The URL can be used to link to this page

Home My WebLink About14-3306 Supreme Court-of Pennsylvania ift Cour �o 'CommofiTleas I/, g,N, For Prothonotary Use Only: � V 1Covef beet C&BAid D1'��1 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: ❑x Complaint ❑Writ of Summons ❑Petition S ❑Transfer from Another Jurisdiction ❑Declaration of Taking E Lead Plaintiff's Name: PNC BANK,NATIONAL Lead Defendant's Name: MAD14AVAN A. SUSEELAN ASSOCIATION,SUCCESSOR IN INTEREST TO C NATIONAL CITY REAL ESTATE SERVICES,LLC, T SUCCESSOR BY MERGER TO NATIONAL CITY I MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. Are money damages requested? ❑ Yes � No Dollar Amount Requested: El within arbitration limits N (Check one) ❑x outside arbitration limits A Is this a Class Action Suit? ElYes ❑x No Is this an MDJ Appeal? ElYes ❑x No Name of Plaintiff/Appellant's Attorney: Jonathan Lobb,Esq.,Id.No.312174,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 S ❑Motor Vehicle ❑Debt Collection: Other ❑Board of Elections ❑Nuisance ❑Dept. of Transportation E ❑Premises Liability ❑ Statutory Appeal: Other C ❑Product Liability(does not ,I, include mass tort) ❑Employment Dispute: ❑ Slander/Libel/Defamation Discrimination I ❑Other: ❑Employment Dispute: Other ❑Zoning Board U ❑ Other: N MASS TORT ❑Other: ❑Asbestos $ ❑ Tobacco ❑Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑Toxic Waste ❑Ejectment ❑ Common Law/Statutory Arbitration ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑Mandamus ❑ Landlord/Tenant Dispute ❑Non-Domestic Relations Z 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 01/0112011 I rLfr! A YL PHELAN HALLINAN,LLP Jonathan Lobb,Esq.,Id.No.312174 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza. ATTORNEY FOR PLAINTIFF Philadelphia,PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY COURT OF COMMON PLEAS REAL ESTATE SERVICES,LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., CIVIL DIVISION FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. TERM 3232 NEWMARK DRIVE I V t MIAMISBURG, OH 45342 NO. Plaintiff CUMBERLAND COUNTY V. MADHAVAN A. SUSEELAN 15723 EDO CIRCLE HOUSTON, TX 77083-1446 Defendant CIVIL ACTION-LAW COMPLAINT IN MORTGAGE FORECLOSURE lam/ �vak File#: 944977 �6UUq 1. Plaintiff is PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. 3232 NEWMARK DRIVE MIAMISBURG, OH 45342 2. The name(s) and last known address(es) of the Defendant(s) are: MADHAVAN A. SUSEELAN 15723 EDO CIRCLE HOUSTON,TX 77083-1446 who is/are the mortgagor(s) of the property hereinafter described. 3. On 09/15/2003 MADHAVAN A. SUSEELAN 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 1840,Page 3026.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 10/01/2013 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 by written notice sent to Mortgagor,the entire principal balance and all interest due thereon are collectible forthwith. File#: 944977 6. The following amounts are due on the mortgage as of 05/16/2014: Principal Balance $71,266.52 Interest $2,900.32 09/01/2013 to 05/16/2014 Late Charges $282.52 Property Inspections $78.00 Non Sufficient Funds Charge $62.00 Escrow $376.75 TOTAL $74,966.11 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. 9. The mortgage premises are vacant and abandoned. File#: 944977 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $74,966.11, 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 By: 11-dk JonAfhan Lobb,Esq., Id.No.312174 Attorney for Plaintiff File#: 944977 LEGAL DESCRIPTION The land referred to in this Commitment, situated in the County of Cumberland, State of PENNSYLVANIA, is described as follows: Beginning at a point on the Eastern right of way line of Nantucket Drive at the Southwest corner of Lot No. 123; thence along said right of way line,North 55 degrees 29 minutes 30 seconds West, 20.22 feet to a point, being the Southeast corner of Lot No. 121; thence along Lot No. 121 and partly through a partition wall,North 43 degrees 01 minutes 45 seconds East, 150.25 feet to a point, being the Eastern line of Lot No. 169;thence along Lot No. 169, South 57 degrees 21 minutes 23 seconds East, 20.33 feet to a point, being the Northwest corner of Lot No. 123; thence along Lot No. 123 and partly through a partition wall, South 43 degrees 01 minutes 45 seconds West, 150.92 feet to a point,being the place of beginning. Containing 3,012 Square feet,more of less. Being Lot No. 122 on a Plan of Beaumont Square, recorded in Plan Book 62, Page 51. PROPERTY ADDRESS: 4204 NANTUCKET DRIVE,MECHANICSBURG,PA 17050- 9105 PARCEL #10-16-1058-124 File#: 944977 VERIFICATION Barbara Wacker,hereby states that he/s_ hetes Authorized Signe of PNC MORTGAGE,A DIVISION OF PNC BANK,NA,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: Z&&XA4U& Name: batDara Wacker- Title: Authorized Signer- PNC MORTGAGE,A DIVISION OF PNC BANK,NA File#: 944977 Name: SUSEELAN File#: 944977 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#: 944977 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OF.F.ICE OF THE SHERIFF P PNC Bank, National Association vs. Madhavan A Suseelan Case Number 2014-3306 SHERIFF'S RETURN OF SERVICE 07/02/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Madhavan A Suseelan, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 4204 Nantucket Drive, Hampden Township, Mechanicsburg, PA 17050. Residence is vacant and to this date the Mechanicsburg Postmaster has not provide a good forwarding address and Complaint in Mortgage Foreclosure has expired. SHERIFF COST: $44.79 SO ANSWERS, July 02, 2014 (c) CountySuite Sheriff, Teleosett, Inc. RONNR ANDERSON, SHERIFF Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. Plaintiff vs. ED - Ft 'OTHONOTAt:- 2014 AUG 12 All 10 04 vU BERLA PENNSYLVANIA COUNTY Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 14 -3306 -CIVIL MADHAVAN A. SUSEELAN Defendant MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan, LLP, moves this Honorable Court for an Order directing service of the Complaint and the notice of Sheriff's Sale upon the above -captioned Defendant, MADHAVAN A. SUSEELAN, by first class mail to MADHAVAN A. SUSEELAN at the mortgaged premises, 4204 NANTUCKET DRIVE, MECHANICSBURG, PA 17050-9105; posting of the mortgaged premises, 4204 NANTUCKET DRIVE, MECHANICSBURG, PA 17050-9105; and in support thereof avers the following: 1. Attempts to serve Defendant, MADHAVAN A. SUSEELAN, personally with the Complaint have been unsuccessful. The Sheriff of CUMBERLAND County attempted to serve the Defendant at the mortgaged premises, 4204 NANTUCKET DRIVE, MECHANICSBURG, PA 17050-9105. As indicated by the Return of Service, no service was made as said address is vacant. A true and correct copy of the Return of Service is attached hereto, made part hereof, and marked as Exhibit "A". 2. The Plaintiffs Process Server attempted to serve the Defendant at 15723 EDO CIRCLE, HOUSTON, TX 77083-1446. As indicated by the Affidavit of Service, no service was made as the Defendant does not reside at said address. A true and correct copy of the Affidavit of Service is attached hereto, made part hereof, and marked as Exhibit "B". 3. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendant. A true and correct copy of an affidavit of due diligence setting forth the specific inquiries as to the Defendant's whereabouts and the results thereof is attached hereto, made part hereof, and marked as Exhibit "C". 4. Plaintiff contacted the Prothontary's Office and as of July 31, 2014, no Judge has previously entered a ruling in this case. 5. In accordance with CUMBERLAND County Local Rule 208.2(d), Plaintiff sent a copy of its Proposed Motion for Special Service and Order to the Defendant on July 31, 2014 and requested Defendant's concurrence. Plaintiff did not receive any written response from the Defendant. A true and correct copy of Plaintiffs July 31, 2014 letter and postmarked certificate of mailing pursuant to Local Rule 208.2(d) attached hereto, made part hereof, and marked Exhibit "D". 6. Plaintiff submits that it has made a good faith effort to locate the Defendant but has been unable to do so. 944977 WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint and notice of Sheriff's Sale by first class mail; posting; and by publication. Date: Respectfully submitted, PHELAN HALLINAN, LLP Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 944977 Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. Plaintiff vs. MADHAVAN A. SUSEELAN Defendant Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 14 -3306 -CIVIL MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT I. FACTUAL BACKGROUND Attempts to serve Defendant, MADHAVAN A. SUSEELAN, with the Complaint have been unsuccessful. The Sheriff of CUMBERLAND County attempted to serve the Defendant at the mortgaged premises, 4204 NANTUCKET DRIVE, MECHANICSBURG, PA 17050-9105. The Plaintiffs Process Server attempted to serve the Defendant at 15723 EDO CIRCLE, HOUSTON, TX 77083-1446. As indicated by the Return of Service and the Affidavit of Service, no service was made. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to discover the whereabouts of the Defendant as evidenced by the affidavit of due diligence setting forth the specific inquiries as to the Defendant's whereabouts and the results thereof. 944977 Consequently, Plaintiff submits that it has made a good faith effort to locate the Defendant but has been unable to do so. II. LEGAL AUTHORITY Pennsylvania Rule of Civil Procedure 430(a) specifically states: If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Pa.R.C.P. 430(a) (2009). In particular: An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends, and employers of the defendant, and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. Id. at 430(a) n. Similarly, the Pennsylvania Superior Court has gone on to explain that, "While by no means exhaustive, this Note is at least indicative of the types of procedures contemplated by the legislature when enacting Rule 430." Deer Park Lumber, Inc. v. Major, 384 Pa. Super. 625, 633, 559 A.2d 941, 946 (1989), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). Only after such proof has been offered is the Court authorized to direct another method of substitute service. See id. In the instant case, as indicated by the Return of Service and the Affidavit of Service, the Sheriff and the Plaintiffs Process Server have been unable to serve the Complaint. Plaintiff has made a good faith effort to discover the whereabouts of the Defendant as evidenced by the 944977 affidavit of due diligence. Therefore, Plaintiff respectfully requests an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail, posting, and publication. Additionally, pursuant to Pennsylvania Rule of Civil Procedure Rule 3129.2, it is necessary in a foreclosure action for the Sheriff or Process Server to serve upon the Defendant Notice of the Sale of the mortgaged premises. Specifically, Pa. R.C.P. Rule 3129.2(c) provides in applicable part as follows: The written notice shall be prepared by the plaintiff, shall contain the same information as the hand bills or may consist of the handbill and shall be served at least thirty days before the sale on all persons whose names and addresses are set forth in the affidavit required by Rule 3129.1. (1) Service of the notice shall be made: (i) upon a defendant... (A) by the sheriff or by a competent adult in the manner prescribed by Rule 402(a) for the service of the original process upon a defendant, or (B) by the plaintiff mailing a copy in the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if the service cannot be made as provided in subparagraph (A) or (B), the notice shall be served pursuant to special order of court as prescribed by Rule 430, except that if original process was served pursuant to special order of court under Rule 430 upon the defendant in the judgment, the notice may be served upon that defendant in the manner provided by the order for service of original process without further application to the court. Therefore, Plaintiff respectfully requests that the Court allow for service of the Notice of Sale upon Defendant in accordance with Pa. R. C. P. Rule 430 by first class mail and posting. III. CONCLUSION As indicated by the Return of Service and the Affidavit of Service, the Sheriff and the Plaintiffs Process Server have been unable to serve the Complaint upon the Defendant. Plaintiff 944977 has made a good faith effort to discover the whereabouts of the Defendant as evidenced by its affidavit of due diligence. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint and Notice of Sheriff's Sale by first class mail, posting, and publication. Date: Respectfully submitted, PHELAN HALLINAN, LLP By: Adam H. Davis, Esq., Id. o.203034 Attorney for Plaintiff 944977 Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. Plaintiff vs. Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 14 -3306 -CIVIL MADHAVAN A. SUSEELAN Defendant CERTIFICATION OF SERVICE The undersigned hereby certifies that copies of the Motion for Service Pursuant to Special Order of Court, Memorandum of Law, Proposed Order and attached exhibits have been sent to the individual as indicated below by first class mail, postage prepaid, on the date listed below. MADHAVAN A. SUSEELAN 4204 NANTUCKET DRIVE MECHANICSBURG, PA 17050-9105 The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Respectfully submitted, PHELAN HALLINAN, LLP Date: ym// ( By: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 944977 Exhibit "A" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY •Low p cS En>nbrrf0,10 OFFICE QF THE SHERIFF PNC Bank, National Association vs. Madhavan A Suseelan Case Number 2014-3306 SHERIFF'S RETURN OF SERVICE 07/02/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Madhavan A Suseelan, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 4204 Nantucket Drive, Hampden Township, Mechanicsburg, PA 17050. Residence is vacant and to this date the Mechanicsburg Postmaster has not provide a good forwarding address and Complaint in Mortgage Foreclosure has expired. SHERIFF COST: $44.79 SO ANSWERS, July 02, 2014 (c) CounySulle Sher,tf, Teleosori Inc. RONNY ANDERSON, SHERIFF Exhibit "B" sew x .a....a AFFIDAVIT OF SERVICE Please effectuate Service attempts by 07/02/2014 on Philadelphia Addresses or 07/17/2014 on Out of State Addresses PLAINTIFF CUMBERLAND COUNTY PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, PH # 944977 LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. DEFENDANT SERVICE TEAM/ bsp MADHAVAN A. SUSEELAN COURT NO.: 14 -3306 -CIVIL SERVE MADHAVAN A. SUSEELAN AT: 15723 EDO CIRCLE HOUSTON, TX 77083-1446 TYPE OF ACTION XX Mortgage Foreclosure XX Civil Action SERVED Served and made known to MADHAVAN A. SUSEELAN, Defendant on the day of , 20 _. at , o'clock . M., at in the manner described below: Defendant personally served. _ Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age Height __. Weight Race Sex Other I,). !'rola PO'1 f' a competent adult, being duly sworn according to law, depose and state that I personally handed a true an correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of ,20 . Notary: B y: �q Nl On the (7 da of 20d, atb'dd o'clock Defendant NOT FO e ause: Vacant — Does Not Exist _ No Answer on at Service Refused Other: Sworn to and subset offor} i this Nrtnry: y rte. a At, JORGE IVAN FRANCESCHI My Commission Expires February 3, 2016 By: S RVE D M., I, , a competent adult hereby state that `Moved ,Does Not Reside (Not Vacant) ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel 0, Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. Na 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. Np. 84439 t rye 4-0 5;03.4erlr Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Mario J. Hanyon, Esq., Id. No. 203993 John M. Kolcsnik, Esq.. Id. No. 308877 Matthew G. Brushwood, Esq., Id. No. 310592 Justin F. Koheski, Esq., Id. No. 200392 Adam Davis, Esq., Id. No. 203034 Joseph E. DeBarberie, Esq., Id. No. 315421 EMILY M. PHELAN, Esq., Id. No. 315250 Michael Dingerdissen, Esq., Id. No. 317124 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Exhibit "C" AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 944977 Attorney Firm: Phelan Hallinan LLP Subject: Madhavan A. Suseelan Property Address: 4204 Nantucket Drive, Mechanicsburg, PA 17050 Possible Mailing Address: 4204 Nantucket Drive, Hampden, PA 17025 I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Madhavan A. Suseelan - xxx-xx-5567 B. EMPLOYMENT SEARCH Madhavan A. Suseelan - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Madhavan A. Suseelan reside(s) at 4204 Nantucket Drive, Hampden, PA 17025. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which had no listing for Madhavan A. Suseelan. B. On 03-28-14 our office made a telephone call to a possible phone number of the subject(s) (717) 732-7184 and received the following information: disconnected. III. INQUIRY OF NEIGHBORS On 03-28-1.4 our office made a phone call in an attempt to contact William M. Chorgo (717) 732-0483, 4200 Nantucket Drive, Mechanicsburg, PA 17050: discorrnected. On 03-28-14 our office made several phone calls in an attempt to contact Carol L. Skowronski (717) 732-1175, 4198 Nantucket Drive, Mechanicsburg, PA 17050: no answer. On 03-28-14 our office made several phone calls in an attempt to contact Drucila Vovakes (717) 728-3428, 4208 Nantucket Drive, Mechanicsburg, PA 17050: no answer, Using our white pages database our office was unable to locate any neighbors for 4204 Nantucket Drive, Hampden, PA 17025. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 03-28-14 we reviewed the National Address database and found the following information: Madhavan A. Suseelan - 4204 Nantucket Drive, Hampden, PA 17025. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: 4204 Nantucket Drive, Hampden, PA 17025. V. OTHER INQUIRIES A. DEATH RECORDS As of 03-28-14 Vital Records and all public databases have no death record on file for Madhavan A. Suseelan. VL ADDITIONAL INFORMATION OF SUBJECT A. YEAR OF BIRTH Madhavan A. Suseelan -1943 * Our accessible databases have been checked and cross-referenced for the above named individual(s). * Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S. S. 4904 relating to unsworn falsification to authorities. A e. ' The above information is obtained from available public records and we are only liable for the cost of the affidavit. Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 F.AX#: 215-568-7616 Noeleen R. Urmson Ext. 1469 Representing Lenders in Service Department Pennsylvania July 31, 2014 MADHAVAN A. SUSEELAN 4204 NANTUCKET DRIVE MECHANICSBURG, PA 17050-9105 RE; PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. v. MADHAVAN A. SUSEELAN Premises Address: 4204 NANTUCKET DRIVE, MECHANICSBURG, PA 17050-9105 CUMBERLAND County, No. 14 -3306 -CIVIL Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, service of the complaint by first class mail and post ino. of the mortgaged premises. Please respond to me within one week, by Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 944977 Name and ALldtess Of Sender Phelan VIallnum.1„.1,P 10'7 JfK Boulevard, Suite 1800 One, Penn CentA er Plaza Philade ia, A. Suseelan Madhavan 4204 NANTUCKET DRIVE MECIINNICSBURG, t7050-9105 'NW NoTohcv of Piozes Liqta tvy Solider ail Surnher of Pica, 1Wetveil at No0 OffIce Poitroastct, it4ame of Itccep: tog, tiow‘ol:te) P11 # 9449'7711021 te tun clasatioo of wittc topottl att &Illtsttx: aroLi antemation. gi,totti 11}151 1St M tOt tht teCk1ilitrUCAWO 000negoiohte ototorlt,; tauottert,,mut," ret4,11,1titictIon rt0c 501'0:.% al htutt S.5.00.000 per occootocs MAX-1119.11nirAkOnity oaf ptc, The rroxiolont ktactoility vulyabit tzi,t;t0Aa nua, Wirn otAtemal ovastati,t, 5913 403 Sq2.1 tiootowioo, ,ovo.t 'orU 3W17 a csiml 9449-17 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Court of Common Pleas SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, Civil Division SUCCESSOR BY MERGER TO NATIONAL • CITY MORTGAGE, INC., FORMERLY KNOWN •CUMBERLAND County AS NATIONAL CITY MORTGAGE CO. Plaintiff No. 14 -3306 -CIVIL vs. MADHAVAN A. SUSEELAN Defendant ORDER AND NOW, this "`1` day of 4-5k, , 2014, upon consideration of Plaintiff's motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED, that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and of the Notice of Sheriffs Sale as authorized by Pa.RCP. 3129.2 (c)(1)(i)(C)*, on the above captioned Defendant, MADHAVAN A. SUSEELAN, by: 1. Posting of the premises: 4204 NANTUCKET DRIVE, MECHANICSBURG, PA 17050-9105 by the Sheriff or a non-party competent adult; and 2. First class mail to MADHAVAN A. SUSEELAN at the mortgaged premises located at 4204 NANTUCKET DRIVE, MECHANICSBURG, PA 17050-9105. Service by mail is complete upon the date of mailing. PH # 944977/NRU tit It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to ensure compliance with this Court Order. BY T E COU *Prior to fulfilling the requirements of service of Notice of Sale as set forth i this Order, Plaintiff must first attempt service as set forth in Pa.RCP. 3129.2(c)(1)(i) (A) or (B). In the e ent this attempted service is not successful, Plaintiff may proceed with service of the Notice of Sale in confor ity with this Order. Cc:MADHAVAN A. SUSEELAN 4204 NANTUCKET DRIVE, MECHANICSBURG, PA 17050-9105 n PH # 944977/NRU n CUI Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 i. JLED-tj�• Ut,.. THE PROTHCAOTAEt r 2014 AUG 27 AN 9:57 CUMBERLAND COUNTY PENNS YLVANIA Attorney For Plaintiff PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. Plaintiff v. MADHAVAN A. SUSEELAN Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 14 -3306 -CIVIL PRAECIPE TO THE PROTHONOTARY: ❑ Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ® Please mark the above referenced case Settled, Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑ Please acate he Judgment entered. Date: PH # 944977 PHELA ALLIN By: Justin F. Koeski, Esq., Id. No.200392 Attrrney for Plaintiff LLP Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff PNC BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. Plaintiff v. MADHAVAN A. SUSEELAN Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 14 -3306 -CIVIL CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: MADHAVAN A. SUSEELAN 4204 NANTUCKET DRIVE MECHANICS iBURQ, PA 17050-9105 Date: obeski, Esq., Id. No.200392 torney for Plaintiff