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HomeMy WebLinkAbout14-23971 X11 Supreme Caurt_ai Pennsylvania S E C T 0 N A S E C T I 0 N B C:ourt of Cotnmoit. Pleas Gig il.Co� ei, Sheet Cumberland County For Protlionotar v Use Onlj': Docket No: The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: Complaint 0 Writ of Summons 0 Transfer from another Jurisdiction ❑ Petition ❑ Declaration of Taking Lead Plaintiff Name: LOANDEPOT.COM, LLC Lead Defendant's Name: DEBRA LINN Are money Damages requested?: 0 Yes ® No Dollar Amount Requested within arbitration limits (Check one) X outside arbitration limits Is this a Class Action Suit? 0 Yes X NO Is this an MDJ Appeal? 0 Yes NO Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. 0 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) ❑ Intentional ❑ Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander/Libel Defamation ❑ Other MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other CONTRACT (do not include Judgments) ❑ Buyer Plaintiff ❑ Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment dispute: Discrimination ❑ Employment Dispute: Other O Other CIVIL APPEAL Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Zoning Board ❑ Statutory Appeal: Other ❑ Other: PROFESSIONAL LIABILITY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: REAL PROPERTY ❑ Ejectment ❑ Eminent Domain/Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute gX Mortgage Foreclosure: Residential ❑ Mortgage Foreclosure: Commercial ❑ Partition ❑ Quiet title O Other MISCELLANEOUS ❑ Common Law/Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non -Domestic Relations Restraining Order ❑ Quo Warranto ❑ Replevin ❑ Other Pa.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 — BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PI-IILADELPHIA, PA 19106 (866) 413-2311 WWW.KMLLAWGROUP.COM LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 Plaintiff vs. DEBRA LINN Mortgagor(s) and Record Owner(s) 12 Walnut Lane Camp Hill, PA 17011 Defendant(s) `�L� ` )� f i 4I1�1 THE COURT OF COMMON PLEAS NOTICE OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CIVIL ACTION: MoraCiACI,. QRECLOSSURE 9_ -Yl LVr 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 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Qom-} Si O !.7.74,C4fatid a* 3b, -W112 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 0 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 1N 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/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 homeretention@kmllawaroup.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 131089FC. 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 LOANDEPOT.COM, LLC, 425 Phillips Blvd, Ewing, NJ 08618. 2. The name(s) and address(es) of the Defendant(s) is/are DEBRA LINN, 12 Walnut Lane, Camp Hill, PA 17011, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On October 20, 2012 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR LOANDEPOT.COM, LLC, its successors and assigns which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on October 31, 2012 as Instrument # 201233493. The mortgage has been assigned to: LOANDEPOT.COM, LLC by assignment of Mortgage recorded on February 14, 2014 as Instrument # 201403239. 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 of principal and interest are due and unpaid for September 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: Principal Balance $119,975.31 Interest from 08/01/2013 through 05/01/2014 at 4.0000% $3,599.28 Monthly interest at $399.92 Late Charges $213.27 Escrow Advance $414.23 Property Inspection $120.00 Recoverable Balance $195.00 Pro Rata MIP/PMI $162.81 Reasonable Attorney's Fee $1,650.00 $126,329.90 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 has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit "B". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $126,329.90, together with interest at the rate of $399.92, per month 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, Michael McKeer'a. 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 313 897 Attorneys for Plaintiff Jrfontjtv ThCCWc X 16 [ (QO VERIFICATION 1, re,'esa , tG -ream Lead , for Cenlar FSB, servicing agent for LOANDEPOT.COM, LLC, the Plaintiff herein, hereby verifies and says 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: ?//Lth ),J\Ng'&4 rc�Tearn � aid #131089FC - DEBRA LINN 12 Walnut Lane Camp Hill, PA 17011 Exjiibit)1 All that tract or parcel of land situate in the Town/City of Camp Hill, County of CUMBERLAND and State of PA, and more particularly described as follows: All that certain tract or parcel of ground situate in the Township of Lower Allen, County of Cumberland, Commonwealth of Pennsylvania, m ore particularly bdunded and deScribed according to survey of Ernest J. Walker, Professional Engineer, dated September 10, 1963, as follows: BEGINNING ata point at a stake on the Northern line of Walnut Lane 50 feet wide, 220 feet in a Westerly direction by same from Walnut Circle at the dividing line between Lots Nos. 5-A and Block 6, Block "F"; THENCE along Lot No. 5-A, Block "F," North 31 degrees 39 minutes West a distance of 126.58 feet to a point on the dividing lin? between Lots Nos. 5 and 6, Block "P; THENCE along Lot No. 5, Block "F", North 27 degrees 11 minutes*Eatt a distance of 43.16 feet to a point at lands. now or formerly of Allen Park Development Corporation; THENCE along said lands South 87 degrees 9 minutes East a distance of 27.98 feetto a point at the dividing line betVigen Lots Nos. 6 and 7, Block "F"; THENCE along Lot No. 7, Block "F", South 31 degrees n minutes East, a distance of 133.11 feet to a point on the Northern line of Walnut Lane 50 feet THENCE along the Nbilhem line of Walnut Lane South 58 degrees 21 Minutes West a distance of 60 feet to the place of BEGINNING. Efiibi *Exhibit has been redacted to remove all personally identifiable information or non-public information YOUR BEST LOAN. PERIOD.' • Ioanoepot 7 S October 23, 2013 Debra Linn 12 Walnut Lane Camp Hill PA 17011 Hours of operation: 00216 Customer Service:Monday - Friday, 8:30 AM to 11:00 PM EST Collections Dept.:Monday - Friday, 8:30 AM to 10:00 PM EST Loan Number: X2710 Property Address: 12 Walnut Lane Camp Hill PA 17011 NOTICE OF INTENTION TO FORECLOSE MORTGAGE 0047932710 HZ Dear Debra Linn: The MORTGAGE held by LOANDEPOT.COM,LLC (hereinafter we, us or ours) on your property located at: 12 Walnut Lane Camp Hill PA 17011 IS IN SERIOUS DEFAULT because you have not made the monthly payment (s) and other charges for the months of September 01, 2013 through October 23, 2013 as follows: Next Payment Due Date: Current Monthly Payment: September 01, 2013 $846.65 Total Monthly Payments Due: $1,693.30 Late Charges:. $46.44 Other Charges: Uncollected NSF Fees: $.00 Other Fees: $.00 Corporate Advance Balance: $.00 Suspense Funds: $.00 TOTAL YOU MUST PAY TO CURE DEFAULT: $1,739.74 The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is: TOTAL YOU MUST PAY TO CURE DEFAULT: $1,739.74 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $1,739.74, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order. Please remit the total amount due immediately to: loanDepot, P.O. Box 77404, Ewing, NJ 08628. www.loandepot.loanadministration.com 1-877-420-4526 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legalproceedings against you, you will still have to pay the reasonable attorney' s fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney'sfees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty 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 Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately January 21, 2014. A notice of the date of the Sheriff 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 will be by calling us at the following number: 877-420-4526. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU 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 (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEYI]S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, loanDepot offers consumer assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. You may be eligible for a loan workout plan or other option. If you would like to learn more about these programs, you may contact us at the number listed. WE ARE VERY INTERESTED IN ASSISTING YOU. Attention Servicemembers and dependents: The Federal Servicemembers' Civil Relief Act ("SCRA") and certain state laws provide important protections for you, including prohibiting foreclosure under most circumstances. If you are currently in the military service, or have been within the last nine (9) months, AND joined after signing the Note and Security Instrument now in default, please notify loanDepot immediately. When contacting loanDepot as to your military service, you must provide positive proof as to your military status_ If you do not provide this information, it will be assumed that you are not entitled to protection under the above-mentioned Act. For your benefit and assistance, there are government approved homeownership counseling agencies designed to help homeowners avoid losing their homes. To obtain a list of approved counseling agencies, please call (800) 569-4287 or visit http:l/www.hud.gov/offices/hsglsfhlhcc/hcs.cfm. You may also contact the Homeownership Preservation Foundation'sHope hotline at (888) 995 -HOPE (4673). This matter is very important. Please give it your immediate attention. Sincerely, loanDepot 425 Phillips Blvd. Ewing, NJ 08618 XC019 008 JYH HZ FEDERAL LAW REQUIRES US TO ADVISE YOU THAT THIS IS AN A'1TEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN A'1'I'LMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE NUMBER. Cumberland County *CCCS of Western PA - York 55 Clover Hill Road Dallastown PA 17313 888.511.2227 / 888.511.2227 www.cccspa.org Community Action Commission - Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 www.cactricounty.org Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Housing & Redevelopment Authority - Cumberland Cnty 114N Hanover St; STE 104 Carlisle PA 17013 866.683.5907 / 717.249.0789 www.cchra.com Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 vvww.ruralisc.org/pathstone_pa.htm Pennsylvania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 www.adamscha.org LOANDEPOT.COM, LLC Plaintiff vs. DEBRA LINN Defendant(s) IN THE COURT OF COMMON PLEAS OF .. CUMBERLAND COUNTY, PENNSYLVAI Case No. -G y, ( - )3/i? N 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. All_911V4 Date Respectfully . bmi (Signature of � ns. for Plaintiff) Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete•your request for hardship assistance, your lender must consider your circumstances to deterrnine possible options while working with your Please provide the following information to the best of your knowledge: 1),STompot>,RimA1ty:iiiPP 'CANT • - Borrower name(s): Property Address; City: State: Zip: Is the property for sale? Yes I No Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes fl No 0 Mailing Address (if different): City: Phone Numbers: Email: State:._.Zip: Home; Office; Cell: Other: # of people in household: How long? Mailing Address; City: Phone Numbers: Email: State: Zip: Home: Cell: Office: Other: # of people in household: How Jong? 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: $ Date of Last Payment: Primary Reason.for Default: Included Taxes & Insurance; Is the loan in Bankruptcy? Yes 0 No Cl If yes, provide names, location of court, case number & attorney: Assets Amo t nt Owed: Home: Other Real Estate: $ Retirement Funds; $ Investments: $ ._ Checking: $ Savings: $ Other: $ Automobile #1: Model: Amount owed: Automobile #2: Model: Yea'. Amount owed: Value: __.... . Other transportation (automobiles, boats, motorcycles); Model: Year Amount owed: Value Values $ Value: Year: Monthly Income Name of Employers; 1. 2. 3. Additional Income Description (not. wages): 1. _ monthly amount 2. _ monthly amount: — Borrower Pay Days: Co -Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2"4 Mortgage Utilities Car Pa ens Condo/Neig,h. Fees Auto Insurance Med. (not covered Other prop. payment Auto fuel/repairs Install. Loan Payment Cable TV Child Support/Alim. Spending Money t Day/Child Caretfuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes © No If yes, please provide the following information: Counseling Agency: Counselor: Phone.(Office): Fax. Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes D No If yes, please indicate the status of the application: Have you had any prior negotiations with your tender or lender's loan servicing company to resolve your delinquency? YesE No El If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name} Phone: Contact: I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options, lfWe understand that Uwe am/are under no obligation to use the services provided by the above named Borrower Signature Date Co -Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Al Proof of income 4 Past 2 bank statements 4 Proof of any expected income for the last 4S days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation r (hardship letter) V 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 THE PROTHONOTARY of Corot OFFICE QF THE `v'kERIFF 2 1 i Mt; 20 PM 1 1. CUMBERLAND COUNTY PENNSYLVANIA Loandepot.com, LLC vs. Debra Linn Case Number 2014-2397 SHERIFF'S RETURN OF SERVICE 05/16/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Debra Linn, 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 12 Walnut Lane, Lower Allen, Camp Hill, PA 17011. Residence is vacant and to this date the Camp Hill Postmaster has been unable to provide a good forwarding address. SHERIFF COST: $50.44 SO ANSWERS, May 16, 2014 RON2-R ANDERSON, SHERIFF (c) CountySuite Sherif(, Tcleosoft, Inc. K1V L Law Group, P.C. SUITE 5000—BNY INDEPENDENCE CENTER 701 MARKET STREET IN THE COURT OF COMMON PLEAS PHILADELPHIA,PA 19106-1532 OF Cumberland COUNTY (215)627-1322 ATTORNEY FOR PLAINTIFF CIVIL ACTION-LAW LOANDEPOT.COM,LLC ACTION OF MORTGAGE 425 Phillips Blvd FORECLOSURE Ewing,NJ 08618 Plaintiff Term No. 14-2397 vs. DEBRA LINN 12 Walnut Lane Camp Hill PA 17011 Defendant(s) ri c M w co C! Cs PRAECIPE TO REINSTATE COMPLAINT ��'- ms's` Kindly reinstate the Complaint in the above captioned matter. By: KML LAW ROUP,P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Jay E.Kivitz Pa. ID 26769 Jill P.Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 Alyk L. Oflazian Pa.ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff a4_tv IfIi.75 d � 7L/ 3 307.E&a Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 1 --THE PROTHONOTARY 2Gill i'�UG -8 F;nH:02 CU`IB RLAND COUNTY PENNSYLVANIA OFFICE OF TIE $,:H„RIFF Loandepot.com, LLC vs. Debra Linn Case Number 2014-2397 SHERIFF'S RETURN OF SERVICE 06/25/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and. inquiry for the within named Defendant to wit: Debra Linn, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 07/10/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of York County, the within named Defendant Debra Linn, not found. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, August 05, 2014 (C) CountySuite Sheriff, Teleosoft, Inc. RONR ANDERSON, SHERIFF Richard P Keuerleber Sheriff Michael S. Hose Chief Deputy, Operations SHERIFF'S OFFICE OF YORK COUNTY PETER J. MANGAN, ESQ. Solicitor Richard E Rice, II Chief Deputy, Administration LOANDEPOT.COM, LLC vs. Case Number DEBRA LINN 14-2397 CIVIL SHERIFF'S RETURN OF SERVICE 07/02/2014 07/10/2014 09:25 AM - DEPUTY BRANDON POLASH, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: DEBRA LINN AT 42 WOODED RUN DRIVE, DILLSBURG, PA 17019. THE DEFENDANT WAS FOUND TO HAVE MOVED. I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: DEBRA LINN, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM AS "NOT FOUND" AT 42 WOODED RUN DRIVE, DILLSBURG, PA 17019. SHERIFF COST: $40.77 SO ANSWERS, August 04, 2014 RICHARD P KEUERLEBER, SHE IFF Affirmed and subscribed to before me this 4TH day of AUGUST NOTARY 2014 COMMONWEAVIN Of PENNSYLVANIA Notarial Seal Sheila E. Cook, Notary Public City of York, York County My Commission Expires Feb. 1, 2017 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES (c) CountySuite Sheriff. Teleosoft, Inc. KML Law Group, P.C. SUITE 5000 – BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DEBRA LINN 12 Walnut Lane Camp Hill , PA 17011 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY. CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: KML LA GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Term No. 14-2397 Attorneys for Plaintiff CO 3732, —r" OM fi.1s CO/ 77-3 asciqzcl Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND ����� ^���K U���� ��- --' '-- '- - - -' ' ' 'r,' ,--. � �'- u�. ��. M� ° PAZ V-riRIP2 C/fl PE 2 2 Ail Li /u/l/ � u�.- ',u�� 'A�/� Loandepot.com, LLC vs. Debra Linn Case Number 2014-2397 SHERIFF'S RETURN OF SERVICE 08/18/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to witDebra Linn, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 08C25C2014 10:25 AM - The requested Notice of Residential Mortgage Foreclosure Diversion Programd Complaint in Mortgage Foreclosure returned by the Sheriff of York County, the within named Defendant Debra Linn, not found. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 09/16/2014 03:33 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person verified by a neighbor to be Lawrence Massey II, Boyfriend, (Lawrence Massey refused to give his idenity to the deputies) who accepted as "Adult Person in Charge" for Debra Linn at 199 Crain Drive, North PWidd|ebzn, Cadis(e, PA 17013. &urn . DAWN KELL, DEPUTY SHERIFF COST: $53.78 SO ANSWERS, September 18, 2014 RONRANDERSON, SHERIFF (c.) CountySuits Sheriff, Teleosoft, Inc. Richard P Keuerleber Sheriff Michael S. Hose Chief Deputy, Operations LOANDEPOT.COM, LLC vs. DEBRA LINN SHERIFF'S OFFICE OF YORK COUNTY PETER J. MANGAN, ESQ. Solicitor Richard E Rice, II Chief Deputy, Administration Case Number 14-2397 CIVIL 08/25/2014 08/27/2014 SHERIFF'S RETURN OF SERVICE 10:25 AM - DEPUTY TAYLOR ECK, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: DEBRA LINN AT 272 ORE BANK ROAD, APT. 2, DILLSBURG, PA 17019. THE ADDRESS WAS FOUND TO BE VACANT. I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: DEBRA LINN, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAMAS "NOT FOUND" AT 272 ORE BANK ROAD, APARTMENT 2, DILLSBURG, PA 17019, PROPERTY IS VACANT. NEW ADDRESS IS 199 CRAIN DRIVE, CARLISLE, PA 17013, CELL 717-991-8081. SHERIFF COST: $40.77 September 11, 2014 SO ANSWERS, MICHAEL S. HOS: "7ACTING SHERIFF FOR RICHARD P KEUERLEBER, SHERIFF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Lisa L, Thorpe, Notary Public City of York, York. County My Commission Expires Aug. 12, 2017 `M�IBER, PENNSYLVANIA ,SSi,CiATIon OF NOTARIES NOTARY Armed and subscribed to before me this 11TH day of SEPTEMBER , 2014 (c) Cou^lySuii€ Shcrlfl, KML Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DEBRA LINN 12 Walnut Lane Camp Hill , PA 17011 Plaintiff Defendants) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: Tenn No. 14-2397 KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 __Joshua L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff N) CA) ui 0 (3) � �1/. )Spol a1% a0)64 777036 g)/Y/S In the Court of Common Pleas of Cumberland County cs LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 VS. DEBRA LINN (Mortgagor(s) and Record Owner(s)) 12 Walnut Lane Camp Hill, PA 17011 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT rn -...1 CAD 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. Enter the Judgment in favor of Plaintiff and against DEBRA LINN by default for want of an Answer. Assess damages as follows: Debt Interest from 12/13/2014 to Date of Sale per diem at $399.92 Total (Assessment of Damages attached) $129,129.34 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 en days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: L GROUP C. Michael cKeever P.. ID 56129 Jay E. ivitz 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 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa ID 316160 Attorneys for Plaintiff AND NOW e . I :1 V I q , Judgment'is entered in favor of LOANDEPOT.COM, LLC and against DEBRA LINN by default for want of an Ahswer alit sessed in the $129,129.34 as per the above certification. Prothonotary *ffe.�!d aiy a NA&marled #3Jl(A? Rule of Civil Procedure No. 236 — Revised LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 DEBRA LINN (Mortgagors and Record Owner(s)) 12 Walnut Lane Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff vs. Defendant(s) No. 14-2397 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 - Deputy 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 131089 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: DEBRA LINN LINN, DEBRA 12 Walnut Lane Camp Hill, PA 17011 LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 Plaintiff Vs. DEBRA LINN (Mortgagor(s) and Record Owner(s)) 12 Walnut Lane Camp Hill , PA 17011 Defendant(s) TO: DEBRA LINN 12 Walnut Lane Camp Hill, PA 17011 DATE OF THIS NOTICE: November 20, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 14-2397 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 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 LAW GROUP, 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 131089FC 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: . DEBRA LINN LINN, DEBRA 199 Crain Drive Carlisle, PA 17013 LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 Plaintiff vs. DEBRA LINN (Mortgagor(s) and Record Owner(s)) 12 Walnut Lane Camp Hill , PA 17011 Defendant(s) TO: DEBRA LINN 199 Crain Drive Carlisle, PA 17013 DATE OF THIS NOTICE: November 20, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 14-2397 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 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 LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 7Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 1 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOANDEPOT.COM, LLC Plaintiff vs. DEBRA LINN NO. 14-2397 Defendant(s) 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): DEBRA LINN, has a last known residence of 199 Crain Drive, Carlisle, PA 17013. 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. Date l /4-4 By: ML LAW OUP,P.C. �i Michae cKeevKeever 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 Servicemennrs Civil Relief Act. Last Name: LINN First Name: DEBRA Middle Name: Active Duty Status As Of: Dec -15-2014 Results as of : Dec -15-2014 04:29:13 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - No , . NA NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .... - - - No- - NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA . No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 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: 20RAEA3E610BN60 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LOANDEPOT.COM, LLC 425 Phillips Blvd . Ewing, NJ 08618 vs. DEBRA LINN (Mortgagor(s) and Record owner(s)) 12 Walnut Lane Camp Hill, PA 17011 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 14-2397 ORDER FOR JUDGMENT Please enter Judgment in favor of LOANDEPOT.COM, LLC, and against DEB Answer in the above action within (20) days from the date of service of the Complla t ' the sum of $129,129.34. i LINN for failure to file an OUP, P.C. Mich. - Mc eever 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 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 and that the name(•, and last known address(es) of the Defendant(s) is/are DEBRA LINN, 199 Crain Drive Carlisle, PA 1.7013; By: ,,KM LAW GROUP, P.C. �l 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 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 08/01/2013 through 12/12/2014 Reasonable Attorney's Fee Late Charges Escrow Advance Property Inspection Recoverable Balance Pro Rata MIP/PMI AND NOW, this 14-2397/131089FC Bv: $119,975.31 $6,398.72 $1,650.00 $213.27 $414.23 $120.00 $195.00 $162.81 $129,129.34 /, KM LA G • IUP, P.C. Mi- i ael McKeever Pa. ID 56129 Ja 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 Salvatore Filippello Pa. ID 313 897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff day of . , 2014 damages are asse ed as a Pro Prothy PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSUI 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 LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DEBRA LINN Mortgagor(s) and Record Owner(s) 12 Walnut Lane Camp Hill, PA 17011 Plaintiff' Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 14-2397 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due } itaBSb-pci 0- .c-14 .c -l4 Interest from 12/13/2014 to Date of Sale per diem at $399.92 (Costs to be added) By: $129,129.34 KML AW GROUP, P.C. ' ` Mich. el 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 Salvatore Filippello Pa. ID 313897 a,asAlyk L. Oflazian Pa. ID 312912 �'• Jennifer Lynn Frechie Pa.. ID 316160 . Sl5 GL Attorneys for Plaintiff CL7g3?P (Zj 31y('9 bUr c 4ssu.41 N�l 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 12 Walnut Lane Camp Hill, PA 17011 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: /a By: KMLA GROUP, P.C. Mi ael 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 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff 2314 DEC 17 PO I: 14 CU SIE LANO COUNTY t °? ! VA' 14-2397 LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DEBRA LINN Mortgagor(s) and Record Owner(s) 12 Walnut Lane Camp Hill, PA 17011 Plaintiff Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 14-2397 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: LINN, DEBRA DEBRA LINN 199 Crain Drive Carlisle, PA 17013 Your house at 12 Walnut Lane, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, June 03, 2015,.at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $129,129.34 obtained by LOANDEPOT.COM, 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 LOANDEPOT.COM, 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. •' KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DEBRA LINN (Mortgagor(s) and Record Owner(s)) 12 Walnut Lane Camp Hill, PA 17011 Plaintiff Defendant(s) r :Li . IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 14-2397 AFFIDAVIT PURSUANT TO RULE 3129 LOANDEPOT.COM, 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: 12 Walnut Lane Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): DEBRA LINN 199 Crain Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: DEBRA LINN 199 Crain Drive Carlisle, PA 17013 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 12 Walnut Lane Camp Hill, PA 17011 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: /V,7/ By: KM LAW GROUP, P.C. e Mi6nael 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 Salvatore Filippello Pa. ID 313 897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Freebie Pa. ID 316160 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215)627-1322 Attomey for Plaintiff C`_ T E Po:0 11!0:.X -M';' 2311IDEC 17 P J 1:14 CU;13ERLAND COUNTY VAl A 14-2397 LOANDEPOT.COM, LLC 425 Philips Blvd Ewing, NJ 08618 vs. DEBRA LINN Mortgagor(s) and Record Owner(s) 12 Walnut Lane Camp Hill, PA 17011 Plaintiff Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 14-2397 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: LINN, DEBRA DEBRA LINN 199 Crain Drive Carlisle, PA 17013 Your house at 12 Walnut Lane, Camp Hill, PA 17011 is scheduled to be sold at Sheriff's Sale on Wednesday, June 03, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $129,129.34 obtained by LOANDEPOT.COM, 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 LOANDEPOT.COM, LLC, the back payments, late charges, costs and reasonable attorney's fees due. To fmd 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: _ 14-2397 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 Sheriffs 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 Cumberland County at 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 Cumberland County at 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 14-2397 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/consumers/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 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 131089FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. • kML Law Group, P.C. Suite 5000 — BNY Independence 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff :7' !l1. t';ti1Nj u1/1in. Center Z311i DEC 17 PO l: 114 CU 3E LI.d:D COUNTY PPRiNSYLVANIA LOANDEPOT.COM, LLC 425 Phillips Blvd Ewing, NJ 08618 vs. DEBRA LINN Mortgagor(s) and Record Owner(s) 12 Walnut Lane Camp Hill, PA 17011 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 14-2397 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: KM AW ROUP, P.C. Mi ael McKeever Pa. ID 56129 Ja 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 Salvatore Filippello Pa. ID 313 897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 12 Walnut Lane Camp Hill, PA 17011 SOLD as the property of DEBRA LINN TAX PARCEL #13-24-0797-039 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net LOANDEPOT.COM, LLC Vs. DEBRA LINN WRIT OF EXECUTION NO 14-2397 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $129,129.34 L.L.: $.50 Interest FROM 12/13/2014 TO DATE OF SALE PER DIEM AT $399.92 Atty's Comm: Due Prothy: $2.25 Atty Paid: $325.22 Other Costs: Plaintiff Paid: Date: 12/17/14 David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL MCKEEVER, 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. 56129