HomeMy WebLinkAbout14-2888 Supreme. Court of Pennsylva a
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Cou3�of Coffi non Pleas
V1* For Prothvnotar^y Use Onh-
va Over, et
Docket No:
Cumberlandv u : County
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:
® 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 NICKOLAS E.MACRI
C
T
I Dollar Amount Requested within arbitration limits
0 Are money Damages requested?: ❑ Yes ® No (Check one) X_outside arbitration limits
1.
Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO
A Name of Plaintiff/appellant's Attorney: KML Law Group,P.C.
❑ Check here if you are a Self-Rep resented(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
O Premises Liability ❑ Zoning Board
❑ Product Liability(does not include ❑ Employment dispute: ❑ Statutory Appeal: Other
E mass tort) Discrimination
C ❑ Slander/Libel Defamation
❑ Other ❑ Employment Dispute:Other
T ❑ Other:
Q 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
® Mortgage Foreclosure:Residential 1 ❑ 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
e ^ f
KML LAW GROUP,P.C.
SUITE 5000-BNY MELLON INDEPENDENCE CENTER r... t
701 MARKET STREETT
'JILT-- 1�1 0 ` t Tji
PHILADELPHIA,PA 19106
(866)413-23113 v
xVWW Kn"1 I AW(R IIJP C OM
LAKEVIEW LOAN SERVICING,LLC r j` IN THE COURT OF COMMON PLEAS
4425 Ponce De Leon Blvd. "� �� n�`r
FE�'� S�l`�.` A OU°'�, r OF Cumberland COUNTY
Mailstop MS5/251 ��i{,�
Coral Gables,FL 3.3146
Plaintiff CIVIL ACTION-LAW
vs.
NICKOLAS E.MACRI ACTION OF MORTGAGE FORECLOSURE
Mortgagor(s)and Record Owner(s) '�,a �
3423 Bedford Drive CPAL AW9N:MORTGAGE.
Camp Hill,PA 17011
Defendant(s) FORECLOSURE
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 ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las
pagmas siguientes,usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion.
Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma
escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se
defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion.
Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones
de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O
SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME
POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. 0-&4 b 103.7Sw`
SI LISTED 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 htto://www.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.org/foreclosure/
7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email
at homeretentiongkmilawaroup.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 12693617C.
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 NICKOLAS E. MACRI, 3423 Bedford Drive,
Camp Hill,PA 17011, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises
hereinafter described.
3. On August 16, 2012 mortgagor(s)made, executed and delivered a mortgage upon the Property
hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., SOLELY
AS NOMINEE FOR UNITED WHOLESALE MORTGAGE, which mortgage is recorded in the Office
of the Recorder of Deeds of Cumberland County on August 22, 2012 as Instrument 4 201225658. The
mortgage has been assigned to: LAKEVIEW LOAN SERVICING, LLC by assignment of Mortgage.
Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as
Exhibit C. 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 August 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..................................................................................$109,591.64
Interest from 07/01/2013 through 04/15/2014 at 3.6250%.......................$3,131.92
Per Diem interest rate at$10.88
LateCharges ...............................................................................................$253.90
Escrow/Impound Overdraft........................................................................$157.13
ProRata PMI..................................................................................................$51.96
PropertyInspections.....................................................................................$118.00
Reasonable Attorney's Fee.......................................................................$1.650.00
$114,954.55
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$114,954.55,
together with interest at the rate of$10.88,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 GROUP, P.C.
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. ID 205047-
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
VERIFICATION
1, Robert J. Horan 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 Pa. C.S. Sec.4904 relating to unsworn falsification to authorities.
Date:
Rober J. ora ice President
#126936FC -NICKOLAS E.MACRI
3423 Bedford Drive Camp Hill,PA 17011
�hibit
A
ALL THAT CERTAIN tract or parcel of ground situate in the Borough of Camp Hill, County of Cumberland,
Commonwealth of Pennsylvania, more particularly bounded and described according to survey of William B.
Mittock,Registered Professional Engineer,dated November 21, 1957.
BEGINNING at a point on the South side of Bedford Drive, seven hundred fifty and eleven one-hundredths
(750:11)feet West of the intersection of Bedford Drive and North 30 Street, also at the dividing line-between
Lots Nos. 124 and 125 on hereinafter mentioned Plan of Lots; thence South five (05) degrees fifty-seven (57)
minutes East along the same,one hundred five(105)feet to a point at the dividing line between Lots Nos. 125 and
145 on said Plan; thence South eighty-four(84) degrees three (03)minutes West along the same and along Lot
No. 146 on said Plan,seventy-five(75)feet to a point at the dividing line between Lots Nos. 123 and 124 on said
PIan;thence North five(05)degrees fifty-seven(57)minutes West along the same,one hundred five(105)feet to
a point on the South side of Bedford Drive; thence Eastwardly along the same, seventy-five (75)feet to a point,.
the Place of BEGINNING.
BEING Lot No. 124 on the General Plan of Hollywood Development, recorded in Plan Book 7, Page 27,
Cumberland County records.
HAVING thereon erected a one story brick dwelling house known as No.3423 Bedford Drive.
i
i
I
*Exhibit has been redacted to remove all personally identifiable information or non-public information
t
REP RES EN TAT ION jjQj0ftV# A%NT
9207 1969 0043 7100 0217 9599 53
M&T.Bank
P.O. Box 840
Williamsville, NY 14221
5.750-71444-0000196-001-01-000-000-000-000
NICKOLAS MACRI
3423 BEDFORD DR
CAMP HILL PA 17011
INTERNET REPRINT
REPRESENTATION OF PRINTED DOCUMENT 5-750-71444-0000196-001-02-000-000-000-000
APPENDIX A
Date: October 7,2013
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 pro-gram 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 Agenck
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 can 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 NOTIFICACION 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 5-750-71444-0000196-001-03-000-000-000-000
HOMEOWNER'S NAME(S): NICKOLAS MACRI
PROPERTY ADDRESS: 3423 BEDFORD DR
CAMP HILL PA 17011
LOAN ACCT.NO.: _1636
ORIGINAL LENDER: United Wholesale Mortgage
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 (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO
DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT";
EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - 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 counselinE a eg ncies for the coun1y in which the propeM is located are set forth at the
end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender
immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default.)
You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies listed at
the end of this Notice. Only consumer credit counseling agencies have applications for the program and
they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.
To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to
PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A
MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT
MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A
FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED "TEMPORARY STAY OF FORECLOSURE".
INTERNET REPRINT
REPRESENTATION OF PRINTED DOCUMENT 5-750.71444-0000196-001-04-000-000-000-000
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 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: 3423 BEDFORD DR CAMP HILL PA 17011 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: -
August 1,2013 through October 7,2013
$2,382.79
Other charges(explain/itemize): $135.56
TOTAL AMOUNT PAST DUE: $2,518.35
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
$2,518.35, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either b cashcashier'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. If you cure the default within the THIRTY _DAY Period. you will not be
required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
INTERNET REPRINT
REPRESENTATION OF PRINTED DOCUMENT 5-750-71444-0000196-001-05-000-000-000-000
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may
do so by paying the total amount then past dueplus ablate or other charges then duereasonable
attorney's fees and costs connected with the foreclosure sale and any-other costs connected with the
Sheriffs Sale as specified in writing by-the lender and by-performing mother 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 9-790-71444.0000196.001.06-000.000-000-000
Foreclosure Mitigation Counseling
.............._..
PENNSYLVANIA HOUSINGFINANCE AGE:NC.Y Initiative Agencies
'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
ExFiidit
C
When Recorded Return To:
VERONIKA STEEN
M&T BANK
ATTN: ASSIGNMENT GROUP
PO BOX 1288
BUFFALO, NY 14203
Parcel No.01-21-0275-028
CORPORATE ASSIGNMENT OF MORTGAGE
Cumberland, Pennsylvania
SELLER'S SERVICING# 636 "MACRI"
SELLER'S LENDER ID#: P97
MERS#: 100032413512262168 SIS#: 1-888-679-6377
Date of Assignment: March 7th, 2014
Assignor: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ("MERS")AS NOMINEE FOR
UNITED WHOLESALE MORTGAGE ITS SUCCESSORS AND ASSIGNS
Assignee: LAKEVIEW LOAN SERVICING, LLG
I hereby certify the precise address of the within �.amed Assignor is 1901 E VOORHEES STREET,
SUITE C, DANVILLE, IL 61834.
1 hereby certify the precise address of the within named Assignee is 4425 PONCE DE LEON BLVD,
CORAL GABLES, FL 33146.
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC is at 1901 E Voorhees Street, Suite C,
Danville, iL 61834, P.O. BOX 2026, FLINT, MI 48501.2026
Executed By: NICKOLAS E. MACRI,A SINGLE MAN To: MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC. ("MERS")AS NOMINEE FOR UNITED WHOLESALE MORTGAGE ITS
SUCCESSORS AND ASSIGNS
Date of Mortgage: 08/16/2012 Recorded: 08/22/20,12 in Book/Reel/Liber: N/A Page/Folia: N/A as
Instrument/Document: 201225657 In the County of Cumberland, State of Pennsylvania.
3423 BEDFORD DRIVE, CAMP HILL, PA 17011 in the Borough of CAMP HILL
I do certify that the precise a ess of LAKEVIEW LCAN SERVICING, LLC is 4425 PONCE DE LEON
BLVD, COG BL , 33146
Attested By�
KNOW ALL MEN BY THESE PRESENTS,that for good and valuable consideration, the receipt and
sufficiency of which is hereby acknowledged, the said Assignor hereby assigns unto the above-named
Assignee,the said Moitgage having an original principal sum of$111,350.00 with interest, secured
thereby, with all moneys now owing or that may hereafter become due or owing in respect thereof, and
*KA3"KAMATB*03107/2014 11:17:02 AM*MATB01 MATBA000000000000000775374*PACUMBE*
_1.636 PASTATE_MORT_ASSIGN_ASSN —KAMATB*
CORPORATE ASSIGNMENT OF MORTGAGE Page 2 of 2
the full benefit of all the powers and of all the covenants and provisos therein contained, and the said
assignor hereby grants and conveys unto the said assignee, the assignor's interest under the Security
Instrument.
TO HAVE AND TO HOLD the said Security instrument, and the said property unto the said assignee
forever, subject to the terms contained in said Security Instrument.
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ("MERS')AS NOMINEE FOR UNITED
WHOLESALE MORTGAGE ITS SUCCESSORS AND ASSIGNS
On March 7th. 2014
JB :
nika A. Steen,Assistant Secretary
STATE OF New York
COUNTY OF Erie
On the 7th day of March in the year 2014 before me, the undersigned Notary Public in and for said State, .
personally appeared Veronika A. Steen, Assistant Secretary of MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, INC. ("MERS')AS NOMINEE FOR UNITED WHOLESALE MORTGAGE
ITS SUCCESSORS AND ASSIGNS, personally known to me or proved to me on the basis of
satisfactory evidence to be the irdividual(s)whose name(s) is(are)subscribed to the within instrument
and acknowledged to me that he/she/they executed the same in his/her/their capacity(ies), and that by
his/her/their signature(s)on the instrument the individual(s), or the person upon behalf of which the
individual(s)acted, executed the instrument.
WITNESS my hand and official seal, HOLLYSUCKOW
Lie.#01$U5068M
Notary Pubiia3taW of New Yi7rk
Qualftd in Erle County
HOLLY SU OW My Commission Expires OCTOBER 28,20'14
Notary Ex s: 10/28/2014 #01SU5068226
Qualified in Erie County
(This area for notarial seal)
*KA3*KAMATB*03/07/2014 11:17:02 AM*MATS01 MATBA000000000000000775374*PACUMBE*
636 PASTATE_MORT_ASSIGN_ASSN **KAMATB*
G
IN THE COURT OF COMMON PLEAS Off' = '
CUMBERLAND COUNTY, PENNSYLVANIA.
J)17(
,,E
LAKEVIEW LOAN SERVICING,LLC �"�� � '•
C! " i �• ,
Plaintiff
:r G7 •.,
, i—
vs. G n
Case No. CJu �> �0
NICKOLAS E. MACRI
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:
(Signatur of Counsel for Plaintiff)
5/9/2014
Date
t
Cumberland County Residential Mortgage Foreclosure Diversion Program
Date
Financial 'worksheet.
Cumberland County Court of Common Pleas Docket#
f3URRQWER REQUEST FQR HARDSHIIp ASSISIAI CE
To complete-your request for hardship assistance
,your lender must circumstances to determine possible options while working with your consider your
Please provide the fo]lowing information to the hest of your knowledge:
Borrower narrre(s):
Property Address.
City: State:_
Is the property for sale? Yes Zip,
Realtor Name: No Listing date;. Prise:$�,
Borrower Occupied? Yes No Realtor Phone:
Mailing Address(if different).- ��� �--
City:
Phone Numbers: State: Zip:
Home: Office:
Email. Cell: Other;
#of people in household: How long?
Mailing Address;
City: State:
Phone Numbers: Horne: ��p'
Office:
Email: Cell: Other:
#ofpeople in household: How long?
First Mortgage Leader:
Type of Loan:
Loan.Number: llate You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Takes Insurance;
Date of Last Payment:
Pritziary Itea'son far I3efault•
Is the loan in Bankruptcy? 'Yes No[�
Tf Yes,provide names,location of coourt, case number&attorney:
---------------
Assets Arr ogrt owed: Value:
Home.
Other Real Estate: $—
Retirement Funds;
Investments: � $
Checking:
Savings: S "�""
Other: ----_---___
Automobile 41: Model.
Amount owed Year.,
Value:
Automob bile Model: Year
Amount owed: Value:
Other trans ortation automobiles hosts rn torc cle$ Model.,
Year... Amount owed: Value
------------
Montlil,Income
Name of Employers:
1..
2.
3.
Additional Income.Description(not wages):
I montWy amount:
2. monthly amount
Borrower Pay Days: Co-Borrowex Pay Days:
Monthly Expenses:(Please only include expenses you are currently paying)
I XI'l l E A.I��fOUZN BXPENSE AMOUNT
Mo a e Road
2 Mort. a a
ITtlities _
Car Pa -on s CondotNei h,Fees
Auto Insurance Med, not covered
Auto fuel/re airs Other ro a meet
Install.Loan Pa rrrent Cable TV
Child Su rtlAlim, S ndin Hone
DaylCshi.Id CarelTuit.
-- --– -- - Other Expenses
Ainount Available for Monthly Mortgage Payments Based on Income&Expenses.-
Have
xpenses.Have you been working with a Housing Counseling Agency?
Yes D No[]
If yes,please provide the following information:
Counseling Agency:
Counselor:
Phone.(Ofhjce): Fix:
Email:_
Have you made application for Homeowners Emergency Mortgage Assistance Program
_04EMAP)assistance?
yes 0 No
eyes,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 M No
If yes,please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or leader's loan
servicing company:
Lender's Contact(Name):
Phone:
Servicing Company(Name):
Contact: Phone:
me,
riarned ,authorize the above
to use/refer this infoamation 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 Uatr
Please forward this document along with the:following information to bender and
lender's counsel:
�f Proof of income
Past bank statements
Proof ofany expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation .
(hardship.tetter)
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
Di corm r� : i it PROT HHO '4011\10
OFfCE OF THE 5f4ERIFF
2Efftt JUN —4 PM 3: } �_
CUMBERLAND COUNTY
PENNSYLVANIA
Lakeview Servicing, LLC
vs.
Nickolas E Macri
Case Number
2014-2888
SHERIFF'S RETURN OF SERVICE
05/23/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Nickolas E Macri, 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 3423 Bedford Drive, Camp
Hill Borough, Camp Hill, PA 17011. Deputies were advised by the neighbor that the defendant moved our
six months ago and per the Camp Hill Postmaster mail is still delivered to the address provided.
SHERIFF COST: $33.00 SO ANSWERS,
May 23, 2014
(c) CountySuito Sheriff, Te!eosoft, Inc.
RONNR ANDERSON, SHERIFF
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
LAKEVIEW LOAN SERVICING, LLC
4425 Ponce De Leon Blvd.
Mailstop MS5/251
Coral Gables, FL 33146
Plaintiff
vs.
NICKOLAS E. MAORI
(Mortgagor(s) and Record owner(s))
3423 Bedford Drive
Camp Hill, PA 17011
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 14-2888 civil
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
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Kindly mark the above case Discontinued and Ended without prejudice upon payment of
your costs only.
KML LAW GROUP, P.C.
F/K/A GOLDBECK McCAFFERTY & McKEEVER
Bv:
el McKeeva. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Thomas Puleo Pa. ID 27615
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello, Pa. ID 313897
Jennifer Lynn Frechie, Pa. ID 316160
Attorneys for Plaintiff