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HomeMy WebLinkAbout14-3553 Supreme Court of Pennsylvania Court of Common Pleas ForProthonotan�Else Only: Civil Cover Sheet Docket No: Cumberland County 14-365 The information collected on this form is used solely for court administration purposes. .This form does not sup olement or replace thefiling and service of leadin s or other a vers as required bylaw or rules of court. S Commencement of Action: E x Complaint ❑ Writ of Summons ❑ Petition C ❑ Transfer from Another Jurisdiction ❑ Declaration of Takia Lead Plaintiff's Name:U.S. BANK NATIONAL Lead Defendant's Name: COURTNEY B.MEYER T ASSOCIATION(TRUSTEE FOR THE PENNSYLVANIA I HOUSING FINANCE AGENCY) 0 N Are money damages requested? : ❑Yes X No Dollar Amount Requested: within arbitration limits A Check one outside arbitration limits Is this a Class ACtion Suit? 0 Yes 0 No Is this an MDJA eal? ❑ Yes ❑X No Name of Plaintiff/Appellant's Attorney:Martha Von Rosenstiel,Esq. ❑ Check here if you are a Self-Represented Pro Se Litigant N ature of the Case: Place an"N" to the left of the ONE case category. that most accurately describes your PRI>1ARYCAS'E. If you are making more than one type of claim, check the one that you consider most important. TORT(do not tncludc'a'ass Tort) CONTRACT(do not Include htdgments) CVVIL APPEALS Intentional ❑Buyer Plaintiff Adtninistrative Agencies Malicious Prosecution ❑Debt Collection:Credit Card 0 Board of Assessment Q Motor Vehicle 0 Debt Collection:Other Board of Elections 0 Nuisance © Dept.of Transportation 0 Premises Liability 0 Statutory Appeal:Other S 0 Product Liability!docs sot inchrde 0 Employment Dispute: mass tort) E Q Slanderitibel'Defamation Discrimination C El Other: Employment Dispute:Other 0 Zoning Board T0 Other- I 0 Other: O 1IASS'TORT Asbestos Tobacco 0 Tonic Tort-DES Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Other: 0 Ejectment O Common Law/Statutory Arbitration B 0 Eminent.Donnain/Condenuuntion 0 Declaratory Judgment 0 Ground Rent. Mandamus 0 Landlord/Tenant-Dispute B Non-Domestic Relations - x0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL.LIABLITY 0 Nlong age Foreclosure:Conunnercial 0 Quo Warranto 0 Dental 0Partition 0 Replevin 0 Legnl 0 Quiet Title 0 Other: 0 Medical 0 Other: 0 Other Professional: Lpdnted 1/1/_'011 FORM 1 U.S. BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS OF (TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, HOUSING FINANCE AGENCY) PENNSYLVANIA 211 North Front Street Harrisburg, PA 17101 Plaintiff VS. NO. I4-3553 l.ivili°rM1 , COURTNEY B. MEYER 25 Sunset Drive - Mechanicsburg, PA 17050 Defendant -- ; NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE a DIVERSION PROGRAM -`-r ' 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 the 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 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 attkmpt 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 A D TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. R ctfully submitted: May 28, 2014 Date Signature of Counsel 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 Please provide the following information to the best of your knowledge: CUSTOMERIPRIMAR Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes[] No M 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? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? INFORMATIONFINANCIAL 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'and 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 payin.E 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 Support/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and 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? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company(Name): Contact: Phone: AUTHORIZATION I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement(if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed S FORM 3 U.S. BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS OF (TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, HOUSING FINANCE AGENCY) PENNSYLVANIA 211 North Front Street Harrisburg, PA 17101 Plaintiff vs. NO. COURTNEY B. MEYER 25 Sunset Drive Mechanicsburg, PA 17050 Defendant REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated ' 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendanfs Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 U.S. BANK NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS OF (TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY, HOUSING FINANCE AGENCY) PENNSYLVANIA 211 North Front Street Harrisburg, PA 17101 Plaintiff vs. NO. COURTNEY B. MEYER 25 Sunset Drive Mechanicsburg, PA 17050 Defendant CASE MANAGEMENT ORDER AND NOW,this day of ,20 the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which. has been completed by the defendant/borrower. Upon agreement of the parties lin 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 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; 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. MARTHA E. VON ROSENSTIEL, P.C. 34500CFC-AB Martha E. Von Rosenstiel, Esquire/No. 52634 `- ' F kc C- r 1 Heather Riloff, Esquire/No. 309906 A f 649 South Avenue, Suite 7 Pp g rc Y L A:AA Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff U.S. BANK NATIONAL ASSOCIATION COURT OF COMMON PLEAS OF (TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY HOUSING FINANCE AGENCY) 211 North Front Street Harrisburg, PA 17101 Plaintiff V. NO. 14 -3-553 Ci W-Felpi COURTNEY B. MEYER 25 Sunset Drive Mechanicsburg, PA 17050 Defendant CIVIL ACTION—MORTGAGE FORECLOSURE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims Le ban demandado a usted en la corte. Si usted quiere defenderse de set forth in the following pages,you must take action within twenty estas demandas expuestas en las paginas siguientes,usted tiene (20)days after this complaint and notice are served,by entering a veinte(20)dias de plazo al partir de la fecha de la demanda y la written appearance personally or by attorney and filing in writing with notificacion. Hace falta a sentar una comparencia escrita o en the court your defenses or objections to the claims set forth against you. persona o con un abogado y entregar a la corte en forma escrita sus You are warned that if you fail to do so the case may proceed without defensas o sus objeciones a las demandas en contra de su persona. you and a judgment may be entered against you by the court without Sea a visado que si usted no se defiende,]a corte toma ra medidas y further notice for any money claimed in the complaint or for any other puede continuar la demanda en contra suya sin previo aviso o claim or relief requested by the plaintiff. You may lose money or notificacion. Ademas,la corte puede decidir a favor del demandante property or other rights important to you y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT LLEVE ESTA DEMANDA A UN ABOGADO ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN TELEPHONE THE OFFICE SET FORTH BELOW.THIS PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT ESTA OFICINA LE PUEDE PROVEER INFORMACION HIRING A LAWYER.IF YOU CANNOT AFFORD TO HIRE A SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A WITH INFORMATION ABOUT AGENCIES THAT MAY UN ABOGADO,LE PODEMOS DAR INFORMACION OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A REDUCED FEE OR NO FEE PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 ID3 7� PP fl 800-990-9108 Lid X455 3o'7 IQ3 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. 34500CFC-AB Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 ` Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff U.S. BANK NATIONAL ASSOCIATION COURT OF COMMON PLEAS OF (TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY HOUSING FINANCE AGENCY) 211 North Front Street Harrisburg, PA 17101 Plaintiff V. NO. COURTNEY B. MEYER 25 Sunset Drive Mechanicsburg, PA 17050 Defendant CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is U.S. Bank National Association (Trustee for the Pennsylvania Housing Finance Agency), a bank organized and existing under state law, with offices for the conduct of business at 211 North Front Street, Harrisburg, PA 17101. 2. Defendant, Courtney B. Meyer is the mortgagor and real owner of premises 25 Sunset Drive, Mechanicsburg, PA 17050, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor, and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor, and real owner to Countrywide Home Loans, Inc. on July 31, 2001, which mortgage was recorded on August 2, 2001 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1729, Page 2591, secured on premises 25 Sunset Drive, Mechanicsburg, PA 17050 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage was then assigned to Pennsylvania Housing Finance Agency by written assignment dated July 31, 2001 and recorded on August 2, 2001 in the office of the recorder of deeds of Cumberland County in Mortgage Book 679, Page 4541. 5. The mortgage has since been assigned to U.S. Bank National Association (Trustee for the Pennsylvania Housing Finance Agency)by written assignment dated April 11, 2014 and recorded on May 15, 2014 in the office of the recorder of deeds of Cumberland County as Mortgage Instrument No. 201410066. 6. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 7. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from December 2013 and each month thereafter, up to and including the present time. 8. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 9. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 83,386.48 Interest from 11/1/2013 to 5/23/2014 at $14.28 per diem $ 2,934.21 Accrued late charges $ 438.84 Attorney's Fee $ 1,650.00 Inspection Fees $ 96.00 Satisfaction Costs $ 55.50 Total $ 88,561.03 9. Plaintiff sent to obligated defendant, mortgagor and real owner a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 as amended by Act 160 of 1998 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of$88,561.03, plus per diem interest at $14.28 from May 24, 2014 to the date of judgment plus costs thereon. MARTHA E. VON ROSENSTIE , P.C. rHeatherRiloff, stiel, Esquire e VERIFICATION Thomas F. Brzana. Jr. hereby states that he/she is the Director of Loan Servicing of Pennsylvania Housing Finance Agency, Servicer for U.S.Bank National Association(Trustee for the Pennsylvania Housing Finance Agency), plaintiff herein;that he/she is duly authorized to make this Verification on behalf of U.S.Bank National Association(Trustee for the Pennsylvania Housing Finance Agency)and verifies that the statements made in the foregoing Complaint in U.S. Bank National Association(Trustee for the Pennsylvania Housing Finance Agency)v. Courtney B. Meyer relating to the property located at 25 Sunset Drive, Mechanicsburg, PA 17050 are true and correct to the best of his/her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. *M"06 * T/ BY: Thomas F. Brzana, Jr. Title: Director of Loan Servicing Pennsylvania Housing Finance Agency as servicer for U.S. Bank National Association (Trustee for the Pennsylvania Housing Finance Agency) Dated: 1 EXHIBIT I i LEGAL DESCRIPTION ALL THAT CERTAIN house and tract of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows,to wit: BEGINNING at an iron pin on the south side of a 40 foot public road, known as Legislative Route#597, said point being located South 72 degrees 51 minutes East along the south side of said public road, a distance of 171.75 feet from a point on the eastern line of land now or formerly of Donald B. Kramer and Blondena J. Kramer, his wife;thence along the south side of said public road, South 72 degrees 51 minutes East, 74.27 feet to an iron pin;thence along a curve to the right having a radius of 50 feet, an arc distance of 63.57 feet to an iron pin on the west side of another public road known as White Birch Avenue,having a width of 50 feet; thence along the west side of White Birch Avenue, due South 81.05 feet to an iron pin;thence along the line of other land now or formerly of Mary Alice Walker,North 78 degrees 33 minutes West, 146.81 feet to an iron pin; thence continuing along the other land now or formerly of Mary Alice Walker,North 17 degrees 09 minutes East, 127.15 feet to an iron pin on the south side of the public road first mentioned above,the place of BEGINNING. BEING Lot No. 3 in the Plan of White Birch Farms Development, recorded in the Recorder's Office in and for Cumberland County, Pennsylvania, in Plan Book 11, Page 37. BEING known as 25 Sunset Drive, Mechanicsburg, Pennsylvania. PARCEL IDENTIFICATION NO: 38-14-0847-040., CONTROL#: 38001437 EXHIBIT II Date: 3/07/2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 6 �ra This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached_pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM Ht EMAP may be able to help save your home. This Notice explains how the Pro ram works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF„THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and ohone number of Consumer Credit Counseling Agencies serving your county are- listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. Persons with impaired hearin can call 717-780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACi6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. Sl NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACi6N OBTENGA UNA TRADUCCbN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM” EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ACT691 LRAtnidoas/ALSV! HOMEOWNER'S NAME(S): COURTNEY B. MEYER PROPERTY ADDRESS: 25 SUNSET DR MECHANICSBURG, PA 17050-1633 LOAN ACCOUNT NO.: S CURRENT LENDER;}SERVICER: Pennsylvania Housing Finance Agency 211 North Front Street P.O. Box 15057 Harrisburg,PA 17145-5057 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BEELIGIBLEFOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, ' IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the Consumer Credit Counseling Agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the Consumer Credit Counseling Agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated Consumer Credit Counseling Agencies for the county in which the property is located are set forth at the end of this Notice. It Is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so you must fill out, sign and file a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated Consumer Credit Counseling ACT691 LRld#mdocsrALSV; Agent€es listed at the end of this Notice. Only Consumer Credit Counseling Agencies have applications for the Program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for Emergency Mortgage Assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (if you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 25 SUNSET DR, MECHANICSBURG, PA 17050-1633, IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months December, 2013 thru the first of March, 2014 in the amount of $3,596.00 plus late charges that have accrued in the amount of $339.66 and other charges (inspection fees and / or attorney fees and casts in the amount of $48.00) . THE TOTAL AMOUNT DUE IS $3,983.66. This includes all payments, fees and expenses due, less any funds we are holding in suspense. HOW TO CURE THE DEFAULT-- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3,983.66 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. moments must be made either by cash in our office, cashier's check, certified check or money order made payable and sent to: PENNSYLVANIA HOUSING FINANCE AGENCY 211 N FRONT STREET P.O. BOX 15057 HARRISBURG, PA 17105-5057 ACT691 LRrdtmdc>csiAL W IFYbU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date,of this Notice, the lender Intends to exercise Its ri hts-to accelerate the mortgagt debt. This r�eans that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the tender refers your case to its attorneys but you cure the delinquency before the lender begins legal Proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY_period,_you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE — If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up-to one hour before the Sheriff's Sale. _You may do so by p�ayinq the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default In the manner set forth In this notice will restore your mortgage to the same position as If you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately three months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to You before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 717-614-2518(FAX) Contact Person: KIMBERLEY AYALA Counseling Agencies: In addition to mailing Appendix B, Notice of Face-To-Face Meeting, please notify PHFA (when we are the first lien holder) of the face-to-face meeting and pending submission of application for HEMAP assistance by sending an e-mail to: Kayala@phfa.org. If you do not have access to e-mail, please call Kim Ayala at 717.780-1815 and advise of the face-to-face meeting. EFFECT OF SHERIFF'S SALE— You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time, ASSUMPTION OF MORTGAGE-- You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. (This does not apply if your mortgage was originated under the Home Start Program.) ACT691 LR/dtmdocs.1ALSV/ YOU MAY ALSO HAVE THE RIGHT: TC) SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE. MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ` TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER. LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling ServicelCCCS of Wester Ilunsing V11auce of York/X Ilousiug;Resources 2000 Lingleslown Road 2941 West Market Street !Harrisburg,PA 17102 lurk,I'A 17401 717-855-2712 Maranatha Community e Alan Contndssion of Caltltal Region 43 I'Itlladelltbia Avenue 1.514 Derry Street Waynesboro,PA 17268 Ilarrisburg,PA 17104 717-762-3285 717-232-9757 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front Street Gettysburg,PA 17325 Harrisburg,PA 17110 717-334-1518 717-780-3940 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg,PA 17102 Chambersburg,PA 17201 717-234-6616 717.264-5913 ACT691 LRldtrndocs/ALSV Pennsylvania H,{3 sin Finance ALiency Accounting& Loan Servicing ?11 Norih front Street, A0. Box I505 7 Harrisburg PA 17105-5057 (800)346-3597 FAX(717) 780-3804 77T(717) 780-I869 NOTICE 3/07/2014 COURTNEY B. MEYER 25 SUNSET DR MECHANICSBURG, PA 17050 RE: Account #969253 TO: COURTNEY B. MEYER 25 SUNSET DR MECHANICSBURG, PA 17050-1633 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY The Federal Housing and Development Act of 1987 (as amended) directs creditors to notify homeowners who are delinquent in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary of the Department of Housing and Urban Development ("HUD") and experienced in the provision of homeownership counseling. Attached is a current list of HUD-approved counseling agencies for Pennsylvania. Attachment: Housing Counseling List ACT691 LR'dimdocs/ALSW HUD-APPROVED CREDIT COUNSELING AGENCIES CCCS OF WESTERN PA-HARRISBURG NAC t 2000 LINGLESTOWN RD. 134I N DELAWARE AVE;SUITE 312 HARRISBURG,PA.17110 PHILAI)ELPIIIA,PA.19125 Phooe:N88-599-2227 PIkoue:888-247-5568 IiOUSING ALLIANCE OF YORK PHILADELPHIA COUNCIL OF COAPT IINITY DEVELOPMENT 34 S.Dake Sl. ONE,PENN CENTER;1617 317K BLVD;SUITE I550 York,PA 17401-1106 PHILADELPHIA,PA.19103-IN2N Phimc:800-8644909 111wone:800-930-4663 TABOR COMMUNITY SERVICES 208 E King St. Lancaster,PA 17608.1676 Phone:717.387.5182 ACT691 LR/dtmdocs/ALSV° Print Key Output Page I 5770SSI V7RIM0 100423 PHFASYSI 03/05/14 10:35:06 Display Device . . . . . . QPADEV00Al User . . . . . . . . . . . GUTSHALE SRV860-02 ..............w.................................... 3/05/14 GUTSHALE PERSONAL & PROPERTY DATA 10:35:04 ....................... Loan* 0000969253 Inv* 251����RAsum: Y Total Due 3983.66 Due 12/01/13 CP: GUTSHALE Msq*I: 30 2: 3: UnPaidBal 83386.48 LPR Barr 1: COURTNEY B liEYER 177-58-7977 Enpl: Sal: 0 717-351 Email: ovnt151atyahoo.com On-Line Res: Y/N Barr 2: 000-00-0000 d ,x Empl: Sal: 0 0 R. �} Email. On-Line Req: YIN Prop: 25 SUNSET DR Number of Children: 00 rn M Las 0 co 0 Addr: Ages: 00 .tea to En m, MECHANICSBURG PA 170501633 Seller: Addr. 25 SUNSET DR MM,.._ �. > i.) En d/�y b a F{-:'' Eat MECHANICSBURG PA 170501633 Legal Description: F3-Exit F6-Additional Names and Addresses F7-Next Loan 'n ) _6 ° Page Dn!!L"A.A_L,O._- F8. Loan F12-Return F16-Opt Out Info v in z C rn -1 z tv C5 ZVI L Q o _Q Ln 0 4M 12 C4 0-3 Yn 31 0 W 4 o u ce � � �. kv ru'e Hester : Dx a L_ 03/012014 :: $01 .30° ZIP 17101 . 011012601941 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff - i •, o, of Cumber/0",i wait,/�fi� JodyS Smith }„ �. Chief Deputy „ ''i .'�,�12€ P t t ,_ ,, Richard W Stewart -!,1, BERLA E) Ci.,W i Solicitor a, �� ,r t PEN S Y LVA N t A U.S. Bank National Assocation Case Number vs. Courtney B Meyer 2014-3553 SHERIFF'S RETURN OF SERVICE 06/16/2014 12:16 PM- Deputy William Cline, being duly sworn according to law, served the requested Complaint& Notice by"personally" handing a true copy to a person representing themselves to be t e Defendant, to /7,wit: Courtney B Meyer at 25 Sunset Drive, Silver Spring, Mechanicsburg, PA 1 50. WILLIAM CLINE, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, June 17, 2014 RON 'R ANDERSON, SHERIFF qur- u : :hari c^ ascf` .1.7, MARTHA E. VON ROSENSTIEL, P.C. Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff U.S. BANK NATIONAL ASSOCIATION (TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY) 211 North Front Street Harrisburg, PA 17101 Plaintiff vs. COURTNEY B. MEYER 25 Sunset Drive Mechanicsburg, PA 17050 Defendant THE PROTHONOTARY /114 AUG 22 P1112: 22• CUMBERLAND COUNTY PENNSYLVANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No. 14-3553 Civil Term PLAINTIFF'S MOTION TO REMOVE CASE FROM THE CUMBERLAND COUNTY RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM Plaintiff, U.S. Bank National Association (Trustee for the Pennsylvania Housing Finance Agency) by and through its undersigned counsel, Martha E. Von Rosenstiel, P.C., Heather Riloff, Esquire, hereby respectfully requests that this Honorable Court enter an Order granting its Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, and in support thereof, avers as follows: 1. This matter has been assigned to the Honorable Kevin A. Hess, P.J. for matters concerning the Residential Mortgage Conciliation Program. 2. This is a residential mortgage foreclosure action. 3. On or about June 16, 2014, service of the Mortgage Foreclosure Complaint was completed in this action and the 60 day stay of proceedings went into effect pursuant to the February 28, 2012 Administrative Order. 4. To date, 60 days after service of the Complaint and Notice, Plaintiff has not received notice of a Conciliation Conference date, nor a Diversion Program Financial Worksheet 5. Plaintiff respectfully requests that it be permitted to proceed with its foreclosure action. WHEREFORE, Plaintiff, U.S. Bank National Association (Trustee for the Pennsylvania Housing Finance Agency), respectfully requests this case be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: August 20, 2014 Alt.xL ,! r 119 Heather Riloff, Esq PA Attorney ID No. 30 Attorney for Plaintiff 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 1 MARTHA E. VON ROSENSTIEL, P.C. Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff U.S. BANK NATIONAL ASSOCIATION (TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY) 211 North Front Street Harrisburg, PA 17101 Plaintiff vs. COURTNEY B. MEYER 25 Sunset Drive Mechanicsburg, PA 17050 Defendant : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No. 14-3553 Civil Term CERTIFICATION OF SERVICE Heather Riloff, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, and proposed order in the above matter was made upon the Defendants: COURTNEY B. MEYER 25 Sunset Drive Mechanicsburg, PA 17050 by regular first class mail, postage prepaid, deposited with the United States Postal Service on August 20, 2014. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. BY: Dated: August 20, 2014 Heather Rilof', Attorney for 11 VERIFICATION HEATHER RILOFF, ESQUIRE, hereby states that she is the Attorney for the Plaintiff in this action and that the statements made in the forgoing Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, are true and correct to the best or her information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: Date: August 20, 2014 Heather Riloff, Attorney for Plai IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION (TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY) 211 North Front Street Harrisburg, PA 17101 Plaintiff vs. COURTNEY B. MEYER 25 Sunset Drive Mechanicsburg, PA 17050 Defendant : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No. 14-3553 Civil Term ORDER OF COURT (-) r C ra j,c z Pi c z 77 GD (Dr- ry -< )> 01 r <o 7.t c) C: PO ---1 CO -< t AND NOW, this 210 day of Aws , 2014, the Defendant having failed to comply with the requirements of the Cumberland County Administrative Order dated February 28, 2012, it is hereby ORDERED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. The temporary stay on this matter is terminated. SEs ��. Let, e.acePY yam. BY THE COURT: 34500CPG-TM(discontinue) MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 =ii 649 South Avenue, Suite 7 Secane PA 19018 (610) 328-2887 Attorneys for Plaintiff /. U.S. BANK NATIONAL ASSOCIATION COURT OF COMMON PLEAS (TRUSTEE FOR THE PENNSYLVANIA CUMBERLAND COUNTY HOUSING FINANCE AGENCY) Plaintiff NO: 14-3553 Civil Term VS. COURTNEY B. MEYER Defendant PRAECIPE TO MARK CASE DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark this action discontinued and ended without prejudice. MARTHA E. VON ROSENSTIEL, P.C. BY: d A Martha E. Vonos tiel, Esquire Heather Riloff, e Attorneys for Plaintiff Dated: August 26, 2014