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Supreme Cout_ fbf ,Pennsylvania Cou rt: offCom molli Tleas For Prothonotary Use Only: Civil Cover, Sheet ' Docket No: CUMSERLAND�' County R i r The information collected on this form is used solely 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: S 2 Complaint 0 Writ of Summons 0 Petition Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Ocwen Loan Servicing, LLC Gerald L. Manhollan, Jr. et. al. T Dollar Amount Requested: El within arbitration limits I Are money damages requested? El Yes El No (check one) Doutside arbitration limits O N Is this a Class Action Suit? E] Yes El No Is this an MDJAppeal? Q Yes Z No A Name of Plaintiff /Appellant's Attorney: M. Troy Freedman Esquire 0 Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant) Nature of t h e 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:noi include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Q Intentional Buyer Plaintiff Administrative Agencies El Malicious Prosecution Debt Collection: Credit Card Board of Assessment E] Motor Vehicle I❑_ Debt Collection: Other 0 Board of Elections Nuisance 0 Dept. of Transportation E] Premises Liability 0 Statutory Appeal: Other S F1 Product Liability (does not include E mass tort) � Employment Dispute: El Slander/Libel/ Defamation Discrimination C El Other: ' M Employment Dispute: Other 0 Zoning Board T, 0 Other: I L] Other: O MASS TORT 0 Asbestos - N F� Tobacco_ 0 Toxic Tort - DES F1 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS F1 Toxic Waste Other: Ejectment El Common Law /Statutory Arbitration B w Eminent Domain /Condemnation Q Declaratory Judgment Ground Rent F❑ Mandamus Landlord /Tenant Dispute 0 Non- Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY — Mortgage Foreclosure: Commercial ❑ Quo Warranto Q Dental ©— Partition 0 Replevin 0 Legal IQ Quiet Title Other: 0 Medical Q Other: Other Professional: Updated 1/1/2011 STEVEN K. EISENBERc,, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) -7 4 LESLIE J. RASE, ESQUIRE (58365) CHRISTINA C. VIOLA, ESQUIRE (308909) ANDREW J. MARLEY, ESQUIRE (312314) U f,' STERN & EISENBERG, PC T 1581 MAIN STREET, SUITE 200 - 'E N' iN S Y BfA N 1 A THE SHOPS AT VALLEY SQUARE WARRINGTON, PA 18976 TELEPHONE: (215) 572-8111 FAcsIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Ocwen Loan Servicing LLC Civil Action Number: � �—J ��p� rv, 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 (Plaintiff) Complaint in Mortgage Foreclosure V. Gerald L. Manhollan, Jr. Administrator of the Estate of Gerald L. Manhollan, Sr. 1315 2nd Street Altoona, PA 16602 (Defendant(s)) CIVIL ACTION - MORTGAGE FORECLOSURE This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE You have been sued in Court. if you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO F IND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITM, V A+ 2 OSJ Qjg INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (800) 990 -9108 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) CHRISTINA C. VIOLA, ESQUIRE (308909) ANDREW J. MARLEY, ESQUIRE (312314) STERN & EISENBERG; PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE WARRINGTON, PA 18976 TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Ocwen Loan Servicing LLC Civil Action Number: 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 (Plaintiff) Complaint in Mortgage Foreclosure V. Gerald L. Manhollan, Jr. Administrator of the Estate of Gerald L. Manhollan, Sr. 1315 2nd Street Altoona, PA 16602 (Defendant(s)) CIVIL ACTION — MORTGAGE FORECLOSURE NOTICE AVISO You have been sued in court. If you wish to defend Le han demandado a usted en la corte. Si usted against the claims set forth in the following pages, quiere defenderse de estas demandas expuestas en las you must take action within twenty (20) days after paginas siguientes, usted tiene veinte (20) dias de this complaint and notice are served by entering a plazo al partir de la fecha de la demanda y la written appearance personally or by attorney and notificacion. Hace falta asentar una comparencia filing in writing with the court your defenses or escrita o en persona o con un abogado y entregar a la objections to the claims set forth against you. You corte en forma escrita sus defensas o sus objeciones a are warned that if you fail to do so the case may las demandas en contra de su persona. Sea avisado proceed without you and a judgment may be entered que si usted no se defiende, la corte tomara medidas against you by the court without further notice for y puede continuar la demanda en contra suya sin any money claimed in the complaint or for any other previo aviso o notificacion. Ademas, la corte puede claim or relief requested by the plaintiff. You may decidir a favor del demandante y requiere que usted lose money or property or other rights important to cumpla con todas las provisions de esta demanda. you. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A Lleva esta demanda a un abogado inmediatamente. LAWYER, OR CANNOT AFFORD ONE, GO TO Si no tiene abogado o si no tiene el dinero suficiente OR TELEPHONE THE OFFICE SET FORTH de pagar tal servicio, vaya en persona o Ilame por BELOW TO FIND OUT WHERE YOU CAN GET telefono a la oficina cuya direccion se encuentra LEGAL HELP. THIS OFFICE CAN PROVIDE escrita abajo para averiguar donde se puede YOU WITH INFORMATION ABOUT HIRING A conseguir asistencia legal. LAWYER. IF YOU CANNOTAFFORD TO HIREA LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATIONABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS ATA REDUCED FEE OR NO FEE. Lawyer Referral and Information Service (Asociacion de Licenciados Servicio de Referencia e Informacion Legal) Cumberland County Bar Association Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (800) 990 -9108 NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT 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. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, this firm will send you the name and address of the original creditor if different from above. IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE ENCLOSED LETTER/NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT A DEBT. IF YOU HAVE RECEIVED A DISCHARGE IN BANKRUPTCY (AFTER ENTERING INTO THE RELEVANT MORTGAGE NOTE AND MORTGAGE (OR OTHER SECURED OBLIGATION) AND HAVE NOT REAFFIRMED THE DEBT) THEN THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT, BUT SOLELY AS PART OF THE ENFORCEMENT OF THE MORTGAGE /LIEN AGAINST REAL PROPERTY (SECURED PROPERTY). STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) CHRISTINA C. VIOLA, ESQUIRE (308909) ANDREW J. MARLEY, ESQUIRE (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE WARRINGTON, PA 18976 TELEPHONE: (215) 572 -8111 FACSIMILE: (215) 572 -5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Ocwen Loan Servicing LLC Civil Action Number: 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 (Plaintiff) Complaint in Mortgage Foreclosure V. Gerald L. Manhollan, Jr. Administrator of the Estate of Gerald L. Manhollan, Sr. 1315 2nd Street Altoona, PA 16602 (Defendant(s)) COMPLAINT CIVIL ACTION — MORTGAGE FORECLOSURE 1. Plaintiff is Ocwen Loan Servicing LLC (hereinafter referred to as " Ocwen Loan Servicing, LLC ") with offices located at 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409. 2. Defendant(s) is Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr., adult individual with a last -known address of 1315 2nd Street, Altoona, PA 16601. 3. On 06/04/1993, Gerald L. Manhollan executed and delivered to PaineWebber Mortgage Finance Inc. a mortgage upon the property located at 35 W Keller St, Mechanicsburg, PA 17055 (the "Property ") to secure the payment of the sum of $73,600.00. The said mortgage was recorded on 06/08/1993 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, at Book 1141, Page 95, and is incorporated herein by reference as though set forth at length herein. A true and accurate copy of said Mortgage is attached hereto, made a part hereof, and marked as Exhibit "A." 4. Assignment from PaineWebber Mortgage Finance Inc. to Ocwen Loan Servicing LLC was prepared and is in the process of being recorded in and for the Office of the Recorder of Deeds, Cumberland County, Pennsylvania. 5. Gerald L. Manhollan departed this life on December 4, 2012. Therefore, the real owners of the Property located at 35 W Keller St, Mechanicsburg, PA 17055 are unknown. 6. In accordance with Pennsylvania law, pre - foreclosure notices (Act 91 /Act 6 as may be applicable) were not required as the mortgagor is deceased. Nevertheless, notices were sent to the Estate of Gerald L. Manhollan, Sr. A copy of the notice is attached hereto as Exhibit `B." 7. The said loan is in default as a result of the failure to pay the monthly installment of $513.17 due on 01 /01 /2013 and each month thereafter. 8. The following is due on the loan to 02/24/2014: PRINCIPAL BALANCE: .................................................................. $48,505.38 INTEREST TO THE DATE OF 02/24/ 2014 ...... ............................... $1,192.89 (CURRENTLY A PER DIEM OF $2.66) ESCROWADVANCES :.................................... ............................... $2,749.24 PRIOR SERVICER AMOUNTS: ...................................................... $45.00 TOTAL :..................................................... ............................... $52,492.51 Attorney fees are allowed in conformity with the mortgage documents and Pennsylvania law, and may be requested as part of any judgment requested and collected in the event of a third party purchaser at Sheriffs Sale. If the mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work actually performed. WHEREFORE, Plaintiff, Ocwen Loan Servicing, LLC requests this Court to enter judgment, IN REM, for foreclosure of the mortgaged property in the sum of $52,492.51 and all other amounts set forth above, less any suspense as set forth above, together with record costs and any other amounts that accrue over the course of the instant matter until judgment is paid in full and to which Plaintiff is entitled to recover. Respectfully S mitted: By: M. TroyFreedman, Esq. Stern & Eisenberg, PC A T 81 Main n Street, Suite 200 he Shops at Valley Square Warrington, PA 18976 Phone: (215) 572 -8111 Facsimile: (215) 572 -5025 Bar Number: 85165 tfreedman@stemeisenberg.com Date: �S Gerald L. Manhollan, Jr. Administrator of the Estate of Gerald L. Manhollan, Sr.;35 W Keller St, Mechanicsburg, PA 17055 XXXXXX8040 VERIFICATION I, Duane Thompson hereby state that I am Contract Management Coordinator of Ocwen Loan Servicing, LLC, Plaintiff in this matter. Ocwen Loan Servicing, LLC maintains and is in control of all documents and records supporting the statements in the foregoing complaint and therefore is the appropriate entity to make this verification. I have reviewed the business records relating to this account and am authorized to make this verification. I hereby verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Name: Duane Thompson Title: Contract Management Coordinator Ocwen Loan Servicing, LLC AFTER RECORDING RETURN TO: PAINEWEBBER MORTGAGE FINANCE,INC. 10440 LITTLE PATUXENT PARKWAY, COLUMBIA, MD 21044 ATTN: DOCUMENT CONTROL )' a a CV r.� r ('� ~ [Space Above This Line For Recording Data] MORTGAGE co C'_ THIS M&TGAGE ( "Security Instrument ") is given on JUNE �/ 4TH 1993 The mortgagor is GERALD L. MANHOLLAN ( "Borrower "). This Security Instrument is given to PAINEWEBBER MORTGAGE FINANCE,INC. which is organized and existing under the laws of STATE OF MARYLAND , and whose address is P.D. BOX 905 COLUMBIA, MARY LAND 21044 -0905 ( "Lender "). Borrower owes Lender the principal sum of I SEVENTY THREE THOUSAND SIX HUNDRED AND 00/100 Dollars (U.S. $- ■- - - 11 IV73 , 600 . 00). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ( "Note "), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on JULY 1ST • , 2023 . This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose „Borrower does hereby mortgage, grant and convey to Lender the following described property located in Mechanicsburg Borough CUM SEE EXHIBIT "A” FOR LEGAL DESCRIPTION B RLAND County, Pennsylvania: (STRIKE OUT IF INAPPLICABLE) BORROWER ACKNOWLEDGES THAT THE SUM SO RECEIVED FROM LENDER UNDER THE NOTE SECURED BY THIS INSTRUMENT IS, IN WHOLE OR IN PART, IN PURCHASE MONEY OF THE PROPERTY SECURED HEREBY. which has 35 WEST KELLER ST. MECHAN ICSBURG [Street, City], Pennsylvania 17055 ( "Property Address "); [Zip Code] Form 3039 9/90 PENNSYLVANIA - Single Family- Fannie Mae /Freddie Mac UNIFORM INSTRUMENT Page 1 01 a Amended 5/91 - 6R(PA) (9105) VMP MORTGAGE FORMS (313)293.9100 - (900)521 -7291 Initials .>Y CDP1 06/03/93 11:25 AM 0 21 `- EXHIBIT Y TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage; grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. `P HIS SECURITY INSTRUMENT combines uniform covenants for national use and non - uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due the principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Note. 2. Funds for Taxes and Insurance. Subject to applicable law or to a written waiver by Lender, Borrower shall pay to Lender on the day monthly payments are due under the Note, until the Note is paid in full, a sum ( "Funds ") for: (a) yearly taxes and assessments which may attain priority over this Security Instrument as a lien on the Property; (b) yearly leasehold payments or ground rents on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums, if any; (e) yearly mortgage insurance premiums, if any; and (f) any sums payable by Borrower to Lender, in accordance with the provisions of paragraph 8, in lieu of the payment of mortgage insurance premiums. These items are called "Escrow Items." Lender may, at any time, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally related mortgage loan may require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act of 1974 as amended from time to time, 12 U.S.C. Section 2601 et seq. ( "RESPA "), unless another law that applies to the Funds sets a lesser amount. If so, Lender may, at any time, collect and hold Funds in an amount not to exceed the lesser amount. Lender may estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with applicable law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrgy{ account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits `Lender to make such a charge. However, Lender may require Borrower to pay a one -time charge for an independent real estate tax reporting service used by Lender in connection with this loan, unless applicable law provides otherwise. Unless an is made or applicable law requires interest to be paid, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender may agree to writing, however, that interest shall he paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds, showing credits and debits to the Funds and the purpose for which each debit to the Funds was made. The Funds are pledged as additional security for all sums secured by this Security Instrument. If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Borrower for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender aVany time is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower in writing, and, in such case Borrower shall pay to Lender the amount necessary to make up the deficiency. Borrower shall make up the deficiency in no more than twelve monthly payments, at Lender's sole discretion. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against the sums secured by this Security Instrument. 3. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs 1 and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third, to interest due; fourth, to principal due; and last, to any late charges due under the Note. 4..Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Property':'which may attain priority over this Security Instrument, and leasehold payments or ground rents, if any. Borrower'"shall pay these obligations in the manner provided in paragraph 2, or if not paid in that manner, Borrower shall pay themon time dimctly to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this`pamgraph. If Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. BOOK 1141 PACE 96 Form 3039 9/90 CvRwo (9105) Page 2 of 6 Initials: t r CDP1 06/03/93 11:25 AM 018 721 S. Hazard or Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property -insured against loss by fire, hazards included within the term "extended coverage" and any other hazards, including floods or flooding, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. The insurance carver providing the insurance shall be chosen by Borrower subject to Lendet's• approval which shall not be unreasonably withheld. If Borrower fails to maintain coverage described above, Lender may, at Lender's option, obtain coverage to protect Lender's rights in the Property in accordance with paragraph 7. All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. In the event of loss, Borrower shall give .prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair of the Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. If Borrower abandons the Property, or does not answer within 30 days a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument, whether or not then due. The 30 -day period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date: of the monthly payments referred to in paragraphs 1 and 2 or change the amount of the payments. If under paragraph 21 the Property is-acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security Instrument immediately prior to the acquisition. 6. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower be in default if any forfeiture action or proceeding, whether civil or criminal, is begun that in Lender's good faitl7'judgment "could result in forfeiture of the Property or otherwise materially impair the lien created by this Security Instrument or Lender's security interest. Borrower may cure such a default and reinstate, as provided in paragraph 18, by causing the action or proceeding to be dismissed with a ruling that, in Lender's good faith determination, precludes forfeiture of the Borrower's interest in the Property or other material impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 7. Protection of Lender's Rights in the Property. If Borrower fails to perform the covenants and agreements contairico.'sn this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property( cuch as a proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may do and pay for whatever is necessary to protect the value of the Property and Lender's rights in the Property. - Lender's etions may include paying any sums secured by a lien which has priority over this Security Instrument, appearing; in court, paying reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may take action under this paragraph 7, Lender does not have to do so. Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting ,payment. 8. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan secured by this Security 13strument, Borrower shall pay the premiums required to maintain the mortgage insurance in effect. If, for any reason, the mortgage insurance coverage requited by Lender lapses or ceases to be in effect, Borrower shall pay the premiums, required to obtain coverage substantially equivalent to the mortgage insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the mortgage insurance previously in effect, from an alternate mortgage insurer approved by Lender. If substantially equivalent mortgage insurance coverage is not available, Borrower' shall pay to Lender each month a sum equal to one - twelfth of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to be in effect. Lender will accept, use and retain these payments as a loss reserve in lieu of mortgage insurance. Loss reserve payments may no longer be . required, BOOK 1 �1 PACE 97 Form 3039 9/900 ® sal�ak ` (9105) Page 3 of 9 Initials: — l/ / CD3p' 06/03/93 11 ;25 AM 0187'I721 at the option of Lender, if mortgage insurance coverage (in the amount and for the period that Lender requires) provided by an insii'rer approved by Lender again becomes available and is obtained. Borrower shall pay the premiums required to maintain mortgage insurance in effect, or to provide a loss reserve, until the requirement for mortgage insurance ends in accordance with any written agreement between Borrower and Lender or applicable law. 9. Inspection. Lender or its agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 10. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair markez value of the Property immediately before the taking is equal to or greater than the amount of the sum�'s6c'ted by this Security Instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Property immediately before the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers to make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is au' to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone tie due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of such payments. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amo- tization of the sums secured by this Security Instrument granted by Lender to any successor in interest of.Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made.by tl�e original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. SSuceessors and Assigns Bound; Joint and Several Liability; Co- signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragra)h 17. Borrower's covenants and agreements shall be joint and several. Any Borrower who co -signs this Security Instrument but does not execute the Note: (a) is co- signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 13. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges, and that lave is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary`to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge under the Note. 14. Notices. An -.I notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first ciGss mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or kiny other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class ,mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for it, this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided iri this paragraph. 17. (', a *verning Law; Severability. This Security Instrument shall be governed by federal law and the law of the jurisdictic", in which ;the Property is located. In the event that any provision or clause of this Security Instrument or the Note confiicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to 1•,e severable. BOOK 1141 PAGE 98 Form 3039 9/90 6R(PA) (9105) Pago 4 of 8 II11t1015' r i CD3P - 06/03/93 11:25 AM 0187 21 16. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 17. Transfer of she Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it is sold ortransferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by th s'Scj. city Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 18. Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earlier of: (a) 5 days (or such other period as applicable law may specify for reinstatement) before sale of the Property pursuant to any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takes such action as Lender may reasonably require to assure that the lien of this Security Instrument, Lender's tights in the Property and Borrower's obligation to pay th,- sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. Howev :r, this right to reinstate shall not apply in the case of acceleration under paragraph 17. 19. Sale of Note; Change of Loan Servicer. The Note or a partial interest in the Note (together with this Security Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known as the "Loan Servicer ") that collects monthly payments due under the Note and this Security Instrument. There also may rbo: one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servi�cr,:3;otrower will be given written notice of the change in accordance with paragraph 14 above and applicable law. The notid' `will state the name and address of the new Loan Servicer and the address to which payments should be made. The notice will also contain any other information required by applicable law. 20. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, not allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or . regulatory authority,: that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower: >hall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides ands herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials: As used in -.this paragraph 20, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON- UNIFORIA COVENANTS. Borrower and Lender further covenant and agree as follows: 21. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of-any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraph 17 unlessapplicable'law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the aifion required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specifiedmay result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non - existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender, at its option, may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 21, Including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by applicable law. 22. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed; shall termynate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. BOOK 1141 PAGE Form 3039 q /90 - 6R(PA) pim) Page 5 018 Initials _�� CD 06/03/93 11:25 AM 0187'r721 r, • 23. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enfot(�e this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 24. Reinstatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument. 25. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 26. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action o% mortgage foreclosure shall be the rate payable from time to time under the Note. 27. Riders to thr,s Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend and supplement the cove : and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)] Fj Adjustable Rate Rider ❑ Condominium Rider 1 -4 Family Rider Graduated Payment Rider ❑ Planned Unit Development Rider Biweekly Payment Rider Balloon Rider ❑ Rate Improvement Rider 0 Second Home Rider V.A. Rider ❑ Other(s) [specify] BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. Witnesses: � / / �• �'�� (Seal) GERALD L. MANHOLLAN - Borrower ,Q (Seal) L - Borrower (Seal) (Seal) - Borrower - Borrower Certifwcate of Residence 1, THERESA A. O' BR I EN , do hereby certify that the correct address of the within -named Mortgagee is P.O. BOX 905 COLUMBIA, MARYLAND 21044 -0905 Witness my hand this 4TH day of JUNE 1993 THERESA A. O' BR I EN Agent of Mortgagee COMMONWEALTH OFPENNSYLVANIA, Cumberland Countyss: On this, the 4th day of June 1993 , before me, the undersigned officer, personally appeared Gerald L. Manhollan known to me (or satisfactorily proven) to be the person' v name i subscribed to the within instrument and acknowledged that he executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. X My Commission Expires: n c A EA? Notary Public [ :CAMP CKIE R tat•! nER, N('TARY rU8LIC Hit L 1 3URO. f.)+t��UERLA)W CO. Title of Officer OMMISSION EXI`41S MARCH 4, 1995 """ vR(PA) (eto5) Page 5 of 6 Form 3039 9/90 CD5P 06/03/93 BOOK��1 PA 100 01871721 File•Number. 9 3 14 6 SCHEDULE - CONTINUED LEGAL_,DESCRIPTION ALL CERTAIN House and Lot of Ground situate on the South side of West Keller Street (First Ward), in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows to wit: BEGINNING at a point on the building line of West Keller Street, at corner of Lot now or formerly of Mr. Greegor; thence Westwardly along said building line, thirty -four (34) feet and six (6) inches to corner of Lot now or formerly of Peter Wetzel and now or formerly of Mr. Slothouer; thence along said Lot Southward, one hundred forty (140) feet, more or less, to a twenty (20) foot alley; thence along said alley Eastward, thirty -four (34) feet, six (6) inches, more or less, to a pin; thence Northward along the above mentioned Lot now or formerly of Mr. Greegor, one hundred forty (140) feet, more or less, to the building line of said West Keller Street, at the point and place of BEGINNING. HAVING. thereon erected a two and one -half story single family frame dwelling, numbered as 35 West Keller Street, Mechanicsburg, Pa. BEING�THE SAME premises conveyed unto Gerald L. Manhollan, Mortgagor herein, by deed from Verna R. Roth, Grantor herein, dated 1993 to be recorded in the Office of the Recorder of eeds ift and for Cumberland County, Pennsylvania. ,,. �,nnsyivanio SS . .. <;�•nb+srlr.nd offine for the recording of Deeds f ,,((��HHm!�riand Coun'VR rwo La-a- 006104 ' o -, Rocordor . ' - * � . l� f ' �r • � T BOOK 1141 PAGE 101 Ocwen Loan Servicing, LLC PO Box 780 3451 Hammond Avenue Waterloo , IA 50704 -0780 DATE OF NOTICE: 06/17/13 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 - 1.869). 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. HOMEOWNER S NAME(S): GERALD MANHOLLAN ESTATE ADDRESS: 35 W KELLER ST MECHANICSBU PA 1 7055 LOAN ACCOUNT NUMBER: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Ocwen Loan Servicing, LLC 7IT ( B 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 designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 33 DAYS. 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 If you meet with one of the consumer credit counseling agencies 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 property 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 . YOU HAVE 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 rime, 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 INFORMATIONAL 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 (Brine it up to date). NATURE OF THE DEFAULT The MORTGAGE debt held by the above lender on your property located at 35 W KELLER ST MECHANICSBU PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Monthly Payments from 01/01/13 through 06/01/13 $ 3079.02 b) Late charges from 01/01/13 through 06/01/13 $ 69.18 c) Other charges: (Escrow, Inspection Fees, other) $ 45.00 d) Other provisions of the mortgage obligation, if any $0.00 e) Less Suspense Balance $- 0.00 f) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $ 3193.20 HOW TO CURE THE DEFAULT You may cure the default within THIRTY -THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 3193.20, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY -THREE (33) DAY PERIOD. Payments must be made either by cashier s check, certified check or money order made payable and sent to: LENDER NAME: Ocwen Loan Servicing, LLC ADDRESS: PO Box 780 3451 Hammond Avenue Waterloo , IA 50704 -0780 IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within THIRTY -THREE (33) 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 -THREE (33) 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. a 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 -THREE (33) DAY period and foreclosure proceedings have begun, You still have the right to cure the default and prevent the sale at any time U to one hour before the Sheriff s Sale. You may do so by paying the total amount then past due plus any late or other charges then due reasonable attorney s fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s 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 Sheriff s Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriff s 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: Ocwen Loan Servicing, LLC Address: PO Box 780 3451 Hammond Avenue Waterloo , IA 50704 -0780 Phone Number: 800- 8504622 Fax Number: 866 - 709 -4744 Contact Person: Collection Department Email Address: Ocwen.mortgagebanksite.com *If you prefer to contact us via email, please access our website at the above address. 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 Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTAGE You may or may not 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. 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. 5039 i.;?a� . S == U S D' pade tTtent cif Housing :T. _ fa�r��n DevefQgmenf t 1 HOWL T* AV- 01 ®1:CiRECL ,0SUM ,u . s .' ;: t . } t i. '' y ' : s i v . l_ r r ". � i f . $ { ` ."i - - t . L '( ), 7 x i 1 t ,J 3 3 r ; t t l } ( 1 1 S 3 Y. l f Z .1 ! S < i U r 1 T� , , - ' 1 i } 'k ., b I t G r 1 -t 1i 1 j t '. % : ;C 1• 2 '. ! t r F / t f ..J W 1 t x t S i r . {' z ,f z o- . - N . 'a T l '' This 000kler explcams hok,,r property .;; ,.: owners can avoldaosmg their homes f. because of de)mqucnt payment t, ' Este folleto explrca a los propletanos h c1e caws Como evitar perde su hogar , ~ z F r " z, debido al incumpbmiento en'!os pagos ,a _ ." _ z ; ' . r I d t '. `F 5C � Pora an en espano) [ t F� ` ti �� L � Ya . �-, II i ' a la enI idod que le dio el prestomo r= ,i � i �! Yr Gz � £ .1 I �'� F'� 9 t�f z x r�� 1��a www hud ov , -=' �- .��F�� i 0 Q VMAT HAPPENS WHSN I mgrs MY MORTGAGE PAYMENTS! Foreclosure may occur. This is the legal means that your lender can use to repossess (take over) your home. When this happens, you must move out of your house. If your property is worth less than the total amount you owe on your mortgage loan, a deficiency judgment could be pursued. If that happens, you not only lose your home, you also would owe HU D an additional amount. Both foreclosures and deficiency judgments could seriously affect your ability to qualify for credit in the future. So you should avoid foreclosure if possible. WHAT SHOULD I DO? 1. DO NOT IGNORE THE LETTERS FROM YOUR LENDER. If you are having problems making your pay- ments, call or write to vour lender's Loss Mitigation Department without delay. Explain your situation. Be prepared to provide them with financial information, such as your monthly income and expenses. Without this information, they may not be able to help. 2. Stay in your home for now. You may not qualify for assistance if you abandon your property. 3. Contact a HUD- approved housing counseling agency. Call 1-806-569-4237 or TlDD 1 -800- 877 -8339 for the housing counseling agency nearest you. agencies are valuable resources. They frequently have information on services and programs offered by Government agencies as well as private and community organizations that could help you. The housing counseling agency may also offer credit counseling. These services are usually free of charge. 06 e WHAT ARE MY ALME TOTES ? You may be considered for the following: Saecial Forbearance. Your lender may be able to arrange a repayment plan based on your financial situation and may even provide for a temporary reduction or suspension of your payments. You may qualify for this if you have recently experienced a reduction in income or an increase in living expenses. You must furnish information to your lender to shorn that you would be able to meet the requirements of the new payment plan. Mor t&IMIAodification. You may be able to refinance the debt and /or intend the term of your mortgage loan. This may help you catch up by reducing the monthly payments to a more affordable level. You may qualify if you have recovered from a financial problem and can afford the new payment amount. Bmial Claim. Your lender may be able to work with you to obtain a one -time payment from the FHA - Insurance Fund to bring your mortgage current. You may qualify if. I. your loan is at least 4 months delinquent but no more than 12 months delinquent; 2. you are able to begin making full mortgage payments. When your lender files a Partial Claim, the U.S. Department of Housing and Urban Development will pay your lender the amount necessary to bring your mortgage current. You must execute a Promissory Note, and a Lien will be placed on your property until the Promissory Note is paid in full- The Promissory Note is interest-free and is due when you pay off the first mortgage or when you sell the property. Pre - foreclosure sale. This will allow you to avoid foreclosure by selling your property for an amount less than the amount necessary to pay off your mortgage loan. - a You may qualify if. 1. the loan is at least 2 months delinquent; 2. you are able to sell your house within 3 to 5 months; and 3. a new appraisal (that your (ender will obtain) shows that the value of your home meets HUD program guidelines. Deed- in- lieuofforeclosure. As a last resort, you may be able to voluntarily "give back" your property to the lender. This wont save your house, but it is not as damaging to your credit rating as a foreclosure. You can qualify if- 1. you are in default and don't qualify or any of the other options; 2. your attempts at selling the house before foreclosure were unsuccessful; and 3. you don't have another FHA. mortgage in default. 0 Q NOW DO I kil*W IF I QUALIFY FOR ANY OF SSE , TE VES? Your lender will determine if you qualify for any of the alternatives. A housing counseling agency can also help you determine which, if any, of these options may meet your needs and also assist you in interacting with your lender. Call 1- 800 -569 -4287 or TDD 1- 800 -877- 8339. SHOULD I BE AWAR9 OF ANYTHING ELSV. Yes. Beware of scams! Solutions that sound too simple or too good to be true usually are. if you're selling your home without professional guidance, beware of buyers { who try to rush you through the process. Unfortunately, there are people who may try to take advantage of your financial difficulty. Be especially alert to the following: f L Egnity skimming. In this type of scam, a "buyer" approaches you, offering to get you out of financial trou- ble by promising to pay off your mortgage or give you a sum of money when the property is sold. The "buyer" may suggest that you move out Quickly and deed the property to him or her. The "buyer" then collects rent for a time, does not make any mortgage payments, and allows the lender to foreclose. Remember, signing over your deed to someone else does not necessarily relieve you of your obligation on your loan. Ph ony counseling agencies. Some groups calling themselves "counseling agencies" may approach you and offer to perform certain services for a fee. These could well be services you could do for yourself for free, such as negoti- ating a new payment plan with your lender, or pursuing a pre - foreclosure sale. If you have any doubt about paying for such services, call a HUD - approved housing counseling agency at 1.800.569 -4287 or T[DtD 1 -800- 877 -8339. Do this before you pay anyone or sign anything. ARE THERE ANY PRECAU'T'IONS I CAN TAKE? Here are several precautions that should help you avoid being "taken" by a scam artist: 1. Don't sign any papers you dorit firlly understand. 2. Make sure you get all "promises" in writing. 3. Beware of any contract of sale or loan assumption where you are not formally released from liability for your mortgage debt. - 4. Check with a lawyer or your mortgage company before Y entering into any deal involving your home. 5. If yodre selling the house yourself to avoid foreclosure, check to see if there are any complaints against the prospective buyer. You can contact your state's Attorney General, the State Real Estate Commission, or the local District Attorney's Consumer Fraud Unit for this type of information. WHAT ARE THE MAIN POINTS I : SHOULD REMEMBER? 1. Don`t lose your home and damage your credit history. 2. Call or write your mortgage lender immediately and be honest about your financial situation. 3. Stay in your home to make sure you qualify for assistance. 4. Arrange an appointment with a HUD - approved housing counselor to explore your options at 1 -80 -80&-569-4287 or TDD 1-800- 877-8339. 5. Cooperate with the counselor or lender trying to help you. 6. Explore every alternative to keep your home. 7. Beware of scams. 8. Do not sign anything you don't understand. 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R - _ ma.., x;' -- e!•r.R'a. iC .i •t _ rte• :3y.:c;_p�: s.r. ,.; . - r,i �- ... -+. � - %^ <>+ :` :•: ._'.7s�_� + =r :,.�` :'tc:; � of _ ��.0 :� ��i!Y, :'' �-a. r.:+ :_S :: i "r J ' .,; r,..- i 'i'c.� y. .b• -/ 4v ___ _ _ _ , : •iMVS y :y -: :' av^ - ; 42: ;y': /�igT :i�'u.S.- ,...i.�',`/„k .' - - _'_ - - yit= iii}`.. -s �.: F.. - rl:' �f...4.: -t w �J,., - - -_ - �'�q :::' :Iry 9 ' <:. .��, : :.. >' >x : :• "IH.. :�'. :.' =:: �l./ S,�• :_; - �\.�;•. �.A - _5 "i T'�,'�, E_.c,. -. :l'' -_''h^ - - v'i• -',f: I;i S `iv , >' mi l ,.. � ? -:••. �, .�r�;.1: , :c 'r :.� -..s �= Jj:?r.._I 04/29/2014 08:50 Stern Eisenberg ffAX)2155725025 P.0021002 FORM I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) G e ra '7aa h *Ilan, JR. Defendant(s) — I ' "Divil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a concillatiou conference, First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 - 9400 extension 2510 or (800) 822 - 5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days o.fthe service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed 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 ROME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully sub itted- �CD s �. rn Date [ e of Counsel f ainti ��' ;7i C � �• C) 3 y '--9 > , 04/29/2014 08:37 Stern Eisenberg TAX)2155725025 P.0031009 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 Please provide the following information to the best of your knowledge: CITSTOMERWR I'M ARY APPLICANT 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): State: Zip: City: Phone Numbers: Home: Office: . Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip:. Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ 04129/2014 08:37 Stern Eisenberg AX)2155725025 P.0041009 If yes, provide names, location of court, case number & attorney: Assets ,Amount Owed Value: I 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, motorcvmlesl: Model: Year: Amount owed: Value Monthly Income Name of Employers: I . 2. 3. Additional Income Description (not wages): 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" Mort a e 'Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel /re airs Other prop. payment Install. .Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 04/2912014 08:37 Stern Eisenberg TAl()2155725025 P.0051009 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 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 lend counsel: V Proof of income IV' Past 2 bank statements �I Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 . 04/2912014 08:37 Stern Eisenberg TAK)2155725025 P.0061009 FORM 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. 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 18 Pa. C. S. §4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date 04/29/2014 08:37 Stern Eisenberg TAX12155725025 P.00710 FORM 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) CIVIL ACTION VS. 140. Defendant(s) CASE MANACrEMENT ORDER AND NOW, this day of , 20 , the defendant/borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court- supervised conciliation Conference on at .M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program' Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the 04129/2014 08:37 Stern Eisenberg TAX)2155725025 P.0081 I � Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated, 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; 04/2912014 .08:37 Stern Eisenberg TAX )2155725025 P.0091009 entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy. proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, 7. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY MIC THE PROTHONOTARY 2014 AUG -8 AM Q2 CUMBERLAND COUNTY PENNSYLVANIA OF ME QFTHE .*$HF,R,IFF Ocwen Loan Servicing, LLC vs. Gerald L Manhollan, Jr Case Number 2014-2608 SHERIFF'S RETURN OF SERVICE 04/29/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Gerald L Manhollan, Jr, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Berks, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 04/29/2014 07:45 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Gerald L Manhollan, Jr, 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 35 W. Keller Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Deputies were advised by a neighbor that the defendant passed away 1 1/2 years ago and that the residence is vacant. 08/05/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within.named Defendant'to wit: Gerald L Manhollan, Jr, 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 1315 2nd Street, Altoona, PA 16602. SHERIFF COST: $63.30 SO ANSWERS, August 05, 2014 RONR ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. i DATE RECEIVED SHERIFF'S DEPARTMENT BLAIR COUNTY, PENNSYLVANIA COURTHOUSE, HOLLIDAYSBURG, PA. 16648 DATE PROCESSED SHERIFF SERVICE INSTRUCTIONS: Print legibly, insuring readability of all copies. PROCESS RECEIPT, and AFFIDAVIT OF RETURN Do not detach any copies. BCSD ENV. # 1. PLAINTIFF / S OCWEN LOAN SERVICING LLC 2. COURT NUMBER 2608-14/60129T-2014 3. DEFENDANTS / S SERVE AT 4. TYPE OF WRIT OR COMPLAINT GERALD L MANHOLLAN JR ET AL COMPLAINT MORTGAGE FORECLOSURE 5. NAME OF INDMDUAL, COMPANY, CORPORATION, ETC. TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. GERALD L MANHOLLAN JR ADMINISTSRATOR OF THE ESTATE OF 6. ADDRESS (Street or RFD. Apartment No., Oty, Boro, Twp., State and ZIP Code) 1315 SECOND STREET ALTOONA, PA 16602 7. INDICATE UNUSUAL SERVICE: L r .i PERSONAL El PERSON IN CHARGE Q DEPU 11lJ: El CERT. MAIL n REGISTERED MAIL Q POSTED OTHER NOW, I, SHERIFF OF BLAIR, COUNTY, PA., do hereby deputize the Sherri of County to execute thls Writ and make return thereof according to law. This deputation being made at the request and risk of the plaintiff, SHERIFF OF BLAIR COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION N 8 WAIVER OF WATCHMAN — Any tleputy sheriff levying upon or ettaching any property under within writ may leave same without a watchman In custody of whomever Is found In possession, after notifying person of levy or attachment, without Ilabllhy on the part of such deputy or me sheriff of any plaintlff herein for any loss, desauafon or removal of any such property before sheriffs sale thereof. 9, SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: DEPUTIZED BT CUMBERLAND CO SHERIFF P°INTIFF DEFENDANT 0. TELEPHONE NUMBER 11. DATE SPACE BELOW FOR USE OF SHERIFF ONLY — DO NOT WRITE BELOW THIS LINE I acknowledge receipt of the wri! 12. or complaint ad indicated above. SIGNATURE of Authorized BCSD Deputy or Cerk and Title 13. Date Received 05/01/2014 14. Expiration/Hearing Date 05/29/2014 I hereby CERTIFY and RE'I1JRN that I _ have personally served. _ have served person in charge. _ have legal evidence of service as shown in "Remark? (on reverse). — have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at 15. the address shown above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COPY thereof. 16. 17. hereby. Certify and return a NOT FOUND• b me and title of individual served use I am unable to Ioc to the indlviduel, company, corporation etc., named above. (See remarks below) 18. A person of suitable age and discretion then residing in the defendant's usual place of abode. Read Order Address 0 19. State and 23. ere served (complete only If different than shown above) (street or RFD, Apartment No., City, Boro, Twp., Code) ev-t ST6-E5 0E7 15 IN v t 74Yre S o ti.1 AFFIRMED and subscribed to before me this day of MY COMMISSION EXa1RFS NOTARY PUBLIC 50 ANSWER By (She /Deq. St riff) Please Print gr,Type) ate L1 S SHERIFF OF BLAIR COUNTY 1 ACIWOWLEDGE RECEIPT OF THE SHERIFFS RETURN SIGNATURE OF AUTHORIZED ISSUING AU T1ORTTY AND TITLE. Date Received Sti6E '°N wdtiZ:Z1 tiLQ .� .qfV STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) CHRISTINA C. VIOLA, ESQUIRE (308909) ANDREW J. MARLEY, ESQUIRE (312314) STERN & EISENBERG, PC THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) t .HE PROTHONU 1Ai=;`; 7014 AUG 22 N1/411-0. 51 U PE NN5 LVAN COUNTY TY IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 v. Gerald L. Manhollan, Jr. Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) 8/12/14 Civil Action Number: 14-2608 Civil Term PRAECIPE TO REINSTATE CIVIL ACTION Kindly reinstate the civil action in the above captioned matter. STERN & EISENBERG, PC BY: EDWARD J MCKEE, SQ. Attorney for Plaintiff J:\JIM\REINSTATEMENTS\CUMBERLAND\ OCWEN.MUHOLLAND.08.142.DOC Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF Sr °�,_ ci'” � � '�r �' � Ocwen Loan Servicing, LLC vs. Gerald L N1anho||an, Jr Case Number 2014-2608 'SHERIFF'S RETURNOF SERVICE 0025/2014 Sheriff RonR Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendanto wit: Gerald L Manhollan, Jr, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 89/18/2014 The requested Notice of Residential Md a Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of.Dauphin County, the within named Defendant Gerald L Manhollan, Jr. not found. Jack Lohmiok, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, September 18, 2014 R NNYRANDERSON, SHERIFF (c) CountySuite Sheriff, Teleesert, Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy OCWEN LOAN SERVICING LLC VS GERALD L. MANHOLLAN, JR Sheriffs Return No. 2014-T-2385 OTHER COUNTY NO. 2014-2608 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for GERALD L. MANHOLLAN, JR the DEFENDANT named in the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, SEPTEMBER 11, 2014. PER PHONE CALL FROM RESIDENT OF ADDRESS 2935 WAYNE STREET, HARRISBURG, PA 17111, THE DEFENDANT DOES NOT RESIDE THERE. Sworn and subscribed to before me this 16TH day of September, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffinan, Notary Public City of Harrisburg, Dauphin County My Commission Expires .lanuary 8, 2018 So Answers, Sheriff of Dauphin County, Pa. ByK9DA2—lt*e-- - Deputy Sh r ff Deputy: MEGAN TRITT Sheriffs Costs: $47.25 8/26/2014 STEVEN K.EISENBERG,ESQUIRE(75736) i HE !- M.TROY FREEDMAN,ESQUIRE(85165) OCT -2 ANDREW J.MARLEY,ESQUIRE(312314) F* EDWARD J.MCKEE,ESQUIRE(316721) WILLIAM E. GALLAGHER,ESQUIRE(308951) STERN&EISENBERG,PC 1581 MAIN STREET, SUITE 200 WARRINGTON,PENNSYLVANIA 18976 TELEPHONE: (215)572-8111 FACSIMILE: (215)572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 (Plaintiff) Civil Action Number: 2014-2608 v. Gerald L. Manhollan, Jr.Administrator of the Estate of Gerald L. Manhollans, Sr. 1315 2nd Street Altoona, PA 16602 (Defendant(s)) PRAECIPE TO REINSTATE CIVIL ACTION Kindly reinstate the civil action in the above captioned matter. STERNA: SENBERG, PC BY.I WARD J. MCKEE, ESQ. Attorney for Plaintiff 9/29/14 3JtA: 7�pa et# kryG JAANGELA\REINSTATEMENTS\CUMBERLAND\MANHOLLAN.9.14.DOC Z-1, 311 -) (42 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F iLED—C t t Cr-11lhP3nr, OF THE P RO T HONP AR E OF THE SHERIFF 2614 OCT 21 PM ;21 59 CUMBERLAND COUNTY PENNSYLVANIA Ocwen Loan Servicing, LLC vs. Case Number Gerald L Manhollan, Jr 2014-2608 I SHERIFF'S RETURN OF SERVICE 10/13/2014 07:08 PM - Deputy Shawn Harrison, being duly sworn according to law, served the r in Mortgage Foreclosure by "personally" handing a true copy to a perso : • -sen .. the Defendant, to wit: Gerald L Manhollan, Jr at 201 Valley Road, East ' e •;. ro . ested Complaint themselvesto be a, PA 17025. SH N HARtIS• TY SHERIFF COST: $44.95 SO ANSWERS, October 15, 2014 RONZ ANDERSON, SHERIFF (c) ChuntySuite Sheriff, Teleasoft, Inc. STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC v. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action Number: 2014-2608 Civil MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant(s), Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr., for failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty (20) days of service thereof. PRINCIPAL BALANCE $48,505.38 INTEREST accrued thru 02/24/2014 of $1,192.89 Interest after 02/24/2014 shall accrue at the per diem rate of $2.66.) ESCROW ADVANCES $2,749.24 PRIOR SERVICER AMOUNTS $45.00 EL -ti- /31/42 12-4\ ; /I,G Sub -Total Through Date of Complaint $52,492.51 ri J ACCRUED INTEREST after 02/24/2014 shall accrue at the per diem rate of $2.66 to November 17, 2014 $707.56 TOTAL DUE THROUGH DATE OF REQUEST FOR JUDGMENT BY: $53,200.07 STERN - EN :-E ► • El T ;VEN K. EISBERG, ESQUIRE ❑ M. TROY FRE Fr AN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE VSLIE J. RASE, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314.) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC v. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action: 2014-2608 Civil MORTGAGE FORECLOSURE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF BUCKS I, the undersigned, being duly sworn according to law, deposes and says, to the best of his knowledge, information and belief, Defendants': 1. Last -known address is 201 Valley Road Enola, PA 17025 2. Is over the age of twenty-one. 3. Is not now nor has been within the last six (6) months in the Armed Services of the United States as defined in the SoldiersCivil Relief Act of 1940, as amended. PIP4 NOTARIAL SEAL ANGELA HARRIGAN, Notary Public Wernngton Two. Bucks county My Commission Expires November 26, 2016 %%VANUA Sworn to and subscribed before me this 17th Day of November, 2014. No ublic BY: STERN & EISENBERG, PC o STEVEN K. EIS NBERG, ESQUIRE o M. TROY FREEDMAN, ESQUIRE o JACQUELINE F. McNALLY, ESQUIRE 0,1,ESLIE J. RASE, ESQUIRE 0g ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant to Servicementhers Civil. Relief Act Last Name: MANHOLLAN First Name: GERALD Middle Name: Active Duty Status As Of: Nov -17-2014 Results as of : Nov -17-2014 08:23:22 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 - No NA s 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 NA _ _. ; `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 • No 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 Etierr— StEVEN K..EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85i 65) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC v. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action: 2014-2608 Civil MORTGAGE FORECLOSURE CERTIFICATION UNDER RULE 237.1 I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten-day notice of intention to enter judgment by default was sent to Defendants in accordance with Pa. R.C.P. No. 237.1., a true and correct copy of which is attached hereto. BY: STERN & EISENBE' _ PC EVEN K. fer NBERG, ESQUIRE ❑ M. TROY F'4 EDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE LIE J. RASE, ESQUIRE 'ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 THE SHOPS AT VALLEY SQUARE, WARRINGTON, PA 18976 TEL-EPH ONE: (215)572-8111 FACSIMILE: (215) 572-5025 (COUNSELFOR PLAINTIFF) UN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Omen Loan Servicing, LIC (Plaintiff) Gerald L. Manhollan, Jr. Administrator of the Estate of Gerald L. Manhollans, Sr. (Defendant(s)) Docket #: 2014-2608 Civil TEN DAY NOTICE NOTICE PURSUANT TO Pa.R,C.P, 237.1 TO: Gerald L. Manhollan, Jr. Administrator of the Estate of Gerald L. Manhollans, Sr. 201 Valley Road Enola, PA 17025 Date of Notice: November 3, 2014 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 (10) 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: 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 ATA REDUCED FEE OR NO FEE. Cumberland County Bar Association Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 I By: I. Edward J. McKee, Esq. STERN & EISENBERG, PC rCj Attorney for Plaintiff STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. 'MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC V. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action: 2014-2608 Civil MORTGAGE FORECLOSURE CERTIFICATE UNDER ACT 91 OF 1983 It is hereby certified that the Sheriffs Sale scheduled in the above -captioned matter is not protected under the Homeowner's Emergency Assistance and Mortgage Foreclosure Act, P.L. 1688, No. 621 because notice, as required, was sent to Defendants and no timely response was made. BY: STERN & EISENBERG, PC O 'STEVEN K. E : RG, ESQUIRE O M. TROY F DMAN, ESQUIRE O JACQUELINE F. McNALLY, ESQUIRE O SLIE J. RASE, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff S'T'EVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC v. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action: 2014-2608 Civil MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 (Plaintiff) Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. 201 Valley Road Enola, PA 17025 (Defendant(s)) BY: STERN & EISENBER PC STEVEN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE ❑ J.,ESLIE J. RASE, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff • S'T'EVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111. FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC v. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action: 2014-2608 Civil MORTGAGE FORECLOSURE CERTIFICATION OF ADDRESS It is hereby certified that the last known addresses of the parties are as follows: Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 (Plaintiff) Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. 201 Valley Road Enola, PA 17025 (Defendant(s)) BY: STERN & EISENBERG. PC STEVEN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE O JACQUELINE F. McNALLY, ESQUIRE ❑ .,ESLIE J. RASE, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Ocwen Loan Servicing, LLC VS. 0 Confessed Judgment Plaintiff ❑ Other File No. 2014-2608 Civil Gerald L. Manhollan, Jr., Administrator Address: 201 Valley Road Enola, PA 17025 Amount Due $53,200.07 Defendant Interest Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966.as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) 35 West Keller Street, Mechanicsburg, PA 17055 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee (s) as a lis pendens aga. defendant(s) described in the attached exhibit. Date 11 /17/2014 Signature: aINA s aSt) ri atillV ctc 1 -1s \t. ')S WI. so cO Pc1,1-0 IS(P(0 Print Name: Address: Attorney for: Telephone: Supreme Court ID No: 312314 1581 Main Street, Suite 200 Warrington, PA 18976 Plaintiff 215-572-8111 Lt4 IL/T ALL THAT CERTAIN house and lot of ground situate on the South side of West Keller Street (First Ward), in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, tow it: BEGINNING at a point on the building line of West Keller Street, at a corner of Lot now or formerly of Mr. Greegor; thence Westwardly along said building line, thirty-four (34) feet an six (6) inches to comer of Lot now or formerly of Peter Wetzel and now or formerly of Mr. Slothouer; thence along said Lot Southward, one hundred forty (140) feet, more or less, to a twenty (20) foot alley; thence along said alley Eastward, thirty-four (34) feet, six (6) inches, more or less, to a pin; thence Northward along the above mentioned Lot now or formerly of Mr. Greegor, one hundred forty (140) feet, more or less, to the building line of said West Keller Street, at the point and place of beginning. HAVING erected thereon a two and one-half story single family frame dwelling. BEING KNOWN AS 35 West Keller Street, Mechanicsburg, PA 17055 BEING the same premises which Eloy M. Mazo, single man, and Justin R. Keppy and Nicole Crum-Mazo, now by marriage Nicole Keppy, husband and wife, by Deed dated January 22, 2003 and recorded February 11, 2003 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 255 Page 3701, granted and conveyed unto Robert A. Patrick and Tammy L. Patrick, husband and wife. PARCEL NO. 16-24-0787-018 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC v. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action: 2014-2608 Civil MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 35 West Keller Street, Mechanicsburg, PA 17055. 1. Name and address of Owner(s) or Reputed Owner(s): Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. 201 Valley Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. 201 Valley Road Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Hershey Medical Center Bureau of Account Management 3607 Rosemont Avenue — Suite 502 Camp Hill, PA 17011 Milton S. Hershey Medical -Center- 500 University Drive Hershey, PA 17033 4. Name and address of the last recorded holder of every mortgage of record: N/A 5. Name and address of every other person who has any record lien on the property: 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: PA Department of Revenue Bureau of Compliance Box 281230 Harrisburg, Pennsylvania 17128 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: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Tenant(s)/Occupant(s) 35 West Keller Street Mechanicsburg, PA 17055 Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false. statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: November 17, 2014.STERN & EISENBERG BY: COMMONWEALTH Of P�EP4NSVLVANIA NOTARIAL SEAL ANGELA HARRIGAN, Notary Public Warrington Twp. Bucks Cnunty My Commission Expires November 26, 2016 Sworn to and subscribed before me This 17th Day of November, 2014. ublic ❑ STEVEN K. EIS B G, ESQUIRE ❑ M. TROY FRE . I ► ' • N, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE 0 )SLIE J.RASE; ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff 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 attomey.) 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 Stem & Eisenberg PC, telephone (215) 572-8111. 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 Stern & Eisenberg PC, telephone (215) 572-8111. 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 a 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 on a date specified by the Sheriff no later than 30 days after the sale date. 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 the date of filing of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine the actual date of filing of said schedule. 7. You may also have other rights and defenses, or ways of getting your house 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, Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC v. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action: 2014-2608 Civil MORTGAGE FORECLOSURE RE: PREMISES: 35 West Keller Street, Mechanicsburg, PA 17055 Dear Sir or Madam: Please be advised that I represent the above creditor that has a judgment against the above Defendant. As a result of a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of Cumberland County on Wednesday, March 4, 2015 at 10:00 A.M. at Sheriffs Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice). The sale is being conducted pursuant to the judgment in the amount of $53,200.07 together with interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriff' s Sale upon your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice. A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days thereafter. November 17, 2014 STERN & EISENBE , P BY: O E EN K. EIS ERG, ESQUIRE o M. TROY FREEDMAN, ESQUIRE 1:1 JACQUELINE F. McNALLY, ESQUIRE o ;ESLIE J. RASE, ESQUIRE ANDREW J. MARLEY, ESQUIRE Attorney for Plaintiff ALL THAT CERTAIN house and lot of ground situate on the South side of West Keller Street (First Ward), in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, bounded and described as follows, tow it: BEGINNING at a point on the building line of West Keller Street, at a corner of Lot now or formerly of Mr. Greegor; thence Westwardly along said building line, thirty-four (34) feet an six (6) inches to corner of Lot now or formerly of Peter Wetzel and now or formerly of Mr. Slothouer; thence along said Lot Southward, one hundred forty (140) feet, more or less, to a twenty (20) foot alley; thence along said alley Eastward, thirty-four (34) feet, six (6) inches, more or less, to a pin; thence Northward along the above mentioned Lot now or formerly of Mr. Greegor, one hundred forty (140) feet, more or less, to the building line of said West Keller Street, at the point and place of beginning. HAVING erected thereon a two and one-half story single family frame dwelling. BEING KNOWN AS 35 West Keller Street, Mechanicsburg, PA 17055 BEING the same premises which Eloy M. Mazo, single man, and Justin R. Keppy and Nicole Crum-Mazo, now by marriage Nicole Keppy, husband and wife, by Deed dated January 22, 2003 and recorded February 11, 2003 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 255 Page 3701, granted and conveyed unto Robert A. Patrick and Tammy L. Patrick, husband and wife. PARCEL NO. 16-24-0787-018 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 OCWEN LOAN SERVICING, LLC Vs. NO 14-2608 Civil Term CIVIL ACTION — LAW GERALD L. MANHOLLAN, JR, ADMINISTRATOR OF THE ESTATE OF GERALD L. MANHOLLAN, SR. WRIT OF EXECUTION 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: $53,200.07 Interest Atty's Comm: Atty Paid: $317.50 Plaintiff,Paid: Date: 11/20/14, (Seal) REQUESTING 'PARTY: Name: ANDREW J. MARLEY, ESQUIRE. Address: STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PA 18976 Attorney for: PLAINTIFF Telephone: 215-572-8111 Supreme Court ID No. 312314 L.L.: $.50 Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary Deputy STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) EDwARD J. MCKEE (316721) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC v. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action Number: 2014-2608 Civil MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, EDWARD J. MCKEE, ESQ., attorney for the within Plaintiff, hereby certify that notice of the Sheriff's Sale was mailed to the Defendants by certified mail return receipt requested and regular mail on January 8, 2015. I further certify that notice of the Sheriff's Sale was mailed to each lienholder by regular, first-class, postage prepaid mail on January 8, 2015, as evidenced by copy of certificates of mailing attached. 1/13/15 STERN & EISENBERG, PC BY: EDWARD J. MCKEE Attorney for Plaintiff name anu Address of Sender .7I ratPi o G1JIL.1\Dri(V 1581 Main Street, Suite 200 Warrington, PA 18976 Line Postage Fee 1 Gerald L. Manhollan Jr., Administrator of the Estate of Gerald L. Manhollan Sr., 201 Valley Road, Enola, PA 17025 2 Hershey Medical Center, Bureau of Account Management, 3607 Rosemont Ave. Ste. 502, Camp Hill, PA 17011 3 Milton S. Hershey Medical Center, 500 University Dr., Hershey, PA 17033 4 Mellon Bank N.A., 10 South Market St., Harrisburg, PA 17101 5 Citizens Bank of PA, 1735 Market St., Harrisburg, PA 17101 6 Borough of Mechanicsburg, 35 West Keller Street, Mechanicsburg, PA 17055-6338 7 PA Dept. of Revenue, Bureau of Compliance, Box 281230, Harrisburg, PA 17128 8 Domestic Relations—Cumberland County, 13 North Hanover St., Carlisle, PA 17013 9 Tax Claim Bureau, Cumberland County Courthouse, One Courthouse St., Carlisle, PA 17013 10 Tenant(s)/Occupant(s), 35 West Keller St., Mechanicsburg, PA 17055 11 p m cr. N r- q] c:3 p O CI (1J N U.S. Postal Service,. CERTIFIED MAILTM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) 12 tgit_ r I' .Y ~�+ #.. o�n'-1/ o _ w oo v -, J O 0) ` >O O 2 0 0 . Q i till' 13 ti • ' A For delivery information visit our website at www.usps.como `` 14 . Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Pos ag & F es Cie is �. • $ Postmark Here 15 ` 16 Q t 1 f1> e111 —1 D 17 G7 11 -t Imo 18 Z < h in 1r• ACirnin. Sec - E Si-. o f eier__ i s L. Mane St eet, Apt. No.; /t �r or PO Box No. 1201 Vaum d . C'I State, ZIP+ v 111114 — 111 PS Form 3800, August 2008 See Reverse for Instructions STEVEN K. EISENBERG, ESQUIRE (75736) M. TROY FREEDMAN, ESQUIRE (85165) LESLIE J. RASE, ESQUIRE (58365) ANDREW J. MARLEY (312314) STERN & EISENBERG, PC 1581 MAIN STREET, SUITE 200 WARRINGTON, PENNSYLVANIA 18976 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY Ocwen Loan Servicing, LLC v. Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. Defendant(s) Civil Action: 2014-2608 Civil MORTGAGE FORECLOSURE AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 35 West Keller Street, Mechanicsburg, PA 17055. 1. Name and address of Owner(s) or Reputed Owner(s): Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. 201 Valley Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Gerald L. Manhollan, Jr., Administrator of the Estate of Gerald L. Manhollan, Sr. 201 Valley Road Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Hershey Medical Center Bureau of Account Management 3607 Rosemont Avenue — Suite 502 Camp Hill, PA 17011 Milton S. Hershey Medical Center 500 University Drive Hershey, PA 17033 A 4. Name and address of the last recorded holder of every mortgage of record: Mellon Bank, N.A. 10 South Market Square Harrisburg, PA 17101 Citizens Bank of Pennsylvania 1735 Market Street Harrisburg, PA 17101 5. Name and address of every other person who has any record lien on the property: Borough of Mechanicsburg 35 West Keller Street Mechanicsburg, PA 17055-6338 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: PA Department of Revenue Bureau of Compliance Box 281230 Harrisburg, Pennsylvania 17128 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: Domestic Relations Cumberland County 13 North Hanover Street Carlisle, PA 17013 Tenant(s)/Occupant(s) 35 West Keller Street Mechanicsburg, PA 17055 Tax Claim Bureau Cumberland County Courthouse One Courthouse Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: January 7, 2015 COMM NGTARiAL SEAL, HELEN CAPASSO, Notary Public Warrington Twp•, 5ucics County My Commission Expires October 21, 2016 ,of, rrtNINSYL.irAIA BY: Sworn to and subscribed before me This 7th Day of January, 2015. 4( 4.440 Notary Public STERN & F,ISENBERG, PC ❑ STEVEN K. EISENBERG, ESQUIRE ❑ M. TROY FREEDMAN, ESQUIRE ❑ JACQUELINE F. McNALLY, ESQUIRE `0 EDWARD J. MCKEE, ESQUIRE Attorney for Plaintiff