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HomeMy WebLinkAbout14-2836 Supreme. Court-of Pennsylvania - man Pleas C'our(cif Co>cn S eet For Prothonotary Use Onlir Curberlana ;, Coa�nt�� Do�et Nu: The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: R Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: LAKEVIEW LOAN SERVICING,LLC SHERRY A.MARTIN C MICHAEL S.MARTIN T I Dollar Amount Requested within arbitration limits 0 Are money Damages requested?: ❑ Yes No (Check one) X outside arbitration limits NN Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A Name of Plaintiff/appellant's Attorney: KML Law Group,P.C. ❑ Check here if you are a Self-Represented(Pro Se Litigant Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection:Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation s ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include ❑ Employment dispute: ❑ Statutory Appeal: Other I mass tort) Discrimination C ❑ Slander/Libel Defamation ❑ Other ❑ Employment Dispute:Other T ❑ Other: I 0 MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑ Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus NMortgage Foreclosure:Residential ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000-BNY MELLON INDEPENDENCE CENTER ,' 701 MARKET STREET /�fd oliju v,, PHILADELPHIA,PA 19106 f - (866)413-2311 (li' . . 117 /0. 1 1, - tLJ �, '�d. LAKEVIEW LOAN SERVICING,LLC IN J'(610P 4MON PLEAS 4425 Ponce De Leon Blvd. Mailstop MS5/251 OF Cumberlani COUNTY Coral Gables,FL 33146 Plaintiff CIVIL ACTION-LAW vs. SHERRY A.MARTIN ACTION OF MORTGAGE FORECLOSURE MICHAEL S.MARTIN 2 Mortgagor(s)and Record Owner(s) No. 1288 High Street Boiling Springs,PA 17007 VIL ACTION:MORTGAGI Defendant(s) FORECL SM NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAMEa�b3. POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. n # . 12*305446 SI USTED NO PUEDE PAGARLE A UN ABOGADO,ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website httl2://-vvww.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http•//www_philadelphiafed.oriz/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at.homeretentiongkmllawgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.Please reference our Attorney File Number of 129057FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop.it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is LAKEVIEW LOAN SERVICING,LLC,4425 Ponce De Leon Blvd., Mailstop MS5/251 Coral Gables,FL 33146. 2. The name(s) and address(es) of the Defendant(s) is/are SHERRY A. MARTIN, 1288 High Street, Boiling Springs,PA 17007 and MICHAEL S. MARTIN, 1288 High Street,Boiling Springs,PA 17007, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On August 17, 2011 mortgagor(s)made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,ACTING SOLELY AS NOMINEE FOR FIRST FINANCIAL SERVICES,INC.,which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on August 30, 2011 as Instrument 4201124113. The mortgage has been assigned to: LAKEVIEW LOAN SERVICING,LLC by assignment of Mortgage recorded on October 11, 2013 as Instrument 4201333542. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments are due and unpaid for June 01, 2013 and each month thereafter and by the terms of the Mortgage,upon default in such payments for a period of one month or more,the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: PrincipalBalance....................................................................................$82,753.58 Interest from 05/01/2013 through 02/26/2014 at 4.7500°/x..................... $3,217.36 Per Diem interest rate at$10.77 LateCharges ...............................................................................................$221.60 Escrow.......................................................................................................$2,634.46 PropertyInspections........................:..............................................................$28.00 NSFCharges..................................................................................................$20.00 Reasonable Attorney's Fee.......................................................................$1,650.00 $90,525.00 7. If the Mortgage is reinstated prior to a Sheriff s Sale,the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results.in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit,process serving and skip tracing,title searches,recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an"in personam"judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding,this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy,but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit`B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff,the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$90,525.00, together with interest at the rate of$10.77,per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: KML LAW GRO , P. . Michael M K ever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff f VERIFICATION I, Jeremy Kirsh as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 ya. C.S. ec. 4904 relating to unsworn falsification to authorities. Date: / remy irsh/Vice President #129057FC-SHERRY A.MARTIN and MICHAEL S.MARTIN 1288 High Street Boiling Springs,PA 17007 hibit A LEGAL DESCRIPTION SCHEDULE "A" TRACT NO. 1: ALL THAT CERTAIN lot of ground situate in the Village of Churchtown,Township of Monroe and County of Cumberland,Pennsylvania,bounded and described as follows: FRONTING South on High Street;on the West on lot now or formerly of William Diller's heirs; on the North on an alley;and on the East on lot now or formerly of Harvey Rinehart(formerly Lot No. 1 in Plan of Lots). CONTAINING 33 feet in front and 159 feet,more or less,in depth and having thereon erected a two-story from dwelling house and outbuildings,with mailing address of 1288 High Street,Boiling Springs,Pennsylvania 17007. TRACT NO. 2: ALL that certain lot of ground situate in the Village of Churchtown,Township of Monroe and County of Cumberland,Pennsylvania,bounded and described as follows: BEGINNING at the southeastern comer of Tract No. 1 herein,thence by High Street, East 33 feet to lands now or formerly of Paul D.Krissel,et al.thence by said lands now or formerly of Paul D.Krissel,et al.,North 159 feet to an alley fence;thence West along said alley 33 feet to Tract No. 1 herein;thence South along the same 159 feet;more or less,to the place of BEGINNING. CONTAINING.33 feet in front along the northern line of High Street and extending northwestwardly therefrom at an even width 159 feet more or less to an alley. Parcel Number:22-28-2401-059 and 22-28-2401-060. Eichibit (-B *Exhibit has been redacted to remove allpersonally identifiable information or non-public information REPRESENT NT 7107 8381 6542 1783 2146 M M&TBank P.O.Box 840 Williamsville, NY 14221 3-750-70936-0000053-001-01-000-000-000-000 MICHAEL S MARTIN 1288 HIGH ST BOILING SPRINGS PA 17007 INTERNET REPRINT REPRESENT J NT 7107 8381 6542 1783 2153 11 M&TBank P.O.Box 840 Williamsville, NY 14221 9-750-70936-0000054-001-01-000-000-000-000 SHERRI A MARTIN 1288 HIGH ST BOILING SPRINGS PA 17007 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 3-750-70936-0000053-001-02-000-000-000-000 APPENDIX A- Date: September 20,2013 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 vour 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)780-18691. 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 NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 3-750.70936-0000053-001-03-000-000-000-000 HOMEOWNER'S NAME(S): MICHAEL S MARTIN PROPERTY ADDRESS: 1288 HIGH ST BOILING SPRINGS PA 17007 LOAN ACCT.NO.: _0789 ORIGINAL LENDER: First Financial Services,Inc. CURRENT LENDER/SERVICER: M&T Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE kL31DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the coun1y in which the property i�Llocated are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 3-750-70936-0000053-001-04-000-000-000-000 YOU HAVE THEIRRIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty(60) days to make a decision after it receives your application.During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE:IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTAGAGE debt held by the above lender on your property located at: 1288 HIGH ST BOILING SPRINGS PA 17007 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: June 1,2013 through September 20,2013 $2,626.28 Other charges(explain/itemize): $152.96 TOTAL AMOUNT PAST DUE: $2,779.24 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY(30)DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,779.24, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bycash, cashier's check, certified check or money order made payable and sent to: M&T Bank P.O.Box 62182 Baltimore,MD 21264-2182 Attn: Payment Processing IF YOU DO NOT CURE THE DEFAULT -If you do not cure the default within THIRTY(30)DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30)DAYS,the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys,but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred,up to $50.00. However, if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender,which may also include other reasonable costs. ff you cure the default within the THIRTY �30�DA Period. you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 3.750-70936-0000053-001-05-000-000-000-000 RIGHT TO TIM DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by_paving the total amount then past due. plus anlate or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and ay other.costs connected with the Sheriffs Sale as specified in writing bathe lender and by�performing my—other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 10 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: M&T Bank Address: P.O.Box 840 Buffalo,NY 14240 Phone Number: 1-800-724-1633 Fax Number: 1-855-678-0866 Contact Person: Evelyn Wilson E-Mail Address: ewilsonna,mtb.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not 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. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 3-750-70936-0000053-001-06-000-000-000-000 77 M i Foreclosure Mitigation Counseling .. _..__ MPH FA Initiative Agencies PENNSYLVANIA }tOtJ51NG FINANCE AGENCY Agencias Participantes que Aconsejan en Mitigacion contra la Ejecucion de una Hipoteca NOTICE: If you are a resident of Philadelphia, you must choose one of the Save Your Home Philly counseling agencies to be afforded the most punctual access to the Philadelphia Disposition process. Most of PHFA's Foreclosure Mitigation Counseling Initiative network agencies are also in the Save Your Home Philly network.To see a list: http://www.phila.gov/OHCD/csigagencies.htm Cumberland County Advantage Credit Counseling Service/CCCS of Western PA 2000 Linglestown Road Harrisburg,PA 17102 888-511-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg,PA 17104 717-232-9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York,PA 17401 717-855-2752 Maranatha 43 Philadelphia Avenue Waynesboro,PA 17268 717-762-3285 PathStone Corporation 1625 North Front St Harrisburg,PA 17102 717-234-6616 PathStone Corporation 450 Cleveland Ave Chambersburg,PA 17201 717-264-5913 PA Interfaith Community Programs Inc 40 E High Street Gettysburg,PA 17325 717-334-1518 PHFA 211 North Front Street Harrisburg,PA 17110 717-780-3940 800-342-2397 NOTE:For more information,questions,or concerns regarding this list,contact PHFA at 1.800.822.1174. "Other locations available to serve you;inquire with agency for more information. INTERNET REPRINT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA -0 �on t LAKEVIEW LOAN SERVICING,LLC Plaintiff . VS. Case No. SHERRY A. MARTIN /y ryV MICHAEL S. MARTIN Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference. First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date. During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. .. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: (Signature of Counsel for Plaintiff) 5/8/2014 Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket� BORROWER REQUEST FOR HARDS141P ASSISTANCE To complete-your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower names): Property Address: City: State: Zip: Is the property for sale? Y'es E—J.No Lj Listing date; Price: Realtor Name: Realtor Phone: Borrower occupied? Yes No Fj -- Mailing Address (if different): City: State:—Zip: Phone Numbers: Rome- office; Cell: Other; Email; #of people in household: How long? Mailing Address; City: State.,—Zip: Phone plumbers: Nome: Office: Cell: Other: Email: #ofpeople in household: How long? FINANCIAL lNr,()I1MATI0N 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 f6r Default: Is the loan in Bankruptcy? 'Yes[l No[I If}yes;provide names, location of court,case number&attorney: Assets Amount Owed: Vaiue: Home: $ Other.Real Estate: $ $ Retirement Funds: $ $ -- Investments: $ $ Checking: $� �^ Savings: $ $ Other: $� $ Automobile##l: Model: Year- Amount awed: Value: Automobile#2: Model: Year: Amount owed: Value: Other trans flrtationautomobiles boats m Coro cies • Madel: Year: Amount©wed: Value Month!y Income Name of Employers: l� Z. 3. Additional Income Description(nota wages): I. _ monthly amount: 2: monthly arnount:. Borrower Pay Days; Co-Borrower Pay nays: Montj ly Expernses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mo a Food 2 Mortgage Utilities Car Pa ent !j Condo/Nei Fees Auto Insurance Ivied. net covered) Auto fuellre irs Other ro .Rayment Install..Loan;Pa mcnt Cable TV Child Su rttAlirn. Spending Mone Ll a )Child CarelTuit. Other Ex eases Amount Available for Monthly Mortgage Payments Based on lncome&Expenses' Have you been working with a Housing Counseling Agency) 'Yes No El If yes,please provide the following infonnation: Counseling Agency: Counselor: Phone(Office): _- Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (1.1:1:MAP)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 Q If yes,please indicate the.status of those negotiations: Please provide the follo�&bg information, if know, regarding your leader or leader's loan servicing company: Lender's Contact(Name) Phone: Servicing Company(Name): Contact: Phone: oA authorize the above named to use/refer this information to my lenderlservicer for the sole purpose of evaluating my financial situation for possible mortgage options, I/We understand that Ilwe 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 leader's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days. Copy of a current utility bill Y Tetter explaining reason for delinquency.and any supporting documentation (hardship:letter) Listing agreement(if property is currently on the market) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY CE OF THE 64ERIF- _ FILED -OFFICE l HE PPD ► HONOT! l ,.{: 2014 MiY 19 P11 2:39.. CUMBERLAND COUNTY PENNSYLVANIA Lakeview Loan Servicing, LLC vs. Sherry A Martin (et al.) Case Number 2014-2836 SHERIFF'S RETURN OF SERVICE 05/12/2014 06:14 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Sherry A Martin at 1288 High Street, Monroe Township, Boiling Springs, PA 17007. RONALD HOOVER, DEPUTY 05/12/2014 06:14 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Sherry Martin, Spouse, who accepted as "Adult Person in Charge" for Michael S Martin at 1288 High Street, Monroe Township, Boiling Springs, PA 17007. SHERIFF COST: $50.78 SO ANSWERS, May 13, 2014 (C) CountySuito Sheriff, Toleosoff, lee, RONALD HOOVER, DEP TY RONN? R ANDERSON, SHERIFF In the Court of Common Pleas of Cumberland County LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 SHERRY A. MARTIN MICHAEL S. MARTIN (Mortgagor(s) and Record 1288 High Street Boiling Springs, PA 17007 vs. Owner(s)) Plaintiff Defendant(s) No. 14-2836 PRAECIPE FOR JUDGMENT<c ; + -r; THIS LAW FIRM ISA DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECTAB --1' OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TftE;PUREOSE'. OF COLLECTING THE DEBT. rr • - , Enter the Judgment in favor of Plaintiff and against SHERRY A. MARTIN and MICHAEL S. MARTIN by default for want of an Answer. Assess damages as follows: $92,183.58 Debt Interest from 7/31/2014 to Date of Sale per diem at $10.77 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: KML LAW GRO Michael McKeever PID 56129 Jay E. Kivitz Pa. ID 26769 _Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 _David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua L Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff AND NOW W""(1 ( �/ `1 LAKEVIEW LOAN SERVICING, LLC and against SHERRY A. MARTIN and MI ,Jud AEL want of an Answer and damages assessed in the sum of $92,183.58 as per the aboveifica 31 au is d in favor of y default Prothonotary p,I0 \\ce 1A4)Je� �,lc, T) a-3 7a Rule of Civil Procedure No. 236 — Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 SHERRY A. MARTIN MICHAEL S. MARTIN (Mortgagors and Record Owner(s)) 1288 High Street Boiling Springs, PA 17007 Plaintiff vs. Defendant(s) No. 14-2836 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above -captioned matter has been entered against you. David D. Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA:.17013 Prothonotary By: If you have any questions concerning the above, please contact: KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 i T THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: SHERRY A. MARTIN MARTIN, SHERRY A. 1288 High Street Boiling Springs, PA 17007 LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 Plaintiff vs. SHERRY A. MARTIN MICHAEL S. MARTIN (Mortgagor(s) and Record Owner(s)) 1288 High Street Boiling Springs, PA 17007 Defendants) TO: SHERRY A. MARTIN 1288 High Street Boiling Springs, PA 17007 DATE OF THIS NOTICE: July 17, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 14-2836 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI11'hN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: KML LA " OUP, P.C. Michae McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Freebie Pa ID 316160 215-627-1322 Attorneys for Plaintiff 129057 FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: MICHAEL S. MARTIN MARTIN, MICHAEL S. 1288 High Street Boiling Springs, PA 17007 LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 Plaintiff vs. SHERRY A. MARTIN MICHAEL S. MARTIN (Mortgagor(s) and Record Owner(s)) 1288 High Street Boiling Springs, PA 17007 Defendant(s) TO: MICHAEL S. MARTIN 1288 High Street Boiling Springs, PA 17007 DATE OF THIS NOTICE: July 17, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 14-2836 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 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 HERE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: rti KML LAW GR .i' P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAKEVIEW LOAN SERVICING, LLC Plaintiff vs. SHERRY A. MARTIN MICHAEL S. MARTIN Defendant(s) NO. 14-2836 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): SHERRY A. MARTIN, has a last known residence of 1288 High Street, Boiling Springs, PA 17007. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to autho ties. Date 713Dit1/41 By: KML LAW UP, P.C. Michael ' cK`6ever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313 897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant to Servicementhers Civil Relief Act Last Name: MARTIN First Name: SHERRI Middle Name: A Active Duty Status As Of: Jul -29-2014 Results as of : Jut -29-2014 02:36:37 PM 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 This response reflects the individuate active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duly 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 Onit 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. r4 Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not. actually begun active duty or actually reported for induction. The Last Date on ActiveDuty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 1BGD368F1047G10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAKEVIEW LOAN SERVICING, LLC Plaintiff vs. SHERRY A. MARTIN MICHAEL S. MARTIN Defendant(s) NO. 14-2836 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C.,. as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): MICHAEL S. MARTIN, has a last known residence of 1288 High Street, Boiling Springs, PA 17007. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. By: KML LAW t1' ', P.C. Michael cKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 lyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: MARTIN First Name: MICHAEL Middle Name: S. Active Duty Status As Of: Jul -30-2014 Results as of : Jul -30-2014 12:06:52 PM 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 This response reflects the individuate 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 ratification 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 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: GCJFW5505087W10 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 vs. SHERRY A. MARTIN MICHAEL S. MARTIN (Mortgagor(s) and Record owner(s)) 1288 High Street Boiling Springs, PA 17007 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 14-2836 ORDER FOR JUDGMENT Please enter Judgment in favor of LAKEVIEW LOAN SERVICING, LLC, and against SHERRY A. MARTIN and MICHAEL S. MARTIN for failure to file an Answer in the above action w. in (20) days from the date of service of the Complaint, in the sum of $92,183.58. By: KML LAW GROUP P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff f1;COhigi ,31g0 I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 and that the name(s) and last known address(es) of the Defendant(s) is/are SHERRY A. MARTIN, 1288 High Street Boiling Springs, PA 17007 and MICHAEL S. MARTIN, 1288 High Street Boiling Springs, PA 17007; By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $82,753.58 Interest from 05/01/2013 through $4,875.94 07/30/2014 Reasonable Attorney's Fee $1,650.00 Late Charges $221.60 Escrow $2,634.46 Property Inspections $28.00 NSF Charges $20.00 AND NOW, this day of 14-2836/129057FC By: $92,183.58 Pa. KML LAW GROUP, P C. Michael McKeever 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff , 2014 damages areassessedas above. (6to PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney -for Plaintiff LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mail stop MS5/251 Coral Gables, FL 33146 vs. SHERRY A. MARTIN MICHAEL S. MARTIN Mortgagor(s) and Record Owner(s) 1288 High Street Boiling Springs, PA 17007 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 14-2836 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 7/31/2014 to Date of Sale per diem at $10.77 (Costs to be added) (1,0 tha S c)‘'s CSF "6-1-51ci. ciP By: $92,183.58 KML LAW G II UP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff iat'a . QS -N.re ev. sou_ 5-0 A„,, -7 )c)-3-1.1— VI ill fIoetai Reale 31(91w :77f TRACT NO. 1: ALL THAT CERTAIN lot of ground situate in the Village of Churchtown, Township of Monroe and County of Cumberland, Pennsylvania, bounded and described as follows; FRONTING South on High Street; on the West on lot now or formerly of William Diller's heirs; on the North on an alley; and on the East on lot now of formerly of Harvey Rinehart (formerly Lot No. 1 in Plan of Lots). CONTAINNING 33 feet in front and 159 feet, more or less, in depth and having thereon erected a two-story from dwelling house and outbuildings, with mailing address of 1288 High Street, Boiling Springs, Pennsylvania 17007. TRACT NO. 2 ALL that certain lot of ground situate in the Village of Churchtown, Township of Monroe and County of Cumberland, Pennsylvania, bounded and described as follows: BEGINNING at the southeastern corner of Tract No. 1 herein, thence by High Street, East 33 feet to lands now or formerly of Paul D. Krissel, et al. thence by said lands now or formerly of Paul D. Krissel, et al. North 159 feet to an alley fence; thence West along said alley 33 feet to Tract No. 1 herein; thence South along the same 159 feet, more or less, to the place of BEGINNING. CONTAINNING 33 feet in front along the northern line of High Street and extending. northwestwardly therefrom at an even width 159 feet more or less to an alley. Parcel Numbers: 22-28-2401-059 and 22-28-2401-060 IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Village of Churchtown BEING PREMISES: 1288 High Street, Boiling Springs, PA 17007 SOLD as the property of Michael S. Martin and Sherri A. Martin, husband and wife TAX PARCEL #S 22-28-2401-059 and 22-28-2401-060 BEING the same premises which Earl D. Garman and Frances C. Garman, husband and wife by deed dated 7/8/11 and recorded 8/30/11 in Cumberland County in Deed Book Volume Instrument #201124112 granted and conveyed unto Michael S. Martin and Sherri A. Martin, husband and wife. nar KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff c`G ti o70/4 40c T, vUr�eERi4 ` J, -EllF�S ycod... IN THE COURTRi1/ Oi 4MON PLEAS LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 vs. SHERRY A. MARTIN MICHAEL S. MARTIN (Mortgagor(s) and Record Owner(s)) 1288 High Street Boiling Springs, PA 17007 Plaintiff Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 14-2836 AFFIDAVIT PURSUANT TO RULE 3129 LAKEVIEW LOAN SERVICING, LLC, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1288 High Street Boiling Springs, PA 17007 1.Name and address of Owner(s) or Reputed Owner(s): SHERRY A. MARTIN 1288 High Street Boiling Springs, PA 17007 MICHAEL S. MARTIN 1288 High Street Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: SHERRY A. MARTIN 1288 High Street Boiling Springs, PA 17007 MICHAEL S. MARTIN 1288 High Street Boiling Springs, PA 17007 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 1288 High Street Boiling Springs, PA 17007 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: By: KML LAW LR@UP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff Tem f1Q pi KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215)627-1322 Attorney for Plaintiff LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 vs. SHERRY A. MARTIN MICHAEL S. MARTIN Mortgagor(s) and Record Owner(s) 1288 High Street Boiling Springs, PA 17007 Plaintiff Defendant(s (Jr rye 6LEO -(��-F . 2814 ALIC I AMID: 3e PSP A NO C �1A 14-2836 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 14-2836 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MARTIN, SHERRY A. SHERRY A. MARTIN 1288 High Street Boiling Springs, PA 17007 Your house at 1288 High Street, Boiling Springs, PA 17007 is scheduled to be sold at Sheriffs Sale on Wednesday, December 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $92,183.58 obtained by LAKEVIEW LOAN SERVICING, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to LAKEVIEW LOAN SERVICING, LLC, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. s ori 14-2836 4. 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 below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is -wrong) are -filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 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 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 14-2836 Resources available for Homeowners in Foreclosure ACT NOW! Even though your .lender .(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. . 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). ;Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consthnefs/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options._ 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup:com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or packageyou`requested will.be,mailed to the'.address that you request or faxed if you leave a: message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 129057FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FILED-OFFIL OF THE PFOTHONO TAR [014 AUG -I MI 10: 38 CUMBERLAND COUNTY PENNSYLVANIA LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 vs. SHERRY A. MARTIN MICHAEL S. MARTIN Mortgagor(s) and Record Owner(s) 1288 High Street Boiling Springs, PA 17007 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 14-2836 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: KMLLAWGU',P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff J It% Raqi 310(ico THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net LAKEVIEW LOAN SERVICING, LLC Vs. NO 14-2836 Civil Term. CIVIL ACTION — LAW SHERRY A. MARTIN MICHAEL S. MARTIN 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: $92,183.58 L.L.: $.50 Interest FROM 7/31/14 TO DATE OF SALE PER DIEM AT $10.77 Atty's Comm: Atty Paid: $199.53 Plaintiff Paid: Date: 8/1/14 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonota REQUESTING PARTY: Name: JENNIFER FRECHIE, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 316160 Deputy KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FILED-UFICE CF THE PI;OTHONOTA:ZY 20111 NOV I 7 Ali 10: 25 CutInFmil:)12 0 - PENH 3 y>1:vAtykTillE COURT OF COMMON PLEAS LAKE VIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 vs. SHERRY A. MARTIN MICHAEL S. MARTIN Mortgagor(s) and Record Owner(s) 1288 High Street Boiling Springs, PA 17007 Plaintiff Defendant(s) 129057FC CF: 05/09/2014 SD: 12/03/2014 $92,183.58 of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 14-2836 Andrew Hauck, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. Premises was posted by Sheriffs Office/competent adult (copy of return attached). Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail attached). Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respe dully submitted, BY: Andrew Andrew Hauck Legal Assistant IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA LAKEVIEW LOAN SERVICING, LLC; et seq. Plaintiff (Petitioner) V. SHERRY A. MARTIN; et al. Defendant (Respondent) CASE and/or DOCKET No.: 14-2836 Sheriffs Sale Date: 12/3/2014 AFFIDAVIT OF SERVICE ❑ Complaint 0 Summons 0 Other: NOTICE OF SALE 1, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served SHERRY A. MARTIN the above process on the 23 day of August, 2014, at 3:42 o'clock, PM, at 1288 HIGH STREET BOILING SPRINGS, PA 17001 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: 0 By handing a copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in charge of the residence because no adult family member was found * By handing a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at which he/she resides * 0 By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s') agent or to the person for the time being in charge thereof * * Name: MICHAEL MARTIN Relationship/Title/Position: Spouse . Remarks: Description: Approximate Age 41-45 Height 5'10 Weight 240 Race WHITE Sex MALE Hair BROWN Military Status: ONO • ❑ Yes Branch: Commonwealth/State of P4 ) ) SS: County of Or • tJ ) Before me, the undersigned notary public, this day, personally, appeared itGV4t. tAeie duly sworn according to law, deposes the following: I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct i� r - (Signature of Affiant) File Number:129057FC Case ID #:4062668 Subscribed and swo this Lt day of to me known, who being ,20 fY COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflerbach, Notary Public Washington Township, Barks County My Commission Expires November 18, 2017 Notary Public IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA LAKEVIEW LOAN SERVICING, LLC; et-seq. Plaintiff (Petitioner) V. SHERRY A. MARTIN; et al. Defendant (Respondent) CASE and/or DOCKET No.: 14-2836 Sheriffs Sale Date: 12/3/2014 AFFIDAVIT OF SERVICE El Complaint El Summons El Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served MICHAEL S. MARTIN the above process on the 23 day of August, 2014, at 3:42 o'clock, PM, at 1288 HIGH STREET BOILING SPRINGS, PA 17001, County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: By handing a copy to the Defendant(s) Description: Approximate Age 41-45 Height fn Weight 240 Race WHITE Sex MALE Hair BROWN Military Status: l]No ❑Yes Branch: Commonwealth/State of Pe ) SS: County of 6c.14 1 Before nie, the undersigned notary public, this day, personally, appeared duly sworn according to law, deposes the following: X a o oa. G j .. to me known, who being I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. (Signature of Affiant) File Number:129057FC Case ID #:4062668 Notary Public Subscribed and swo this 2 tr day of COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflerbach, Notary Public Washington Township, Berks County My Commission Expires November 18, 2017 Name and Address of Sender OLDBECK(If lU ITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service: ❑ Certified ❑Recorded Delivery (International) 0 COD 0 Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise 0 Express Mail 0 Signature Confirmation 0 Insured Addressee (Name, Street, City, State, & ZIP Code) Postage Affix Stamp Here issued as a certificate of mailing, or for additional of this bill) Postmark and Date of Receipt Fee copies Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee R` D Fee RR Fee Article Number 1. DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 TENANTS/OCCUPANTS 1288 High Street NQS v`. 'AUG ; i,isa.��' {r is .,.ti* ,i'4.,101 :4 U.S. POSTAGE �: j /��� •: ZIP 19106 • 002 1r 001391829AUG. : r >> PITNEY BOWES ��� $ 001 06. �t 2014. 0 2. PA DEPARTMENT OF PUBLIC WELFARE Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Boiling 5 9 rin s, PA p 9 1 (00! G vN 3. Harrisburg, PA 17105-2675 •. `.t WE 201) 4. ', • 5. 6. 7. 8. Total Number of Pieces Listed by Sender Total Number of Pieces Received at Post Office \..., Postmaster, Per (Na of re eiving employee) See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) omplete by Typewriter, Ink, or Ball Point Pen 129057FC Cumberland County Sale Date: 12/03/2014 SHERRY A. MARTIN & MICHAEL S. MARTIN Name and Address of Sender :ML LAW GROUP, P.C.(If iUITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service; ❑ Certified El Recorded Delivery (International) ❑ COD ❑ Registered E Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt Article Number Addressee Name, Street City, & ZIP Code ( ) Postage g Fee Handling Ch---" Actual Value if a=nict, red ' • Insured Value r,, '� • . , Inti . Due Sender if COD DC Fee SC Fee SH Fee RD Fee RR Fee 1. Monroe Township Municipal Authority 1220 Boiling Spring Road Mechanicsburg, PA 17055-9794 iU.S. POSTAGE >> PITNEY G/ ' BOWES 2014 02 1Y419106 $ 00013918290CT. 002.600 30. 2' Monroe TownshipMunicipal Authority. p��'� do Michael J. Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 ' 3. \PM PEN ZZ 5. c.o.r..e......_ 3) 90 tierOCT 2014 ✓Ai 6. �� PA 19\0 7. 8. Total Number of Pieces Total Number Pieces Listed by Sender 109NReceived at! ost ffice Postmaster, Per (Name of re mployee) See Privacy Act Statement on Reverse v PS Form 3877, February 2002 (Page 1 of 2) 129057FC Cumberland County Sale Date: 12/03/2014 SHERRY A. MARTIN & MICHAEL S. MARTIN Bete by Typewriter, Ink, or Ball Point Pen KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff LAKEVIEW LOAN SERVICING, LLC 4425 Ponce De Leon Blvd. Mailstop MS5/251 Coral Gables, FL 33146 vs. SHERRY A. MARTIN MICHAEL S. MARTIN Mortgagor(s) and Record Owner(s) 1288 High Street Boiling Springs, PA 17007 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 14-2836 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 LAKEVIEW LOAN SERVICING, LLC., Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1288 High Street Boiling Springs, PA 17007 1.Name and address of Owner(s) or Reputed Owner(s): SHERRY A. MARTIN 1288 High Street Boiling Springs, PA 17007 MICHAEL S. MARTIN 1288 High Street Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: SHERRY A. MARTIN 1288 High Street Boiling Springs, PA 17007 MICHAEL S. MARTIN 1288 High Street Boiling Springs, PA 17007. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: Monroe Township Municipal Authority 1220 Boiling Spring Road Mechanicsburg, PA 17055-9794 Monroe Township Municipal Authority do Michael J. Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 1288 High Street Boiling Springs, PA 17007 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. DATED: November 13, 2014 KML Law Group, P.C. BY: Andrew Hauck Legal Assistant