANNETTE DRIVE ENOLA, PA 17025 -1802 who is /are the mortgagor(s) and /or real owner(s) of the property hereinafter described. 3. On 08/31/2009 NATHAN P. BEAHM and AMANDA D. BEAHM made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR ERA MORTGAGE, which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200931827. By Assignment of Mortgage recorded 04/19/2013 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Instrument No. 201312659. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/01/2013 and each month thereafter are due and unpaid, and by the terms File #: 944726 of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 03/31/2014: Principal Balance $155,289.43 Interest $9,656.36 03/01/2013 through 05/01/2014 Late Charges $146.16 Property Inspections $45.00 Escrow Deficit $2,666.56 TOTAL $167,803.51 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has /have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has /have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 944726 9. This action does not come under Act 91 of 1983 because the mortgage is FHA - insured. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $167,803.51, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By. Michael Dingerdissen, Esq., Id. No.317124 Attorney for Plaintiff File #: 944726 LEGAL DESCRIPTION ALL THAT CERTAIN land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: TRACT NO, 1 BEGINNING at a point of Intersection of the northern line of Annette Drive and the line of the adjoiner between Lots Nos. 103 and 104 on the hereinafter mentioned Plan of Lots; thence North 22 degrees 09 minutes 50 seconds East by said line of adjoiner, a distance of 135.09 feet to a point at lands now or formerly of Acri; thence South 66 degrees 39 minutes East a distance of 77.27 feet to a point on the northwest corner of Lot No. 102 on said Plan; thence South 23 degrees 21 minutes West along the line of adjoiner between Lots Nos. 102 and 103 on said Plan, a distance of 135 feet to a point on the northern line of Annette Drive; thence North 66 degrees 39 minutes West along said northern line of Annette Drive, a distance of 68.21 feet to a point; thence continuing along the northern line of Annette Drive measured in a northwesterly direction on a curve to the left, having a radius of 302.77 feet, an arc distance of 6.27 feet to a point, the place of BEGINNING. BEING Lot No. 103, Plan 5, Section'C' of Penn Heights as recorded in Cumberland County Recorder of Deeds Office in Plan Book 21, page 31. TRACT NO, 2 BEGINNING at the point of the Intersection of the northern line of Annette Drive and the line of adjoiner between Lots Nos. 104 and 105 on the hereinafter mentioned Plan of Lots; thence North 08 degrees 55 minutes East by said line of adjoiner, a distance of 137.36 feet to a point at lands now or formerly of Acri; thence North 84 degrees 36 minutes East a distance of 23.97 feet to a point; thence South 66 degrees 39 minutes East, a distance of 79.63 Pile #: 944726 feet to a point on the northwest corner of Lot No. 103 on said Plan; thence South 22 degrees 09 minutes 50 seconds West along the line of the adjoiner between Lots Nos. 103 and 104 on said Plan a distance of 135.09 feet to a point on the northern line of Annette Drive; thence continuing along said northern line of Annette Drive, measured in a northwesterly direction on a curve to the left, having a radius of 302.77 feet, an arc distance of 70 feet to the point and place of BEGINNING BEING Lot No. 104, Plan 5, Section'C' of Penn Heights as recorded in Cumberland County Recorder of Deeds Office in Plan Book 21, page 31. PROPERTY ADDRESS: 19 ANNETTE DRIVE, ENOLA, PA 17025 -1802 PARCEL #09 -14- 0836 -011. File #: 944726 VERIFICATION William Bellows hereby states that he /she is Assistant Vice President of PHH MORTGAGE CORPORATION, Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his /her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: y 7• ZO / ;� « /�� �� Name William Bellows Title: Assistant vice President PHH MORTGAGE CORPORATION File #: 944726 Name: BEAHM File #: 944726 FORM 1 IN THE COURT OF COMMON PLEAS`c'� PHH MORTGAGE CORPORATION OF CUMBERLAND COUNTY, PENNSYLUAI4A ; Plaintiff(s) ? vs.�t NATHAN P. BEAHM AMANDA D. BEAHM Defendant(s) I Civil y3 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 a)be 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) 2439400 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 canbe prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a Request for Conciliation Conference with the Court, which must be filed with the Cout 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 arrangenents 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 woksheet 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 onference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date Michael Dingerdissen, Esq., Id. No.317124 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: CUSTOM ER/I:'RIMAIZV APPLICANT ,r 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: -- Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION _.. r . First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 ° Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAI assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we am /are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6 Listing agreement (if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 944726 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff LL ll Jody S Smith .Saxe o :r.rara r THE PRO HOB :; r t;J Chief Deputy 2014 APR 30 PH 3: 0 Richard W Stewart Solicitor 0 CUMBERLAND COUNTY "��` "��``� PENNSYLVANIA PHH Mortgage Corporation Case Number vs. Nathan P Beahm (et al.) 2014-2317 SHERIFF'S RETURN OF SERVICE 04/25/2014 08:31 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 handing a true copy to a person representing themselves to be Amanda Beahm,wife,who accepted as"Adult Person in Charge"for Nathan P Beahm at 19 Annette Drive, East Pennsboro, Enola, PA 17025. DAWN KELL, DEPUTY 04/25/2014 08:31 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: Amanda D Beahm at 19 Annette Drive, East Pennsboro, Enola, PA 17025. 34-1-3/-1 V-12-t12_ DAWN KELL, DEPUTY SHERIFF COST: $60.95 SO ANSWERS, April 28, 2014 RON R ANDERSON, SHERIFF (c)CountySUte Sneriff,Teleoscft,Inc. F LEiD- fCF: ilE i'',OT O TA_ , 2r.:141:7U IT 03 CU:"'^x+^iA"'0 COUNTY PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 PHH Mortgage Corporation 2001 Bishops Gate Blvd Mount Laurel, NJ 08054 Plaintiff v. Nathan P. Beahm 19 Annette Drive Enola, PA 17025-1802 Amanda D. Beahm 19 Annette Drive Enola, PA 17025-1802 Defendants Attorney for Plaintiff Court of Common Pleas Civil Division No. 14 -2317 -CIVIL Cumberland County MOTION TO LIFT CONCILIATION STAY Plaintiff, PHH Mortgage Corporation (hereinafter "Plaintiff"), by its attorney, Joseph P. Schalk, Esquire, hereby files the within Motion to Lift Conciliation Stay and in support thereof avers as follows: 1 On April 16, 2014, Plaintiff filed a Complaint in Mortgage Foreclosure against Defendants Nathan P. Beahm and Amanda D. Beahm (hereinafter "Defendants") for the failure to make monthly payments of principal and interest upon their mortgage due April 1, 2013, and 944726 each month thereafter. A true and correct copy of the Complaint is attached hereto, made part hereof and marked as Exhibit "A". 2. On April 25, 2014, Plaintiff completed service of the Complaint in Mortgage Foreclosure along with the Cumberland County Residential Mortgage Foreclosure Diversion Program Notice upon the Defendants. A true and correct copy of the Sheriffs Return of Service is attached hereto, made part hereof and marked as Exhibit "B". 3. Pursuant to the Cumberland County Administrative Order February 28, 2012, which created the Cumberland County Residential Mortgage Foreclosure Diversion Program, the Foreclosure action is stayed for sixty (60) days from the date of service. 4. Within 60 days after service of the complaint, the Defendants may opt into the program by filing a Request for Conciliation Conference with the Court. Upon the filing of the request, the Court will schedule a Conciliation Conference. The program provides that Defendants must contact MidPenn Legal Services within the first twenty (20) days of receipt of notice if not represented by counsel. 5. If more than sixty (60) days has elapsed since the service of Notice of Residential Mortgage Foreclosure Diversion Program and the Defendants have not opted to participate in the Diversion Program Plaintiff may petition the Court to lift the stay and remove the case from the Diversion Program. 6. Defendants have failed to opt into the Cumberland County Residential Mortgage Foreclosure Diversion Program within sixty (60) days of service. 7. Since Defendants have opted not to participate in the Diversion Program, it is appropriate for the stay to be lifted. 944726 WHEREFORE, Plaintiff respectfully requests that this matter be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program and the automatic stay be lifted. Date: 944726 BY: Respectfully submitted, PHELAN HALLINAN, LLP Schalk, Esquire ney for Plaintiff Ehjbjt "A" PHELAN HALLINAN, LLP Michael DIngordlasen, Esq., Id. No.317124 1617 JPK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Michael.Dingerdissen®phelanhallinan.com 215.563.7000 PHI -I MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD MOUNT LAUREL, NJ 08054 Plaintiff vi NATHAN P. BEAHM 19 ANNE'I th DRIVE ENOLA, PA 17025-1802 AMANDA D. BEAHM 19 ANNETTE DRIVE ENOLA, PA 17025-1802 File 4: 944726 Defendants .=.w"��"ral.�. CI1:E r ROTHONOTAR 2014 APR 16 AM ICI: 08 CIIERL AND PENHSVLV RLE COP, EASE RETURN lialev rtifythattr tobltvRsldcof'nonoopy atimparbiallisdef roost ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 14 " a2'�►� CUMBERLAND COUNTY qty 4 fQN - LAW CO14PLAINTIN AIQUGAG ?ORECLOSVRE E T 0 N A s E T 0 N Supreme Court o Pennsylvania Cou Crnu PIeas et ft County For Prothonotary Use Only: Lead Plaintiffs Name: PJ -EH MORTGAGE CORPORATION Docket No: The information collected on this form is used solely for court administration purposes, This form does not supplement or re. 4ace the fluincand service.a or other itt mr,t as ree u re( law or r Commencement of Action: 0 Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction 0 Declaration of Taking Lead Plaintiffs Name: PJ -EH MORTGAGE CORPORATION Lead Defendant's Name; NATHAN P. BEAHM Are money damages requested? 0 Yes fl No Dollar Amount Requested: 0 within arbitration limits (Check one) IE outside arbitration limits Is this an MDJ Appeai? 0 Yes ID No Is this a Class Action Suit? 0 Yes [8] No Name of Plaintiff/Appellant's Attorney: Michael Dingerdissen, Esq., Id. No.317124, Phelan Hallinan, LLP p Check here if you have no attorney (are a Self -Represented [Pro soLitigant) Natureof.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) 0 Intentional 0 Malicious Prosecution 0 Motor Vehicle El Nuisance CONTRACT (do not include Judgments) 0 Buyer Plaintiff 0 Debt Collection: Credit Card 0 Debt Collection: Other CIVIL APPEALS Administrative Agencies 0 Board of Assessment 0 Board of Elections 0 Dept. of Transportation 0 Premises Liability 0 Statutory Appeal: Other 0 Product Liability (does not include mass tort) 0 Employment Dispute: --- 0 Slander/LibeV Defamation 0 Other: Discrimination 0 Employment Dispute; Other 0 Zoning Board 0 Other: MASS TORT 0 Other: 0 Asbestos 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant 0 Toxic Waste 0 Other: REAL PROPERTY 0 Ejectment 0 Eminent Domain/Condemnation 0 Ground Rent MISCELLANEOUS 0 Common Law/Statutory Arbitration 0 Declaratory Judgment 0 Mandamus 0 Landlord/Tenant Dispute 0 Non -Domestic Relations lE1 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY 0 Dental 0 Legal fp Mortgage Foreclosure: Commercial 0 Partition El Quiet Title 0 Other: 0 Quo Warrant° 0 Replevin 0 Other: 0 Medical 0 Other Professional: Pa.R.C.P. 205.5 Updated 01/01/2011 PJ -IH MORTGAGE CORPORATION Plaintiff(s) vs. NATHAN P. BEAHM FORM 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMANDA D. BEAHM Defendant(s) Civil 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 de 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 n conciliation conference. Fife, within twenty (20) days of your receipt of this notice, yOulnust contact MidPenn tegal Services at (717) 2419400. extension 2510 or (800) 822-5288 eXtensiOn 2510 and request appointment of a legal representative at no charge to you, Qnceyou haVo.been appointed a legal repretntative, 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 canbe prepared on:your behalf If you and yOur legal representative complete a financial Worksheet in the format attached'hereto, the legal representative will prepare and a Request for Conciliation Conference with the Court, which must be filed with the Con within sixty (60) days of the service upon you of the foreelosiire 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 nn attempt to work out reasonable arrangenents with your lender before the mortgage foreclosure -suit ptocoeds 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 MidPerai Legal Service for the appointment of a legal repreteatative. However, you must provide your lawyer with all requested financial infomiation so that a loan resolution proposal can be prepared on your behalf Wyatt and your lawyer complete u financial woksheet in the fortriat attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which %Mist be filed within sixty (60) days of the aarvice upon yon -of the fOreclosure complaint. If you do so and a conciliation onference is scheduled, you will have an opportunity t6meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the rnortgage '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. 91-1511-9 Date Respectfully submitted: Micheal Dingerdissen, Esq., Id, No.317124 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Yes JJ No LJ Listing date: Realtor Name: - Borrower Occupied? Yes EFF175) - Mailing Address (if different): City: State: Zip: Price: $ Realtor Phone: State: Zip: Phone Numbers: Home: Cell: Email: Office: Other: # of people in household: How long? Mailing Address: City: Phone Numbers: Email: Xoiricf Celt:. Office: Other: State:_a.): # of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Date You C osed Your Loan: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: Included Taxes & In ura ce: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ Investments: $ Checking: $ Savings: $ $ Other: $ -$_ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2: Model: _ Year: Amount owed: Value: onjautomobilcs, boats, ni©torcycles); Model: Amount owed: Value ;Other tr: ng. c Year: Monthly Income Name of Employers: 1. 2. Monthly Gross Monthly Net Monthly Gross Monthly Net 3. Monthly Gross: _ Monthly Net Additional Income Description (not wages): 1, monthly amount: 2. monthly. amount: Borrower Pay Days: Co -Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mori . e Food 2° Mortgage Utilities P Car ayments) Auto InsuranceMed. Condo/Neigh. Fees (not covered) Other prop p yment Cable TV ,� Auto fuel/repairs Install. Loan Pa en Child Support/Alim. Spending Money Other Expenses bay/Child Care/Tuit. Amount Available for Monthly Mortgage Payments Based on Income & Expenses: }lave you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Phone (Office): Fax: Counselor: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application.: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: I/We, Phone: 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 counseling services provided by the above named Borrower Signature Date Co -Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6 Listing agreement (if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File Th 944726 PHELAN HALLINAN, LLP Michael Dlngerdissen, Esq., Id. No,317124 1617 JFK Eaulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Michael,Dingerdissen©phelanhallinan.com 215.563.7000 ATTORNEY FOR PLAINTIFF PHH MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD COURT OF COMMON PLEAS MOUNT LAUREL, NJ 08054 CIVIL DIVISION Plaintiff v., TERM NATHAN P, BEAHM NO. 19 ANNETTE DRIVE ENOLA, PA 17025-1802 CUMBERLAND COUNTY AMANDA D. 8EAHM 19 ANNETTE DRIVE ENOLA, PA 17025-1802 Defendants CIVIL 6.CTJON - LAW COMTLAINT IN MORTGAGE FOR,EcLOSURIE File # 941726 Plaintiff is P1 -IH MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD MOUNT LAUREL, NJ 08054 2, The name(s) and last known address(es) of the Defendant(s) are: NATHAN P. BEAHM 19 ANNETTE DRIVE ENOLA, PA 17025-1802 AMANDA D. BEAHM 19 ANNETTE DRIVE ENOLA, PA 17025-1802 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described, 3, On 08/31/2009 NATHAN P. BEAHM and AMANDA D. BEAHM made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR ERA MORTGAGE, which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No, 200931827, By Assignment of Mortgage recorded 04/19/2013 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Instrument No, 201312659. The mortgage and assignment(s), if any, arc matters of public record and are incorporated herein by reference in accordance with Pa,R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record, 4, The premises subject to said mortgage is described as attached. 5, The mortgage is in default because monthly payments of principal and interest upon said mortgage clue 04/01/2013 and each month thereafter are due and unpaid, and by the terms Filc if: 944726 of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6; The following amounts are due on the mortgage as of 03/31/2014; Principal. Balance $155,289,43 Interest $9,656,36 03/01/2013 through 05/01/2014 Late Charges $146.16 Property Inspections $45.00 Escrow Deficit $2,666,56 TOTAL $167,803.51 7, Plaintiff is not seeking a judgment of personal liability (or an in person= judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosu n no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. Hie 11: 9447?6 This action does not corne under Act 91 of 1983 because the mortgage is FHA -insured, WHEREFORE, Plaintiff demands an in um judgment against the Defendant(s) in the sum of $167,803.51, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. By: Miclyarl Dingerdissen fsti,, Id, No, 317124 Attorney for Plaintiff PHELAN HALLINAN, LLP File A; 944726 LEGAL DESCRIPTION ALL TI -IAT CERTAIN land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: TRACT NO. 1 BEGINNING at a point of Intersection of the northern line of Annette Drive and the line of the adjoiner between Lots Nos, 103 and 104 on the hereinafter mentioned Plan of Lots; thence North 22 degrees 09 minutes 50 seconds East by said line of adjoiner, a distance of 135.09 feet to a point at lands now or formerly of Acri; thence South 66 degrees 39 minutes East a distance of 77.27 feet to a point on the northwest corner of Lot No. 102 on said Plan; thence South 23 degrees 21 minutes West along the line of adjoiner between Lots Nos. 102 and 103 on said Plan, a distance of 135 feet to a point on the northern line of Annette Drive; thence North 66 degrees 39 minutes West along said northern line of Annette Drive, a distance of 68,21 feet to a point; thence continuing along the northern line of Annette Drive measured in a northwesterly direction on a curve to theleft, having a radius of 302.77 feet, an are distance of 6.27 feet to a point, the place of BEGINNING. BEING Lot No. 103, Plan 5, Section 'C' of Penn Heights as recorded in Cumberland County Recorder of Deeds Office in Plan Book 21, page 31. TRACT NO, 2 BEGINNING at the point of the Intersection of the northern line of Annette Drive and the line of adjoiner between Lots Nos. 104 and 105 on the hereinafter mentioned Plan of Lots; thence North 08 degrees 55 minutes East by said line of adjoiner, a distance of 137.36 feet to a point at lands now or formerly of Acri; thence North 84 degrees 36 minutes East a distance of 23.97 feet to a point; thence South 66 degrees 39 minutes East, a distance of 79.63 q44726 feet to a point on the northwest corner of Lot No, 103 on said Plan; thence South 22 degrees 09 minutes 50 seconds West along the line of the adjoiner between Lots Nos, 103 and 104 on said Plan a distance of 135,09 feet to a point odthe northern line of Annette Drive; thence continuing along said northern line of Annette Drive, measured in a northwesterly direction on a curve to the left, having a radius of 302,77 feet, an arc distance of 70 feet to the point and place of BEGINNING BEING Lot No, 104, Plan 5, Section 'Cof Penn Heights as recorded in Cumberland County Recorder of Deeds Office in Plan Book 21, page 31, PROPERTY ADDRESS: 19 ANNETTE DRIVE, ENOLA, PA 17025-1802 PARCEL #09-14-0836-011, File II: 941126 VER] ICATION William Bellows Assistant Vice President of PHH hereby states that he/she is MORTGAGE CORPORATION, Plaintiff in this matter, that he/she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 1/.7•00/1" File#: 944726 Name: BEAHM File H: 944726 Name: Title: William 8e110WS Assistant Vice President PHH MORTGAGE CORPORATION Exhibit "B" V • Ronny R Anderson Sheriff Jody 8 Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OPRCI OP Tiff $MER.rf PHH Mortgage Corporation Case Number 20i4-umb ' Nathan P Beahm (et al.) umb 2317 SHERIFF'S RETURN OF SERVICE 04/25/2014 08:31 PM - Deputy t]awn Kell, being duly aWorn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint In Mortgage Foreclosure by handing a true copy to a'perison representing themselves to be Amanda Beahm, wife, who accepted as "Adult Person in Charge" for Nathan P .Beahm at 19 Annette Drive, East Penneboro, Enola, PA 17025. vest_ DAWN KELL, DEPUTY 0425/2014 08:31 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program end Complaint In Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Amanda D Beahm at 19 Annette Drive, East Pennsbaro, Enola, PA 17025. SHERIFF COST: $60.$5 April 28, 2014 �v✓n d. uY4 DAWN KELL, DEPUTY SO ANSWERS, 6n�tr RONNY R ANDERSON, SHERIFF da: a1.1-;!*1ljC"Jf.._. 'c r" ic, "l'1.1 i ti ..'I >; . • 1 •✓_,,. -.^'I 'b'..aa •,l: .•,••i J o ` :.` •'4 i " ' . . ;G • . ', I �r,ij . , LI .1 •i( 1•, tl•' ('• �.� 1 w1�L' ; /l. F. . (o) Cou t/Sul* 8h«M', TY.awll, Inc. ;44 e PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656' 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 Attorney for Plaintiff PHH Mortgage Corporation Court of Common Pleas 2001 Bishops Gate Blvd Mount Laurel, NJ 08054 Civil Division Plaintiff No. 14 -2317 -CIVIL v. Cumberland County Nathan P. Beahm 19 Annette Drive Enola, PA 17025-1802 Amanda D. Beahm 19 Annette Drive Enola, PA 17025-1802 Defendants CERTIFICATION OF SERVICE I, Joseph P. Schalk, Esquire, certify that I caused true and correct copies of Plaintiff's Motion to Lift Conciliation Stay and proposed Order to be sent sent via first class mail to the person listed below on the date indicated: Nathan P. Beahm Amanda D. Beahm 19 Annette Drive Enola, PA 17025-1802 Date: 944726 By: • P. '‘ chalk, squire ey for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PHH Mortgage Corporation Court of Common Pleas 2001 Bishops Gate Blvd Mount Laurel, NJ 08054 Civil Division Plaintiff No. 14 -2317 -CIVIL v. . Cumberland County Nathan P. Beahm 19 Annette Drive Enola, PA 17025-1802. Amanda D. Beahm 19 Annette Drive Enola, PA 17025-1802 Defendants AND NOW, this ORDER Z le' day of Now. , 2014, upon consideration of Plaintiff's Motion to Lift Conciliation Stay in the above captioned matter, it is hereby ORDERED and DECREED that this matter is • removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program; it is further ORDERED and DECREED that the automatic Stay is lifted and Plaintiff may proceed with its Mortgage Foreclosure Action. cc :../Nathan P. Beahm Amanda D. Beahm Joseph P. Schalk, Esquire, Id. No. 91656 Attorney for Plaintiff 944726 r `n(e.s. 114a:/e4, li1//P-42//1/1//P-42//1/ BY T . COURT: PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 Nathan P. Beahm Amanda D. Beahm 19 Annette Drive Enola, PA 17025-1802 944726 PHELAN HALLINAN, LLP PETER WAPNER, Esq., Id. No.318263 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 peter.wapner@phelanhallinan.com 215-563-7000 PHH MORTGAGE CORPORATION vs. NATHAN P. BEAHM AMANDA D. BEAHM Attorney for Plaintiff : CUMBERLAND COUNTY _ COURT OF COMMON PLEASE, c-. rrlrn : CIVIL DIVISION : No. 14-2317 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: 37, cJ1 Kindly enter judgment in favor of the Plaintiff and against NATHAN P. BEAHM and AMANDA D. BEAHM, Defendants for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $167,803.51 TOTAL $167,803.51 I hereby certify that (l) the Defendants' last known address is 19 ANNETTE DRIVE, ENOLA, PA 17025-1802, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. � Date ‘0, PO' v -A PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PH # 944726 PROTHONOTARY 4.110.5a POS of 148'114`1 .315 11025 No -lice mailed 944726 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: NATHAN P. BEAHM A/K/A NATHAN PAUL BEAHM AMANDA D. BEAHM A/K/A AMANDA DANIELLE BEAHM A/K/A AMANDA D. KINSEY A/K/A AMANDA DANIELLE KINSEY Debtors PHH MORTGAGE CORPORATION Movant v. NATHAN P. BEAHM A/K/A NATHAN PAUL BEAHM AMANDA D. BEAHM A/K/A AMANDA DANIELLE BEAHM A/K/A AMANDA D. KINSEY A/K/A AMANDA DANIELLE KINSEY and MARKIAN R SLOBODIAN, ESQUIRE (TRUSTEE) Respondents • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • BK. No. 1:14-02939 RNO Chapter No. 07 11 U.S.C.§362 ORDER GRANTING RELIEF FROM §362 AUTOMATIC STAY WITH RESPECT TO 19 ANNETTE DRIVE, ENOLA, PA 17025-1802. Upon consideration of Motion ofPHH MORTGAGE CORPORATION (Movant), it is: ORDERED AND DECREED: that Movant shall be permitted to communicate with the Debtor(s) and Debtor's counsel to the extent necessary to comply with applicable nonbankruptcy law; and it is further; ORDERED that Relief from the Automatic stay of all proceedings, as provided under 11 U.S.C. §362 is granted with respect to, 19 ANNETTE DRIVE, ENOLA, PA 17025-1802(hereinafter the Premises) (as more fully set forth in the legal description attached to the Mortgage of record granted against the Premises), as to allow Movant, its successors or assignee's, to proceed with its rights under the terms of said Mortgage. By the Court, aalU. 4.4xt" Dated: July 23, 2014 Robert N. Opel, II; Bankntptey Judge MG) Case 1:14-bk-02939-RNO Doc 10 Filed 07/23/14 Entered 07/23/14 14:46:13 Desc Main Document Page 1 of 1 PHELAN HALLINAN, LLP PETER WAPNER, Esq., Id. No.318263 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 peter.wapner@phelanhallinan.com 215-563-7000 PHH MORTGAGE CORPORATION vs. NATHAN P. BEAHM AMANDA D. BEAHM Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 14-2317 AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendants NATHAN P. BEAHM and AMANDA D. BEAHM are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) that defendant NATHAN P. BEAHM is over 18 years of age and resides at 19 ANNETTE DRIVE, ENOLA, PA 17025-1802. (c) that defendant AMANDA D. BEAHM is over 18 years of age and resides at 19 ANNETTE DRIVE, ENOLA, PA 17025-1802. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date Phelan allinan, LLP PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 944726 Department of Defense Manpower Data Center Status Report 7amt to Servicenibcrs Civil Relief Act Last Name: BEAHM First Name: AMANDA Middle Name: D Active Duty Status As Of: Jan -08-2015 Results as of : Jan -00-2015 12:06:11 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA-..._...'_""_- ,v v>`'l I,RA .-r E ",.,f;`:`Nd C S. , C NA No This responsereflects the mtlihuals- active't�utyS1titU5 based on'tlie _Acute Or: uty,Status Date left Active Duty within 367 Days of Active Duty Status Date Active Duty Start Date - Active Duty End Date Status .. Service Component NA ,v v>`'l I,RA .-r E ",.,f;`:`Nd C S. , C NA This response r,heetleft2 ,2 Uiji a - n' - M itA`iv 3[ - reflects !Where ,t4 indNiduai lett actwe dlity�bfatus wltPon367iY�y`s 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 Dale Order Notification Start Date Order Notification End Date Status Service Component NA •.NA ``�� `: of '' NA This response reflects whether the indut)ttual a'rhiiiikgimit has feeetved'eady nohfieation totreport for active duty T,'} Upon searching the data banks of the Department of Defense Manpower Bata CenterVRbased 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 Sera ices (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 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act. Last Name: BEAHM First Name: NATHAN Middle Name: PAUL Active Duty Status As Of: Jan -08-2015 Results as of : Jan -08-2015 02:27:36 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .ier-4, \4. - _' .,,. r^'.---.: '-' l-,"- N %. NA This response reflects the- indiividuats' active duty status based on the Active Duty,Status Date Left Active Duty Within 367 Days of Active Duly Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA This response reflects Where the individual left active duty status within 367 days preceding the Active Duty Status Date \•. .t+' "i% : The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Dale Order Notification End Date Status Service Component NA \. NA-, ,'� • . � '` `Y. dNo ri' .. ,{ NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed. Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: BEAHM First Name: NATHAN Middle Name: P Active Duty Status As Of: Jan -08-2015 Results as of : Jan -08-2015 12:06:10 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status"� Service Component NA NAi"�`f \ r.-. — �"..+�.,+r :,ws ./ No., ', _ NA .r?`rr' s,,,NYrs+.Y-, a' .. . - _-.045:',,, ; ) ..amu: This response reflects the individuals active'dut� k statu's:baned on the Activep;Duty;Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA A.,w"s`No:. ,-,,"1,NK. 3 k I�7 y - °'' (1 k.:,,,ii NA r� r ' r . - i ,., ,,, ,t . ^>.t --tt' yr_, ,.t.i-y* ..r Vs ,0 94 This response reflects where the individual IeR active dutAtatus within 367 days preceding the.'Active Duty Status Date ti The Member or His!Her Unit Was Notified of a Futu e Cali -Up to Active Duty on Active Duty Status Date Order Notification Start Date , Order Notification End Date Status Service Component NA 'S 144--,\‘' y .-.- .._ %. / r ''''''t-�",$OlQ.;;:' NA This response reflects whether the individual or'his/her-unit has received early,notification to report for active duty tam—� Upon searching the data banks of the Department of Defense Manpower Data. Cventer based°on the information that you provided, the above is the status of J j^6 the individual on the active duty status date as to all branches of the Uniformed Services=('A m Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember orhis/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 Department of Defense Manpower Data Center Status Report Fit to Servicemem + civil Relief Act Last Name: BEAHM First Name: AMANDA Middle Name: DANIELLE Active Duty Status As Of: Jan -08-2015 Results as of : Jan -08-2015 02:30:36 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA NA t` ~. .. ' h‘lo'''S,. NA This re ponse reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date This response reflects the indiividua active duty status based o the AcWeDuty Status Dale Left Active Duty Within 367 Dass of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA r:.. ,2 NA�..,'"' .. >r . s ^� 4 .r: --.2"----..."':-N;;` i htA This re ponse reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HisIHer 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 NAv/:; t a frr' ` . rA NA This response reflects whether the individual or hiu/Itar unit has received early notification to report for active duty -. Upon searching the data banks of the Department of Defense Manpower Data Center, basedon.the information that you provided, the above is the status of v ►: 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 Department of Defense Manpower Data Center Status Report Pursuant to Servicemornbers Civil. Relief Act Last Name: KINSEY First Name: AMANDA Middle Name: D. Active Duty Status As Of: Jan -08-2015 Results as of : Jan -0B-2015 02:31:39 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NAt....NA L.'"`":. . 7. —`...n ''k w:..N ',C`.. A NA This response This response refects the individuals` active duty status based o the Active Duty Stalus Dale Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NAt....NA L.'"`":. . 7. —`...n ''k w:..N ',C`.. A NA This response reflects where the individual left active duty s atus wi hin367 days preceding the Adtivio 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 ' 1 �ti ". t :. t'.t f ;41C1/ a .is NA This response reflects whether the individual or his/her unit has receivedi rly notification' toFrepart for active duty ti Upon searching the data banks of the Department of Defense Manpower Data Center, based 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 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: KINSEY First Name: AMANDA Middle Name: DANIELLE Active Duty Status As Of: Jan -08-2015 Results as of : Jan -08-2015 02:33:12 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ♦ t i ' i, I:IN NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA i, ., - NAL - .-' = , t f4�7 ANO 'l •'-' NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date t. The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA V. NA r v' .,. "No r, .'.f NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center„based on th�ormation 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-(Arrny, 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 PHH MORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. NATHAN P. BEAHM AMANDA D. BEAHM NO. 14-2317 Defendant(s) CUMBERLAND COUNTY TO: NATHAN P. BEAHM 19 ANNETTE DRIVE ENOLA, PA 17025-1802 DATE OF NOTICE: crf THIS FIRM IS A DEBT COLLECTOR A 1EMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 DAVE 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 O1,1 -ICE 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PH # 944726 By:.. 'CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PETER WAPNER, Esq., I & No.318263 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 I PHH MORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. NATHAN P. BEAHM NO. 14-2317 AMANDA D. BEAHM Defendant(s) CUMBERLAND COUNTY TO: AMANDA D. BEAHM 19 ANNETTE DRIVE ENOLA, PA 1.7025-1802 DATE OF NOTICE:. 1h4l THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PH # 944726 By: CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PETE WAPNER, Esquire Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (Rule of Civil Procedure No. 236) - Revised PHH MORTGAGE CORPORATION : CUMBERLAND COUNTY vs. NATHAN P. BEAHM AMANDA D. BEAHM : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 14-2317 Notice is given that a Judgment in the above captioned matter has been entered against you on I ' , •a B If you have any questions concerning this matter please contact: Phelan Hallinan, LLP PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** 944726