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14-3064
Supreme Court-of Pennsylvania Cour CommofiTleas . For Prothonotary Use Only: k vil"Cov h`eet ft CZT ✓1BK County Docket No: 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: S 9 Complaint ❑ Writ of Summons ❑Petition E ❑Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: PHH MORTGAGE Lead Defendant's Name: GARY L. GLESSNER CORPORATION F/K/A CENDANT MORTGAGE ,I, CORPORATION I Are money damages requested? El Yes 9 No Dollar Amount Requested: 1:1within arbitration limits U (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes 9 No A Name of Plaintiff/Appellant's Attorney: Michael Dingerdissen,Esq Id.No.317124,Phelan Hallinan,LLP ❑ Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑Intentional ❑ Buyer Plaintiff Administrative Agencies ❑Malicious Prosecution ❑Debt Collection: Credit Card ❑Board of Assessment ❑Motor Vehicle ❑Debt Collection: Other ❑Board of Elections ❑Nuisance ❑Dept.of Transportation ❑Premises Liability ❑ Statutory Appeal: Other ❑Product Liability(does not S include mass tort) ❑Employment Dispute: ❑ Slander/Libel/Defamation Discrimination E ❑Other: ❑Employment Dispute: Other ❑Zoning Board C ❑ Other: T I MASS TORT ❑Other: O ❑Asbestos N ❑Tobacco ❑Toxic Tort-DES ❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑Toxic Waste ❑Ejectment ❑ Common Law/Statutory Arbitration B ❑Other: ❑Eminent Domain/Condemnation ❑Declaratory Judgment ❑Ground Rent ❑Mandamus ❑Landlord/Tenant Dispute ❑Non-Domestic Relations ® Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑Quo Warranto ❑Dental ❑Partition ❑Replevin ❑Legal ❑ Quiet Title ❑ Other: ❑Medical ❑ Other: ❑ Other Professional: Pa.R.C.P, 205.5 Updated 01/01/2011 VS PHELAN HALLINAN,LLP Michael Dingerdissen,Esq.,Id.No.317124 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia,PA 19103 Michael.Dingerdissen@phelanhallinan.com 215-563-7000 PHH MORTGAGE CORPORATION F/K/A CENDANT MORTGAGE CORPORATION COURT OF COMMON PLEAS 2001 BISHOPS GATE BLVD MOUNT LAUREL,NJ 08054 CIVIL DIVISION Plaintiff TERM jq -:�Duq NO. 1� I GARY L. GLESSNER 9 FAR VIEW AVENUE CUMBERLAND COUNTY CARLISLE,PA 17013-9606 LORI L. GLESSNER 9 FAR VIEW AVENUE CARLISLE,PA 17013-9606 Defendants CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE �a File#: 927907 1. Plaintiff is PHH MORTGAGE CORPORATION F/K/A CENDANT MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD MOUNT LAUREL,NJ 08054 2. The name(s)and last known address(es) of the Defendant(s) are: GARY L.GLESSNER 9 FAR VIEW AVENUE CARLISLE,PA 17013-9606 LORI L.GLESSNER 9 FAR VIEW AVENUE CARLISLE,PA 17013-9606 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/11/2004 GARY L. GLESSNER and LORI L. GLESSNER made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF,which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Book 1869,Page 2076. Said Mortgage was modified as set forth in a modification agreement recorded December 13, 2010, in Instrument No. 201036779. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/01/2013 and each month thereafter are due and unpaid, and by the terms of said mortgage,upon failure of Mortgagor to make such payments after a date specified File#: 927907 a by written notice sent to Mortgagor,the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 05/02/2014: Principal Balance $105,020.89 Interest $2,106.11 05/01/2013 through 05/02/2014 Late Charges $73.34 Property Inspections $45.00 Escrow Deficit $2,734.47 TOTAL $109,979.81 7. Plaintiff is not seeking a judgment of personal liability(or an in personam judgment) against the Defendant(s) in the Action;however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s)has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974,Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s)has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File#: 927907 WHEREFORE,Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $109,979.81,together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN,LLP 0 h )V Y Im j k By: Michael Dingerdissen, Esq., Id.No.317124 Attorney for Plaintiff File#: 927907 VERIFICATION William Bellows Assistant Vice President hereby states that he/she is PHH MORTGAGE CORPORATION, Plaintiff in this matter,that he/she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: s"' Name: William Bellows Title: Assistant Vice President PHH MORTGAGE CORPORATION File#: 927907 Name: GLESSNER File#: 927907 R FORM 1 IN THE COURT OF COMMON PLEAS PHH MORTGAGE CORPORATION F/K/A OF CUMBERLAND COUNTY,PENNSYLVANIA CENDANT MORTGAGE CORPORATION Plaintiff(s) ' GARY L.GLESSNER LORI L. GLESSNER ='=, Defendant(s) , ./� livil 7 CD C NOTICE OF RESIDENTIAL MORTGAGE FORECLOSE 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 aloe to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference. First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at(717)2439400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date.During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal canbe prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and a Request for Conciliation Conference with the Court,which must be filed with the 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 arrangenents with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference.It is not necessary for you to contact MidPern Legal Service for the appointment of a legal representative.However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf.If you and your lawyer complete a financial woksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed within sixty(60)days of the service upon you of the foreclosure complaint.If you do so and a conciliation onference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: VIM ALA Auu _ Date Michael Dingerdissen,Esq.,Id.No.317124 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: CUSTOM F R/PRI MARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address(if different): City: State:--Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? Mailing Address: City: State:--Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes&Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes❑ No ❑ If yes, provide names, location of court, case number&attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Other transportation (automobiles,boats,motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description(not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2° Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP) assistance? Yes ❑ No ❑ If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes❑ No❑ If yes,please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6 Listing agreement(if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages,you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File#: 927907 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson FILL J—Cl F Hi Sheriff;f THE PRO 1 iCl.a��" k�titb, ofna�$rrya t ri: Jody S Smith , e tg1y JUti —14 Fid 3: I Chief Deputy - Richard W Stewart "" rc CUMBERLAND COUNTY Solicitor PENNSYLVANIA O //iCE OF T4tE $-±!.RIF.= PHH Mortgage Corporaion vs. Gary L Glessner (et al.) Case Number 2014-3064 SHERIFF'S RETURN OF SERVICE 05/23/2014 03:20 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Lori L Glessner outside the Courthouse in the first block of East High Street, Carlisle, PA 17013. g 161_6 DAWN KELL, DEPUTY 05/23/2014 08:04 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Gary L Glessner at 9 Far View Avenue, North Middleton, Carlisle, PA 17013 SHERIFF COST: $50.78 SO ANSWERS, May 27, 2014 (c) CountySu ,e Shay iff: Te:'eosoft, Inc, RONNY R ANDERSON, SHERIFF r PHH MORTGAGE CORPORATION : IN THE COURT OF COMMON PLEAS OF F/K/A CENDANT MORTGAGE : CUMBERLAND COUNTY, PENNSYLVANIA CORPORATION, Plaintiff v. : CIVIL ACTION - LAW L ; dy � -- i r GARRY L. GLESSNER : 14-3064 CIVIL TERM rn �_ r-' ; LORI L. GLESSNER, = 2rn , --, 3 7 Defendants __,<'9' --s c.,3 C-, `+. : (..7) PRAECIPE TO ENTER APPEARANCE •�u. To the Prothonotary: Please enter my appearance on behalf of the Defendant, Lori L. Glessner, in the above captioned case. Date: June 27, 2014 Respectfully Submitted, IRWIN & McKNIGHT, P.C. Atik, Douglas G. iller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: MICHAEL DINGERDISSEN, ESQUIRE 1617 JFK BOULEBARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Date: June 27, 2014 IRWIN & McKNIGHT, P.C. Douglas . Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 PHH MORTGAGE CORPORATION F/K/A CENTANT MORTGAGE CORPORATION v. GARY L. GLESSNER 9 Far View Ave. Carlisle, PA 17013 LORI L. GLESSNER 9 Far View Ave. Carlisle, PA 17013 Plaintiff Defendants FORM 3 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 2014-3064 CIVIL TERM REQUEST FOR CONCILIATION CONFERENCE 't33 ar z' Zr-- I c:).85:;1 _ Itz .I Pursuant to the Administrative Order dated February 28, 2012, governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendants are the owners of the real property which is the subject of this mortgage foreclosure action; 2. Defendants live in the subject real property, which is Defendant's primary residence; 3. Defendants have been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and have taken all of the steps required in that Notice to be eligible to participate in a court -supervised conciliation conference. The undersigned verifies that the statements .made herein are true and correct. I understand that false statements are made subject to -the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authoriXies. George F. Douglas, III, Esq. Defendant's Counsel/Appointed. Legal Rep tive Gary L. G = sner, De en. ant —1 (Icr Date Date Lori L. Glessner, Defendant Date CERTIFICATE OF SERVICE I, George F. Douglas, III, Esq., of Salzmann Hughes, P.C., hereby certify that a copy of the foregoing document was served this date by depositing the same via United States mail, first class mail, postage prepaid, and addressed as follows: Michael Dingerdissen, Esq. Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 William Bellows Asst. Vice President PHH Mortgage Corporation 2001 Bishops Gate Blvd. Mount Laurel, NJ 08054 Date: '1 /7_, rkt By: • eorge F. Douglas, III Esquire PHH MORTGAGE CORPORATION F/K/A CENTANT MORTGAGE CORPORATION Plaintiff v. GARY L. GLESSNER 9 Far View Ave. Carlisle, PA 17013 LORI L. GLESSNER 9 Far View Ave. Carlisle, PA 17013 Defendants FORM 4 • IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA • • NO. 2014-3064 CIVIL TERM • • CASE MANAGEMENT ORDER AND NOW, this day of , 2014, the defendant/borrower in the above -captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court -supervised Conciliation Conference on at .M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled Conciliation Conference. BY THE COURT J. CERTIFICATE OF SERVICE I, George F. Douglas, III, Esq., of Salzmann Hughes, P.C., hereby certify that a copy of the foregoing document was served this date by depositing the same via United States mail, first class mail, postage prepaid, and addressed as follows: Michael Dingerdissen, Esq. Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 William Bellows Asst. Vice President PHH Mortgage Corporation 2001 Bishops Gate Blvd. Mount Laurel, NJ 08054 Date: "1 (24 1 itt By: 644(;ig-e45FL.Douglas, IIItc7;;?'")-L- PHH MORTGAGE CORPORATION F/K/A CENDANT MORTGAGE CORPORATION, Plaintiff v. GARRY L. GLESSNER LORI L. GLESSNER, Defendants : IN THE COURT OF COMMON PI<A$„4)F` i : CUMBERLAND COUNTY, PENN L NIA rrivo (,flr N : ;e.;z .0c7Z, IV =-_;� : CIVIL ACTION - LAW „ccs TTr+" C., .- --3 C> : 14-3064 CIVIL TERM REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned, hereby certifies as follows: 1. Defendants are the owners of the real property which is the subject of this mortgage foreclosure action; 2. Defendant Gary L. Glessner lives in the subject real property, which is Defendant's primary residence; 3. Defendant Gary L. Glessner has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court -supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities Signat Legal re of 1 efendant'`s Counsel/Appointed Date pre ntative Signa "ure of Defendant 7/a (kg //y Date Signature of Defendant Date CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Date: July 22, 2014 MICHAEL DINGERDISSEN, ESQUIRE 1617 JFK BOULEBARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 GARY L. GLESSNER C/O JANE ADAMS, ESQUIRE 17 WEST SOUTH STREET CARLISLE, PA 17013 IRWIN & McKNIGHT, P.C. Douglas' G. Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion. Program,,,. Financial Worksheet Date 7/21/14 rn� Cumberland County Court of Common Pleas Docket # 14-3064 Zfil -0' :0 -u o—n To complete your request for hardship assistance, lender must consider your circumstarfo dtterm possible options while working with your counseling agency. Please provide the following infoiaticit to 5r) the best of your knowledge: *< BORROWER REQUEST FOR HARDSHIP ASSISTANCE CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Home: Cell: irrn 111 We* t)i j State: (:) Zip: \; ?,OL Yes ❑ No [r Listing date: Price: $ CC w`- M -10 , -, c,, Realtor Phone: LL - Yes ( No ❑ Mat lelv. 6-165 n � alaVeu- State: Zip: Email: # of people in household: Office: Other: 3 How long? /1 C(/5. CO -BORROWER Mailing Address: City: Phone Numbers: Email: State: Zip: Home: Cell: Office: Other: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: P Type of Loan: y,Q Loan Number: ©p (C.1 Second Mortgage Lender: Type of Loan: Loan Number: ate You Closed Your Loan: (,oUt!dfl1A0 Total Mortgage Payments Amount: $ 170 3 C/ Included Taxes & Insurance: '1 Date of Last Payment: ID 13cy/3 Prima Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ' If yes, provide names, location of court, case number & attorney: Assets Amount Owed: I Value: Home: $1 bi BVI 11 $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: SOA/UA-ice-N.._ Year: d 3 Amount owed: Value: 7 Automobile #2: Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income �J �^ �j p. Naie �f Fpmploye r r , /Monthly Gross l ` VJ , /Monthly Net `3 /O 4 (/ 2. /I X115 J` /� 1� Monthly Gross Monthly Net (oef y� 3. Monthly Gross Monthly Net Additional Income Description (not wages): monthly amount: 2. monthly amount: Borrower Pay Days: 1. Co -Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 6)75' - 2nd Mortgage Utilities — Car Payment(s) Condo/Neigh. Fees .:9 Auto Insurance Med. (not covered) Auto fuel/repairs ,WD,' 2(22) ' Other prop. payment Install. Loan Payment Cable TV / itli`- Child Support/Alim. Spending Money la,'" Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No 0 If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: G., ( i ni a ( coi? Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No Et If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No E If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): P R -Ek (Y)( .e Phone: { 7J) -- yq . Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, Lb IA , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the counseling services provided by the above named Co -Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6 Listing agreement (if property is currently on the market) I am divorced and have not lived on the property since July 2010. Gary Glessner lives at 9 Far View Ave Carlisle, PA 17013. He was court ordered to sell the property. At this time he does not have the property listed He refuses to make the monthly mortgage payments. I am on my own and have to pay rent as I can not afford to pay rent and a mortgage. Nell's Inc. 600 Arsenal Road York, PA 17402 Employee Number: 17392 Federal Marital Status: Single State Marital Status: Not Used Week Beginning: 7/7/2014 Hourly Rate: 11.30 Work Area.: FRI N WB Exemptions: 0 Exemptions: 0 Week Ending: 7/13/2014 ...<''. ',,...,...c,_;; EARNINGS,?:?:..7:::!".:*1 HOURS THIS PERIOD YEAR TO DATE , Call In Pay 110.66 0.00 4.00 Regular Night Medicare EE Withheld 0.00 5.12 Sunday 7.48 0.00 2,405.42 Time Entry Wages 13.56 153.24 4,355.05 Vacation 8.00 90.40 90.40 Worked Holiday 0.00 56.79 GROSS PAY 243.64 6,916.78 DEPOSIT ACTIVITY Bank arpe : , ,Account• ,,,,pf Amount Members 1st FCU Checking 192.12 Earnings Statement ADVICE NUMBER: 54044947 Lori L Glessner ADVICE DATE: 7/18/2014 ____--):,.---,,,r,A,7c1,.,..c, .-fAXES::4Nci:.PEDUCTIgN§A:'..11-11S'PE1319DI ,I•y;,;)r-7,,,,-r?-„,-,7,:0,-,,,,wz ,,, "TO DATE City Withheld 3.90 110.66 FIT Withheld 21.33 420.84 Medicare EE Withheld 3.53 100.29 SIT Withheld 7.48 212.36 SS EE Withheld 15.11 428.84 SUI Withheld 0.17 4.84 TOTAL DEDUCTIONS 51.52 1,277.83 03495'' 'Firvpd maket:pares!,,andidendiyveperatevrepeatb 's ProSoft Paystub Reprint Generated: 07-21-2014 1 11:46:56 AM Carlisle Area School District SSN XXX -XX -4278 Name: LORI L GLESSNER Dept: S1 Loc: 820 Emp # 284 Check #: D0147487 Earnings This Pay YTD Amount SEC -L-3 Salary $935.25 $12,830.25 Incent Pay $37.31 $522.34 Extra Pay $42.70 Total Gross Deduction(excl direct deposit) Net Pay $972.56 $283.24 $689.32 $13,395.29 $3,900.89 $9,494.40 Deductions This Pay YTD Amount FIT (M 0) $53.63 $730.46 Medicare $13.51 $185.86 Social Security $57.75 $794.89 State Tax - Pennsylvania $28.60 $393.53 PA Unemployment $.68 $9.42 LS Tax -Carlisle Bo $2.00 $28.00 Local Wage Tax - 1.7000% $15.84 $217.94 Retirement -TD -7.5% $70.14 $965.53 DDN Deposit (CK) $689.32 $9,494.40 M 0uL-26 pdyb $41.09 $575.26 Sick Day: 56.37 Vacation Day: 23 Personal Day: 1 Professional Da: 0 Non -salary pay period is 6/16-27/14. Absences updated through 6/30/14 CHECK DATE: 7/11/2014 AMOUNT: $0.00 D0147487 Direct Deposit Amount $ 689.32 7/11/2014 LORI L GLESSNER 116 SALEM CHURCH ROAD MECHANICSBURG PA 17050-2834 VOID Carlisle Area School District 623 West Penn Street Carlisle, PA 17013-2239 Phone: (717)240-6800 Fax: (717)240-6898 ProSoft Paystub Reprint Generated: 07-21-2014 1 11:46:58 AM Transaction History Date Description Page 1 of 8 Amount Balance Check# 07/20/14 12:41 PM Withdrawal: CHECK CARD FIVE BELOW 113 CAMP HILL PA TRANSACTION DATE 07/19/14 Department Stores -$6.36 $258.64 07/19/14 08:48 PM Withdrawal: CHECK CARD KWIK FILL MECHANICSBURG PA Date 07/18/14 2 4200001377 3 5542 %% Card 15 #13012 Automotive $50.00 $265.00 07/1 9/14 06:01 AM Withdrawal: CHECK CARD OLLIES BARGAIN OUTLET 003 MECHANICSBURG PA Date 07/18/14 2 4200732001.8 5310 %% Card 15 #13012 Department Stores -$22.06 $315.00 07/18/14 05:02 AM Withdrawal: CHECK CARD WAL-MART #1886 MECHANICSBURG PA Date 07/17/14 2 4199400000 5 5411 %% Card 15 #13012 Supermarkets -$18.13 $337.06 07/18/14 04:09 AM Withdrawal: CHECK CARD SMARTMED INC CARLISLE PA Date 07/17/14 2 4198001238 1 5912 %% Card 15 #13012 Retail -$12.92 $355.19 07/18/14 02:00 AM Withdrawal: CHECK CARD VINNY'S PIZZA CARLISLE PA Date 07/17/14 2 4199200196 3 5812 %% Card 15 #13012 Restaurants -$6.36 $368.11 07/18/14 12:55 AM Deposit: NELLS, INC. TYPE: PAYROLL ID: 1232251195 CO: NELLS, INC. ACH PPD Prearranged Payment or Deposit ACH transaction $192.12 $374.47 07/17/14 11:24 PM Draft: 001116 - $100.00 $182.35 001116 07/17/14 06:29 AM Withdrawal: CHECK CARD ORTHOPEDIC INSTITUTE OF CAMP HILL PA Date 07/16/14 2 4198200799 7 8011 /o /o Card 15 #13012 Health Services -$20.00 $282.35 07/16/14 11:15 PM Draft: 001115 Processed Check - AT&T SERVICES TYPE: CHECKPAYMT ID: 1742782655 ACH ARC -Accounts Receivable Entry ACH transaction - $302.35 $293.09 001115 07/15/14 11:24 PM Draft: 001114 - $144.82 $595.44 001114 07/15/14 07:45 AM Deposit: PA-SCDU TYPE: CHLD SUPPT ID: 2236003113 CO: PA-SCDU ACH PPD Prearranged Payment or Deposit ACH transaction $234.92 $740.26 07/13/14 06:30 AM Withdrawal: CHECK CARD BLUE MOUNTAIN VINEYARD NEW TRIPOLI PA Date 07/12/14 2 4194207555 9 7991 %% Card 15 #13012 Entertainment/Recreational Services -$5.30 $505.34 07/13/14 06:30 AM Withdrawal: CHECK CARD BLUE MOUNTAIN VINEYARD NEW TRIPOLI PA Date 07/12/14 2 4194207555 8 7991 %% Card 15 #13012 Entertainment/Recreational Services -$24.38 $510.64 https://myonline.memberslst.org/PrinterFriendly.aspx 7/21/2014 Transaction History Date Description Page 2 of 8 Amount Balance Check# 07/12/14 08:10 PM Withdrawal: CHECK CARD SUNOCO 0363902805 MECHANICSBURG PA Date 07/11/14 2 4193000470 8 5542 %% Card 15 #13012 Automotive -$66.38 $535.02 07/12/14 07:55 PM Withdrawal: CHECK CARD SHEETZ 00005181 MECHANICSBURG PA Date 07/11/14 2 4193498642 8 5542 %% Card 15 #13012 Automotive -$20.16 $601.40 07/12/14 06:02 AM Withdrawal: CHECK CARD AMELIA'S GROCERY OU MECHANICSBURG PA Date 07/11/14 2 4192720021 8 5411 %% Card 15 #13012 Supermarkets -$76.73 $621.56 07/12/14 04:42 AM Withdrawal: CHECK CARD KARNS QUALITY FOODS MECHANICSBURG PA Date 07/11/14 2 4192720004 3 5411 %% Card 15 #13012 Supermarkets -$48.64 $698.29 07/11/14 08:50 PM Withdrawal: CHECK CARD LOWES #01710* CARLISLE PA Date 07/11/14 2 4192000040 0 5200 %% Card 15 #13012 Home Improvement -$21.96 $746.93 07/11/14 08:52 AM Withdrawal by ATM: #006750 MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG PA %% Card 15 #13012 -$20.00 $768.89 07/11/14 12:43 AM Deposit Transfer: From Share 0000 $550.00 $788.89 07/11/14 12:43 AM Deposit: NELLS, INC. TYPE: PAYROLL ID: 1232251195 CO: NELLS, INC. ACH PPD - Prearranged Payment or Deposit ACH transaction $205.97 $238.89 07/10/14 04:14 PM Withdrawal: CHECK CARD KWIK FILL MECHANICSBURG PA Date 07/09/14 2 4191000652 8 5542 %% Card 15 #13012 Automotive -$15.03 $32.92 07/09/14 10:25 PM Withdrawal: CHECK CARD HESS 38252 CARLISLE PA Date 07/08/14 2 4190710004 5 5542 %% Card 15 #13012 Automotive -$30.03 $47.95 07/09/14 05:37 AM Withdrawal: CHECK CARD AMELIA'S GROCERY OU MECHANICSBURG PA Date 07/08/14 2 4189720018 7 5411 %% Card 15 #13012 Supermarkets -$22.02 $77.98 07/08/14 11:23 PM Draft: 001112 -$20.00 $100.00 001112 07/08/14 06:38 PM Withdrawal: CHECK CARD STATE FARM INSURANCE 800-956-6310 STATE FA Date 07/08/14 2 4189004070 9 6300 %% Card 15 #13012 Finance/insurance/Real Estate $232 19 $120.00 07/08/14 10:15 AM Deposit Transfer: From Share 0001 $90.00 $352.19 07/08/14 05:42 AM Withdrawal: CHECK CARD NELL'S - WALNUT BOT CARLISLE PA Date 07/07/14 2 4188720004 4 5411 %% Card 15 #13012 Supermarkets -$17.29 $262.19 07/07/14 11:24 PM Draft: 001110 -$36.00 $279.48 001110 https://myonline.memberslst.org/PrinterFriendly.aspx 7/21/2014 , Transaction History Date Description Page 3 of 8 Amount Balance Check# 07/07/14 11:15 PM Draft: 001113 Processed Check - AMAZON TYPE: CHECK PYMT ID: 0818200461 ACH ARC -Accounts Receivable Entry ACH transaction -$50.00 $315.48 001113 07/06/14 04:39 AM Withdrawal: CHECK CARD WINE & SPIRITS 2110 CARLISLE PA Date 07/05/14 2 4187625000 6 5921 %% Card 15 #13012 Retail -$21.18 $365.48 Lr 07/05/14 05:30 AM Withdrawal: CHECK CARD SWEET FROG 200081 MECHANICSBURG PA Date 07/04/14 2 4186286333 1 5814 %% Card 15 #13012 Restaurants -$11.27 $386.66 07/05/14 05:25 AM Withdrawal: CHECK CARD NELL'S - WALNUT BOT CARLISLE PA Date 07/04/14 2 4185720004 8 5411 %% Card 15 #13012 Supermarkets -$7,41 $397.93 07/05/14 05:22 AM Withdrawal: CHECK CARD SHEETZ 00001958 MECHANICSBURG PA Date 07/04/14 2 4185498582 2 5542 %% Card 15 #13012 Automotive -$25.09 $405.34 07/04/14 01:07 AM Withdrawal: CHECK CARD PPG PGH PAINTS 9973 CARLISLE PA Date 07/02/14 2 4184490001 5 5231 %% Card 15 #13012 Home Improvement -$35.66 $430.43 07/03/14 01:00 AM Deposit: NELLS, INC. TYPE: PAYROLL ID: 1232251195 CO: NELLS, INC. ACH PPD- Prearranged Payment or Deposit ACH transaction $189.68 $466.09 07/02/14 11:14 PM Withdrawal: COMENITY PAY NS TYPE: WEB PYMT ID: 1133163498 DATA: 800-395-5714 CO: COMENITY PAY NS ACH WEB -Internet Initiated Entry ACH transaction -$54.02 $276.41 07/01/14 08:01 AM Deposit: PA-SCDU TYPE: CHLD SUPPT ID: 2236003113 CO: PA-SCDU ACH PPD- Prearranged Payment or Deposit ACH transaction $234.92 $330.43 07/01/14 06:19 AM Withdrawal: CHECK CARD NELL'S - WALNUT BOT CARLISLE PA Date 06/30/14 2 4181720004 4 5411 %% Card 15 #13012 Supermarkets -$4.54 $95.51 07/01/14 04:49 AM Withdrawal: CHECK CARD WINE & SPIRITS 2110 CARLISLE PA Date 06/30/14 2 4182625000 0 5921 %% Card 15 #13012 Retail -$19.07 $100.05 $117.32 06/30/14 10:13 PM Withdrawal: CHECK CARD PILOT Carlisle PA Date 06/30/14 0 4182335267 2 5542 %% Card 15 #13012 Automotive -$20.06 06/30/14 12:09 PM Withdrawal: CHECK CARD WM SUPERCENTER #2574 CARLISLE PA Date 06/29/14 2 4181400143 0 5411 %% Card 15 #13012 Supermarkets -$42.62 $137.38 06/30/14 12:03 AM Deposit: Swipe 5 Rebate $1.80 $119.12 06/28/14 11:48 AM Deposit Transfer: From Share 0000 $180.00 $180.00 https://myonline.memberslst.org/PrinterFriendly.aspx 7/21/2014 Transaction History • Date Description Page 4 of 8 Amount Balance Check# 06/28/14 06:18 AM Withdrawal: CHECK CARD KARNS QUALITY FOODS MECHANICSBURG PA Date 06/27/14 2 4178720004 2 5411Card 15 #13012 %% Supermarkets -$50.84 $0.00 06/28/14 05:36 AM Withdrawal: CHECK CARD AMELIA'S GROCERY OU MECHANICSBURG PA Date 06/27/14 2 4178720021 0 5411 %% Card 15 #13012 Supermarkets -$88.69 $50.84 ' 06/27/14 11:22 PM Draft: 001108 - $500.00 $139.53 001108 06/27/14 11:22 PM Deposit Transfer: From Share 0000 $219.53 $639.53 06/27/14 11:22 PM Draft: 001107 - $500.00 $420.00 001107 06/27/14 06:29 PM Withdrawal: CHECK CARD THE HOME DEPOT 4120 MECHANICSBURG PA Date 06/26/14 2 4178010181 3 5200 /o /o Card 15 #13012 Home Improvement -$22.24 $920.00 06/27/14 12:40 AM Deposit Transfer: From Share 0000 $550.00 $942.24 06/27/14 12:40 AM Deposit: NELLS, INC. TYPE: PAYROLL ID: 1232251195 CO: NELLS, INC. ACH PPD- Prearranged Payment or Deposit ACH transaction $197.08 $392.24 06/25/14 10:23 PM Withdrawal Adjustment: Credit Voucher KMART 4275 MECHANICSBURG PA Date 06/24/14 7 4176709000 8 5310 %% Card 15 #13012 Department Stores $25.98 $195.16 06/25/14 06:18 AM Withdrawal: CHECK CARD SMARTMED INC CARLISLE PA Date 06/24/14 2 4175001812 2 5912 %% Card 15 #13012 Retail -$18.57 $169.18 06/25/14 05:57 AM Withdrawal: CHECK CARD NELL'S - WALNUT BOT CARLISLE PA Date 06/24/14 2 4175720004 7 5411 %% Card 15 #13012 Supermarkets -$14.08 $187.75 06/25/14 05:36 AM Withdrawal: CHECK CARD SHEETZ 00005181 MECHANICSBURG PA Date 06/24/14 2 4175498489 8 5542 %% Card 15 #13012 Automotive -$15.02 $201.83 06/24/14 03:28 PM Withdrawal: CHECK CARD PILOT Carlisle PA Date 06/24/14 1 4175723093 9 5542 %% Card 15 #13012 Automotive -$30.00 $216.85 06/23/14 02:43 PM Withdrawal: CHECK CARD FIRE MTN #2465 MECHANICSBURG PA Date 06/22/14 2 4174100370 1 5814 %% Card 15 #13012 Restaurants -$40.12 $246.85 06/22/14 02:12 PM Withdrawal: CHECK CARD WEGMANS #45 MECHANICSBURG PA Date 06/21/14 2 4173100487 1 5411 %% Card 15 #13012 Supermarkets -$19.06 $286.97 06/22/14 02:12 PM Withdrawal: CHECK CARD WEGMANS #45 MECHANICSBURG PA Date 06/21/14 2 4173100487 8 5411 %% Card 15 #13012 Supermarkets -$6.09 $306.03 https://myonline.memberslst.org/PrinterFriendly.aspx 7/21/2014 Transaction History Date Description Page 5 of 8 Amount Balance Check# 06/22/14 03:56 AM Withdrawal: CHECK CARD WM SUPERCENTER #1886 MECHANICSBURG PA Date 06/21/14 2 4173400161 4 5411 %% Card 15 #13012 Supermarkets -$15.84 $312.12 06/21/14 10:02 PM Withdrawal: CHECK CARD KMART 4275 MECHANICSBURG PA Date 06/20/14 2 4172709000 9 5310 %% Card 15 #13012 Department Stores -$23.10 $327.96 06/21/14 10:02 PM Withdrawal Adjustment: Credit Voucher KMART 4275 MECHANICSBURG PA Date 06/20/14 7 4172709000 3 5310 %% Card 15 #13012 Department Stores $10.60 $351.06 06/21/14 02:24 PM Withdrawal: CHECK CARD WEGMANS #45 MECHANICSBURG PA Date 06/20/14 2 4172100486 3 5411 %% Card 15 #13012 Supermarkets -$15.88 $340.46 06/21/14 06:02 AM Withdrawal: CHECK CARD AMELIA'S GROCERY OU MECHANICSBURG PA Date 06/20/14 2 4171720021 4 5411 %% Card 15 #13012 Supermarkets -$40.97 $356.34 06/21/14 05:58 AM Withdrawal: CHECK CARD OLLIES BARGAIN OUTLET 003 MECHANICSBURG PA Date 06/20/14 2 4172731721 3 5310 %% Card 15 #13012 Department Stores -$8.46 $397.31 06/20/14 04:00 PM Withdrawal: CHECK CARD KWIK FILL MECHANICSBURG PA Date 06/19/14 2 4171001467 9 5542 %% Card 15 #13012 Automotive -$40.00 $405.77 06/20/14 01:40 PM Withdrawal: CHECK CARD FIVE BELOW 113 CAMP HILL PA Date 06!19/14 2 4171000769 9 5310 /o /o Card 15 #13012 Department Stores -$10.29 $445.77 06/20/14 04:43 AM Withdrawal: CHECK CARD WINE & SPIRITS 2106 MECHANICSBURG PA Date 06/19/14 2 4171625000 4 5921 %% Card 15 #13012 Retail -$13.77 $456.06 06/20/14 12:40 AM Deposit: NELLS, INC. TYPE: PAYROLL ID: 1232251195 CO: NELLS, INC. ACH PPD - Prearranged Payment or Deposit ACH transaction $187.77 $469.83 06/19/14 03:48 PM Withdrawal: CHECK CARD KWIK FILL MECHANICSBURG PA Date 06/19/14 2 4170001386 8 5542 %% Card 15 #13012 Automotive -$20.19 $282.06 06/19/14 11:58 AM Withdrawal by ATM: #006864 MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG PA %% Card 15 #13012 -$80.00 $302.25 06/19/14 02:48 AM Withdrawal: CHECK CARD RED ROBIN 338 CARLISLE PA Date 06/18/14 2 4170104008 6 5812 %% Card 15 #13012 Restaurants -$28.14 $382.25 06/17/14 11:22 PM Draft: 001109 -$42.80 $410.39 001109 https://myonline.memberslst.org/PrinterFriendly.aspx 7/21/2014 Transaction History Date Description Page 6 of 8 Amount Balance Check# 06/17/14 07:44 AM Deposit: PA-SCDU TYPE: CHLD SUPPT ID: 2236003113 CO: PA-SCDU ACH PPD - Prearranged Payment or Deposit ACH transaction $234.92 $453.19 06/17/14 05:32 AM Withdrawal: CHECK CARD AMELIA'S GROCERY OU MECHANICSBURG PA Date 06/16/14 2 4167720017 5 5411 %% Card 15 #13012 Supermarkets -$38.13 $218.27 06/17/14 05:24 AM Withdrawal: CHECK CARD KARNS QUALITY FOODS CARLISLE PA Date 06/16/14 2 4167720003 7 5411 %% Card 15 #13012 Supermarkets -$13.29 $256.40 06/16/14 09:36 AM Withdrawal: CHECK CARD ALFREDO PIZZA AND RISTORA CARLISLE PA Date 06/15/14 2 4166001134 7 5812Card 15 #13012 %% Restaurants -$6.19 $269.69 06/15/14 10:17 PM Withdrawal: CHECK CARD KMART 4275 MECHANICSBURG PA Date 06/14/14 2 4166709000 1 5310 %% Card 15 #13012 Department Stores -$66.19 $275.88 06/15/14 03:14 PM Withdrawal: CHECK CARD ROSS STORES #1007 HAMPDEN TWP PA Date 06/14/14 2 4166004032 7 5310 %% Card 15 #13012 Department Stores -$33.67 $342.07 06/15/14 03:59 AM Withdrawal: CHECK CARD WM SUPERCENTER #1886 MECHANICSBURG PA Date 06/14/14 2 4166400176 6 5411 %% Card 15 #13012 Supermarkets -$75.60 $375.74 06/14/14 06:21 AM Withdrawal: CHECK CARD WINE & SPIRITS 2110 CARLISLE PA Date 06/13/14 2 4165625000 1 5921Card 15 #13012 %% Retail $21.18 $451.34 06/14/14 04:51 AM Withdrawal: CHECK CARD SHEETZ 00001958 MECHANICSBURG PA Date 06/13/14 2 4164498392 8 5542 /o /o Card 15 #13012 Automotive -$25.00 $472.52 06/13/14 06:36 PM Withdrawal: CHECK CARD STATE FARM INSURANCE 800-956-6310 STATE FA Date 06/13/14 2 4164004069 6 6300 %% Card 15 #13012 Finance/Insurance/Real Estate - $240.71 $497.52 06/13/14 12:43 AM Deposit Transfer: From Share 0000 $550.00 $738.23 06/13/14 12:43 AM Deposit: NELLS, INC. TYPE: PAYROLL ID: 1232251195 CO: NELLS, INC. ACH PPD - Prearranged Payment or Deposit ACH transaction $188.23 $188.23 06/12/14 11:21 PM Draft: 001106 - $500.00 $0.00 001106 06/12/14 11:21 PM Deposit Transfer: From Share 0000 $108.33 $500.00 06/12/14 11:21 PM Draft: 001105 - $144.64 $391.67 001105 https://myonline.memberslst.org/PrinterFriendly.aspx 7/21/2014 Transaction History Date Description Page 7 of 8 Amount Balance Check# 06/12/14 11:18 PM Withdrawal: CHECK CARD HESS 38357 CARLISLE PA Date 06/11/14 2 4163710004 5 5542 %% Card 15 #13012 Automotive -$35.00 $536.31 06/06/14 06:46 AM Withdrawal: CHECK CARD RUSTIC TAVERN CARLISLE PA Date 06/05/14 2 4157206000 3 5812 /o /o Card 15 #13012 Restaurants -$15.80 $571.31 06/06/14 03:55 AM Withdrawal: CHECK CARD WM SUPERCENTER #2574 CARLISLE PA Date 06/05/14 2 4157400140 0 5411 %% Card 15 #13012 Supermarkets -$23.46 $587.11 06/06/14 12:43 AM Deposit: NELLS, INC. TYPE: PAYROLL ID: 1232251195 CO: NELLS, INC. ACH PPD - Prearranged Payment or Deposit ACH transaction $188.28 $610.57 06/05/14 11:13 PM Draft: 001104 Processed Check - AT&T SERVICES TYPE: CHECKPAYMT ID: 1742782655 ACH ARC -Accounts Receivable Entry ACH transaction $250.00 $422.29 001104 06/05/14 04:42 AM Withdrawal: CHECK CARD SHEETZ 00001917 CARLISLE PA Date 06/04/14 2 4155498315 2 5542 %% Card 15 #13012 Automotive -$40.00 $672.29 06/03/14 03:30 PM Withdrawal: CHECK CARD KWIK FILL MECHANICSBURG PA Date 06/02/14 2 4154000160 9 5542 %% Card 15 #13012 Automotive -$25.01 $712.29 06!03!14 07:43 AM Deposit: PA-SCDU TYPE: CHLD SUPPT ID: 2236003113 CO: PA-SCDU ACH PPD Prearranged Payment or Deposit ACH transaction $234.92 $737.30 06/01/14 06:06 AM Withdrawal: CHECK CARD KARNS QUALITY FOODS MECHANICSBURG PA Date 05/31/14 2 4151720004 0 5411 %% Card 15 #13012 Supermarkets -$62.98 $502.38 06/01/14 06:02 AM Withdrawal: CHECK CARD AMELIA'S GROCERY OU MECHANICSBURG PA Date 05/31/14 2 4151720021 8 5411 %% Card 15 #13012 Supermarkets - $100.48 $565.36 05/31/14 11:55 PM Deposit: Swipe 5 Rebate $2.10 $665.84 05/31/14 09:14 AM Withdrawal by ATM: #008023 MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG PA %% Card 15 #13012 -$40.00 $663.74 05/30/14 11:21 PM Draft: 001100 -$29.40 $703.74 001100 05/30/14 12:35 AM Deposit Transfer: From Share 0000 $550.00 $733.14 05/30/14 12:35 AM Deposit: NELLS, INC. TYPE: PAYROLL ID: 1232251195 CO: NELLS, INC. ACH PPD Prearranged Payment or Deposit ACH transaction $183.14 $183.14 05/29/14 03:43 AM Withdrawal: CHECK CARD SMARTMED INC CARLISLE PA Date 05/28/14 2 4148001973 0 5912 %% Card 15 #13012 Retail -$18.57 $0.00 https://myonline.memberslst.org/PrinterFriendly.aspx 7/21/2014 Transaction History Date Description Page 8 of 8 Amount Balance Check# 05/28/14 11:13 PM Draft: 001102 Processed Check - COMENITYCARD PAY TYPE: CHECK PYMT ID: 9311429215 ACH ARC -Accounts Receivable Entry ACH transaction -$50.00 $18.57 001102 05/28/14 11:13 PM Deposit Transfer: From Share 0000 $19.38 $68.57 05/28/14 06:04 AM Withdrawal: CHECK CARD SHEETZ 00005181 MECHANICSBURG PA Date 05/27/14 2 4147498245 4 5542 %% Card 15 #13012 Automotive -$20.02 $49.19 05/27/14 11:13 PM Draft: 001103 Processed Check - AMAZON TYPE: CHECK PYMT ID: 0818200461 ACH ARC -Accounts Receivable Entry ACH transaction $142.19 $69.21 001103 05/27/14 05:51 AM Withdrawal: CHECK CARD AMELIA'S GROCERY OU MECHANICSBURG PA Date 05/26/14 2 4146720018 4 5411 %% Card 15 #13012 Supermarkets -$19.57 $211.40 05/27/14 04:26 AM Withdrawal: CHECK CARD OLLIES BARGAIN OUTLET 003 MECHANICSBURG PA Date 05/26/14 2 4147131472 4 5310 %% Card 15 #13012 Department Stores -$10.43 $230.97 05/26/14 01:50 PM Withdrawal: CHECK CARD NELL'S - WALNUT BOT CARLISLE PA Date 05/25/14 2 4145720003 9 5411 %% Card 15 #13012 Supermarkets -$32.49 $241.40 05/23/14 03:59 PM Withdrawal: CHECK CARD KWIK FILL MECHANICSBURG PA Date 05/22/14 2 4143001586 1 5542 /o Ao Card 15 #13012 Automotive -$35.00 $273.89 05/23/14 12:35 AM Deposit: NELLS, INC. TYPE: PAYROLL ID: 1232251195 CO: NELLS, INC. ACH PPD - Prearranged Payment or Deposit ACH transaction $176.12 $308.89 05/22/14 11:20 PM Draft: 001101 -$20.00 $132.77 001101 05/22/14 04:39 PM Withdrawal: CHECK CARD WEGMANS #45 MECHANICSBURG PA Date 05/21/14 2 4142100317 2 5411 %% Card 15 #13012 Supermarkets -$31.24 $152.77 https://myonline.memberslst.org/PrinterFriendly.aspx 7/21/2014 PHH MORTGAGE CORPORATION F/K/A CENTANT MORTGAGE CORPORATION v. GARY L. GLESSNER and LORI L. GLESSNER 9 Far View Ave. Carlisle, PA 17013 Plaintiff Defendants • • IN THE COURT OF cOMMOLIT, PLEAS, CUMBERLAND COISN PENNSYLVANIA • NO. 2014-3064 CIVIL TE • • • • • PRAECIPE TO ENTER APPEARANCE zzo cnr° • TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendants, Gary L. Glessner and Lori L. Glessner, in the above -referenced matter. Date:�%J°1-1 1!1+ Respectfully submitted, SALZMANN HUGHES, P.C. A-e-tr\-7 • intiL--V442-11 George F. Douglas, III, Esquire Attorney ID #61886 Salzmann Hughes, P.C. 354 Alexander Spring Rd., Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorney for Defendant CERTIFICATE OF SERVICE I, George F. Douglas, III, Esq., of Salzmann Hughes, P.C., hereby certify that a copy of the foregoing document was served this date by depositing the same via United States mail, first class mail, postage prepaid, and addressed as follows: Date: Michael Dingerdissen, Esq. Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 William Bellows Asst. Vice President PHH Mortgage Corporation 2001 Bishops Gate Blvd. Mount Laurel, NJ 08054 )L" By: George F. Douglas, 111 Esquire In Forma Pauperis Form PHH MORTGAGE CORPORATION F/K/A CENTANT MORTGAGE CORPORATION v. GARY L. GLESSNER and LORI L. GLESSNER 9 Far View Ave. Carlisle, PA 17013 Plaintiff Defendants . IN • PL • PE • THE COURT OF COMMON EAS, CUMBERLAND COUNTY, NNSYLVANIA • • 1%Tl1 2014-3064 CIVIL TERM -c-, D mW C.. rn ry • Z r- 3;1' r_a• 240 Psti PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: -- Kindly allow, GARY L. GLESSNER AND LORI L. GLESSNER, formerly husband and wife, Defendant, to proceed in forma pauperis. I, George F. Douglas, III, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. George F. Douglas, III, Esquire, Attorney for Defendant Salzmann Hughes, P.C. 354 Alexander Spring Rd., Suite 1 Carlisle, PA 17015 (717) 249-6333 CERTIFICATE OF SERVICE I, George F. Douglas, III, Esq., of Salzmann Hughes, P.C., hereby certify that a copy of the foregoing document was served this date by depositing the same via United States mail, first class mail, postage prepaid, and addressed as follows: Date: Michael Dingerdissen, Esq. Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 William Bellows Asst. Vice President PHH Mortgage Corporation 2001 Bishops Gate Blvd. Mount Laurel, NJ 08054 By: George F. Douglas, 111 Esquire PHH MORTGAGE CORPORATION: IN THE COURT OF COMMON PLEAS OF F/K/A CENDANT MORTGAGE : CUMBERLAND COUNTY, PENNSYLVANIA CORPORATION, Plaintiff .• • c ` zrrhl = �, vs. CIVIL ACTION cpt- N „CD : NO. 14-3064 CIVIL <c� 33. GARRY L. GLESSNER and ac-) VC 2=,--; 42 c r.1 LORI L. GLESSNER, v Defendants : CASE MANAGEMENT ORDER a AND NOW, this " day of July, 2014, the parties having agreed to a conciliation conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised Conciliation Conference on „tit/or/4/24a, /? 02a/rat 3:SO p m. in f Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet” (Form 2)which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedu e another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference,the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, "L. Kevi . Hess, P.J. ichael Dingerdissen, Esquire 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 For the Plaintiff ouglas G. Miller, Esquire 60 West Pomfret Street Carlisle, PA 17013 For the Defendants :rim eopi.es • PHH MORTGAGE CORP. F/K/A : IN THE COURT OF COMMON PLEAS OF CENDANT MORTGAGE CORP., : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : CIVIL ACTION — LAW : NO. 14-3064 CIVIL GARRY L. GLESSNER and LORI L. GLESSNER, Defendants ORDER AND NOW, this 11th day of September, 2014, on agreement of the parties, the conciliation conference is continued until Friday, November 14th, 2014 at 3:00 PM. BY THE COURT, .oseph P. Schalk, Esquire Phelan Hallinan, LLP 126 Locust Street Harrisburg, PA 17101 For the Plaintiff Douglas G. Miller, Esquire 60 W. Pomfret St. Carlisle, PA 17013 For the Defendants :rlm (,) *la r'. C.; -4 CD CD PHH MORTGAGE CORP. F/K/A : IN THE COURT OF COMMON PLEAS OF CENDANT MORTGAGE CORP., : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : CIVIL ACTION — LAW : NO. 14-3064 CIVIL GARRY L. GLESSNER and LORI L. GLESSNER, Defendants ORDER AND NOW, this day of November, 2014, following conciliation conference, this matter is continued until Friday, January 16, 2015 at 3:00 p.m. in order to give counsel for the defendants in their divorce action to confer with counsel for the plaintiff. George F. Douglas, III, Esquire, is excused from further appearance and participation in this mortgage foreclosure procedure. Joseph P. Schalk, Esquire Phelan Hallinan, LLP 126 Locust Street Harrisburg, PA 17101 For the Plaintiff glas G. Miller, Esquire 60 W. Pomfret St. Carlisle, PA 17013 For the Defendants F. Douglas, III, Esquire 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 • 02,21'6C BY THE COURT, CD -10 rn Cr3 -T., • 111 • - cr) --4 •*:- < cp — 7,17 PHH MORTGAGE CORP. F/K/A : IN THE COURT OF COMMON PLEAS OF CENDANT MORTGAGE CORP., : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. GARRY L. GLESSNER and LORI L. GLESSNER, Defendants : CIVIL ACTION — LAW : NO. 14-3064 CIVIL ORDER AND NOW, this 1 Zday of January, 2015. at the request of counsel for the parties, the conciliation in the above matter set for January 16, 2015, is continued to Friday, March 27, 2015, at 1:30 p.m. in Chambers of the undersigned. BY THE COURT, Joseph P. Schalk, Esquire Phelan Hallinan, LLP 126 Locust Street Harrisburg, PA 17101 For the Plaintiff Douglas G. Miller, Esquire 60 W. Pomfret St. Carlisle, PA 17013 For the Defendants .Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 (4 es tratifaL C.r1 7-6 CD