Loading...
HomeMy WebLinkAbout14-3580 ' Supreme Court of Pennsylvania Court of Common Pleas ForProthonolan Use Only. Civil Cover Sheet Docket No: S Cumberland County 1 4 1 The information collected on this form is used solely for court administration purposes. This form does not sup lement or replace thefiling and service ofpleadings or other a ers as required by law or rules of court. S Commencement of Action: E x Complaint o Writ of Summons o Petition C ❑ Transfer from Another Jurisdiction ❑Declaration of Takia Lead Plaintiffs Name:NATIONWIDE ADVANTAGE Lead Defendant's Name: TODD E.ANTHONY AND T MORTGAGE COMPANY EVELYN R.ANTHONY I ' O N Are money damages requested? : o 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? o Yes ❑X No Name of Plaintiff/Appellant's Attorney: Martha Von Rosenstiel,Esq. o Check here if you are a Self-Represented Pro Se Litigant S ature of the C:ase: Place an"l" to the left of the ONE case category that most accurately describes vour PRLWARY CASE. If you are making snore than one type of clava_check the one that you consider most important. TORT(do not inchrde grass Tort) CONTRACT(do not Include judgments) CIVIL APPEALS 0 Intentional 0 Bx dyer Plaintiff Administrative Agencies 0 Malicious Prosecution Debt Collection:Credit Card Board of Assessment 0 Motor Vehicle Debt Collection:Other 0 Board of Elections 0 Nuisance 0 Dept.of Transportation Premises Liability 0 Starrttory Appeal:Other 5 0 Product Liability(does t,ol include »toss tort} ©Etnplo}°tnent Dispute: E 0 Slander/Libel'Defatnation Discsiriiivation C Other: ©Einploynient Dispute:Other © Zoning Board T 0 Other I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco Toxic Tort-DES Toxic Tort-Iniplant REAL PROPERTY \IISCELLANEOL'S 0 Tonic Waste Eectinent �Connnon La v/Statutory Arbitration Other: B 0 Euiineru.Doniaixr'Cendermaatiou ❑Declaratory Judgment 0 Ground Rent. Mandamus Iandlord/Tenant.Dispute 8 Non-Domestic Relations Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure:Conuuercial Quo Warranto 0 Dental Partition 0 Replevin 0 Legal 0 Quiet Title 0 Other. 0 Medical 0 Other: 0 Other Professional: Lj�dated I/If_'011 MARTHA E. VON ROSENSTIEL, P.C. 34620CFC-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 NATIONWIDE ADVANTAGE MORTGAGE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 Plaintiff �y, V. NO. TODD E. ANTHONY AND EVELYN R. ANTHONY 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Defendants 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]a 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 S' 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 / 800-990-9108 307a93 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. 34620CFC-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 NATIONWIDE ADVANTAGE MORTGAGE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 Plaintiff V. NO. TODD E. ANTHONY AND EVELYN R. ANTHONY 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Defendants CIVIL ACTION- MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Nationwide Advantage Mortgage Company, a company organized and existing under state law, with offices for the conduct of business at 1100 Locust St., Dept. 2009, Des Moines,IA 50391-2009. 2. Defendants, Todd E. Anthony and Evelyn R. Anthony are the mortgagors and real owners of premises 77 Mountain Street Rear A a/k/a 77 Mountain Street, Mount Holly Springs, PA 17065, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to Broadview Mortgage Corpoartion on October 25, 2005, which mortgage was recorded on November 2, 2005 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1929, Page 1977, secured on premises 77 Mountain Street Rear A a/k/a 77 Mountain Street, Mount Holly Springs, PA 17065 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage was then assigned to Nationwide Advantage Mortgage Company by written assignment dated October 25, 2005 and recorded on November 2, 2005 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 722, Page 831. 5. The mortgage has since been modified by Nationwide Advantage Mortgage Company dated March 22, 2013 and recorded on July 5, 2013 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instument No. 201322245. 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 January 2014 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: e Principal Balance $ 140,214.99 Interest from 12/1/2013 to 5/26/2014 at $15.37 per diem $ 2,721.05 Attorney's Fee $ 1,650.00 Pre-Acceleration Late Charges $ 391.58 NSF Fee $ 40.00 Phone Pay A/R Ret Checks $ 21.90 Property Inspection Fee $ 492.50 Total $ 145,532.02 10. Plaintiff sent to obligated defendants, mortgagors and real owners 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$145,532.02, plus per diem interest at $15.37 from May 27, 2014 to the date of judgment plus costs thereon. MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von R' V uire Heather Riloff, EsqAttorneys for Plaint VERIFICATION hereby states that he/she is the of Nationwide Advantage Mortgage Company, a corporation organized and existing under the laws of the United States of America,plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Nationwide Advantage Mortgage Company and verifies that the statements made in the foregoing Complaint in Nationwide Advantage Mortgage Company v. Todd E.Anthony and Evelyn R.Anthony relating to the property located at 77 Mountain Street Rear A a/k/a 77 Mountain Street, Mount Holly Spring,PA 17065 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. BY. aria Neel Title:Assoicate Vice President Nationwide Advantage Mortgage Company Dated: EXHIBIT . 1 5 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in Borough of Mount Holly Springs, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows,to wit: BEGINNING at an existing iron pin located in the North corner of land now or formerly of Kenneth and Sherry Anthony,recorded at Cumberland County Deed Book 31-T,page 743 and Plan Book 45,page 1.9; thence along land now or formerly of Hempt Bros., Inc., South 38 degrees 3 minutes 33 seconds East, a distance of 90.61 feet to a set iron pin;thence along the Northwest border of Lot No. I on the hereinafter Plan of Lots, South 43 degrees 59 minutes 21 seconds West, a distance of 236.24 feet to a set concrete monument; thence along land now or formerly of Michael L. Gumby,North 43 degrees 38 minutes 48 seconds West, a distance of 90 feet to an existing iron pin;thence along land now or formerly of Hempt. Bros., Inc.,North 43 degrees 59 minutes 21 seconds East, a distance of 241.93 feet to an existing iron pin,the place of BEGINNING. CONTAINING 0.4925 acres and being Lot No. 2 on a final subdivision plan for Kenneth Anthony by Eric L. Diffenbaugh, Professional Land Surveyor, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 68 page 7. i HAVING THEREON erected a dwelling known and numbered as 77 Mountain Street-Rear A. UNDER AND SUBJECT, nevertheless,to all restrictions,reservations, conditions, covenants, easements and rights of way of prior record. PARCEL IDENTIFICATION NO: 23-32-2338-078.,CONTROL#: 23000750 i i EXHIBIT II L fi Nationwide Advantage Mortgage Company PO Box 9100 Temecula,CA 92589-9100 PRESORT First-Class Mail U.S.Postage and Fees Paid It 11 1 11 It 1 111 IN 11 111111 It 1111111 lit 11111 RIII W SO Send Payments to: 7196 9006 9297 1594 2455 Nationwide Advantage Mortgage Company PO Box 740850 Cincinnati,OH 45274-0850 20140107-166 I�till�tl�ll ��i�r �I,I�I�I��Ill�i��lllll�'I��lulh�lltllirili Send Correspondence to: Nationwide Advantage Mortgage Company EVELYN R ANTHONY PO Box919000 77 MOUNTAIN ST Des Moines,IA 50391-9000 MOUNT HOLLY SPRINGS, PA 17065 PA ACT91 Nationwide Advantage Mortgage Sent Via Certified Mail t 7196 9006 9297 1594 2455 01/03/2014 EVELYN R ANTHONY 77 MOUNTAIN ST MOUNT HOLLY SPRINGS, PA 17065 Loan Number: Property Address: 77 MOUNTAIN ST MOUNT HOLLY SPRINGS, PA 17065 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FO:R.ECLOSUIZ.E 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 (HEMA.P) may be able to help save your home. This Notice explains how the program works. To see if HEM:AP 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 phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of the Notice If you have any questions ,you may call the Pennsylvania I1:ousingFinance Agency toll-free at(860) 342-2397. (Persons with impaired bearing 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 IMPO:RTANCIA, PLIES AFECTA SU D:ERECH.O A CONTINUAR VIVIE.NDO EN SU CASA. Sl NO COMPRENDE EL CONTENIDO DE ESTA NOTI.FICACI6N OBTENGA UNA TRADUCCI6N INMED:IATAMENTE LLAMANDO ESTA AGENC.IA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE .PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA P:ERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. PA ACf91 Page 1 of 7196 9006 9297 1S94 2455 HOMEOWNER'S NAME(S): TODD:E ANTHONY EVELYN R ANTHONY PROPERTY ADDRESS: 77 MOUNTAIN ST MOUNT HOLLY SPRINGS,PA 17065 LOAN ACCT.NO.: SNOWS ORIGINAL LENDER: BROADVIEW MORTGAGE COMPANY CURRENT LENDER/SERVICER: Nationwide Advantage Mortgage Company HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR:MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, youare 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 FO:R MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice(see fol.l.owTing pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance :Program Application with one of the designated consumer credit counselingagencies 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 PI-IFA 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 h1EETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTtVIARK 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"TEMPORARYSTAY OF FORECLOSURE." PA ACT91 Page 2of6 7196 900b 9297 1594 2455 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 ACT101V, BUT IF YOUR APPLICATION.IS EVENTUALL Y 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 "Al 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 INFORtiIATI:ON PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE -(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: 77 MOUNTAIN ST MOUNT:HOLLY SPRINGS,,PA 17065 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY :MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Next Payment:Due Date: 11/01/2013 Total Monthly Payments Due: $2,148.00 (2 @$1,074.00) Late Charges: $219.26 Other Charges: Uncollected NSF Fees: $40.00 Other Fees: $21.90 Corporate Advance Balance: $0.00 Attorney Fees: $0.00 Inspection Fees: $420.50 Unapplied:Balance: 0.00 TOTAL AMOUNT PAST DUE: $2,849.66 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY(30)DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,849.66 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check certified check, or money order made payable and sent to: Standard Mail: Overni t: Nationwide Advantage Mortgage Company Nationwide Advantage Mortgage Company P.O. Box 740850 1100 Locust St.,:Dept. 2009 Cincinnati,OH 45274-0850 Des Moines, IA 50391-2009 PA ACT91 Page 3of6 7196 9006 9297 1594 2455 IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY(30)DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considereddue immediately and you may lose the chance to pay the mortgage in monthly installments. if: full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to 550.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' .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 Sheriffs Sale. You may do so by paying 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 Sheriffs 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 Sheriffs Sale of the mortgaged property could be held would be approximately 6 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 ,,kill increase the longer you wait. You may find out at anytime exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Nationwide Advantage Mortgage Company Address: 1100 Locust Street,Dept.2009 Des Moines,IA 50391-2009 Phone Number: 800-356-3442 Fax Number: 866-262-3202 EFFECT OF SHE:RIFF'S SALE-You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You ____may or X may not(CHECK ONE) sell or transfer your horne 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 other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL.THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBTOR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR:BEEIALF. PA_AC'T91 Page 4 of6 7196 9006 9297 1594 2455 • 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(3)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 CAN BE LOCATED ON THE ATTACHED LIST OF COUNSELING AGENCIES LOCATED IN THE STATE OF PENNSYVANIA In accordance with the Fair Debt Collection Practices Act,Title 15, U.S,C 1692(a),you may dispute the validity of this 0 debt,or any portion thereof, if you do so in writing within thirty(30)days after the receipt of this notice. If you dispute the validity of this debt, or any portion thereof, within this thirty(30) days period we will provide you with written verification thereof,otherwise the debt will be assumed to be valid. Sincerely, Nationwide Advantage Mortgage Company 1.100 Locust Street, Dept. 2009 Des Moines, IA 50391-2009 800-356-3442 FEDERAL LAW REQUIRES US TO ADVISE YOU THAT NATIONWIDE ADVANTAGE MORTGAGE COMPANY IS A DEBT COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED MAY BE USED FOR THAT :PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE ADEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE REPRESENTED BY AN ATTORNEY,PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE NUMBER. PA ACT91 Page5 of6 7196 9006 9297 1S94 2455 Nationwide Advantage Mortgage Company PO Box 9100 Temecula,CA 92589-9100 PRESORT First-Class Mail U.S.Postage and Fees Paid W SO Send Payments to: ?196 9DD6 9297 1594 2431 Nationwide Advantage Mortgage Company PO Box 740850 Cincinnati,01-145274-0850 20140107-166 �Ir��rlrllrnrlirrllrl�llrllrrr�llnrrrrrlllrnrlrtrrl,rr,rr Send Correspondence to: Nationwide Advantage Mortgage Company TODD E ANTHONY PO Box 919000 77 MOUNTAIN ST Des Moines,IA 50391-9000 MOUNT HOLLY SPRINGS, PA 17065 PA ACT91 Nationwide Advantage Mortgage" Sent Via Certified Mail 7196 9006 9297 1594 2431 01/03/2014 TODD E ANTHONY 77 MOUNTAIN ST MOUNT HOLLY SPRINGS, PA 17065 Loan Number: Property Address: 77 MOUNTAIN ST MOUNT HOLLY SPRINGS, PA 17065 ACT 91 NOTICE TAIL:" ACTION TO SAVE YOUR HOME FROM FOIZECL0SU]'%'E This is an official Notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save vour home. This Notice explains how the program works. To see if HEMA:P 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 phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of the Notice If you have any questions you mU call the Pennsylvania Ilousing Finance Agency toll-free at(800) 342-2397. (Persons with impaired bearing 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECH.O A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAci6N OBTENGA UNA TRADUCCI6N :INMEDIATAM.ENTE LLA.MANDO ESTA AGENCIA (PENNSY:LVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUM.ERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Ell PA ACC91 Page 1 of6 7196 9006 9297 1594 2431 HOMEOWNER'S NAME(S): TODD E ANTHONY EVELYN R ANTHONY PROPERTY ADDRESS: 771NTOUNTAIN ST MOUNT HOLLY SPRINGS,PA 17065 LOAN ACCT.NO.: saga ORIGINAL LENDER: BROADVIEW MORTGAGE COMPANY CURRENT LENDER/SERVICER. Nationwide Advantage Mortgage Company HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE:MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983(THE"ACT"),YOU MAY BE ELIGIBLE.FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty(30)days from the date of this Notice (plus three(3)days for mailing). During that time you must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT":EXPLAINS HOW TO BRING YOURMORTGAGE 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 tender may NOT take action against you for thirty(30)days after the date of this meeting. The name,;, addresses, and telephone numbers of designated consumer credit counseling agencies for the countyin 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 Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice, Only consumer credit counseling agencies have applications for the program,and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to P14FA and received within thirty(30)days of your face-to-face meeting with the counseling agency, C, 0 C, YOU SHOULD FILE A HEM4P 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 -TEMPORARYSTAY OF FORECLOSURE." PA ACT91 Page 2 of 6 7196 9006 9297 1594 2431 ' 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,1 THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULDI NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE:DEBT. 1 (If you have filed bankruptcy,you can still apply for Emergency.Mortgage Assistance.) _..---------------------------------------......-------------------------------------------------------------------------------------------.-------- --.3 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: 77 MOUNTAIN ST MOUNT HOLLY SPRINGS,PA. 17065 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY :MORTGAGEE PAYMENTS for the following months and the following amounts are now past due: Next Pavinent.Due Date: 11/01/2013 Total Monthly Payments Due: $2,148.00 (2 L$1,074.00) Late Charges: $219.26 Other Charges: Uncollected'NSF Fees: $40.00 Other Fees: $21.90 Corporate Advance Balance: $0.00 Attorney Fees: $0.00 Inspection Fees: $420.50 Unapplied Balance: 0.00 TOTAL AMOUNT PAST DUE: $2,849.66 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, WI-IICI-1 IS $2,849.66 PLUS ANY MORTGAGE :PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaMents must be made either by cash. cashier's check certified check, or money order made payable and sent to: Standard Mail: Overnight: Nationwide Advantage Mortgage Company Nationwide Advantage Mortgage Company P.O. Box 740850 1100 Locust St.,Dept. 2009 Cincinnati,OH 45274-0850 Des Moines, IA 50391-2009 PA_ACT91 Page!oF6 7196 9006 9297 1594 2431 IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY(30)DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered.due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $ 0.00. Ilowever, if legal proceedings are started against you, you will have to pay all reasonable attorneys' .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 pav 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 bypaying 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 Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at anytime exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Nationwide Advantage Mortgage Company Address: 1100 Locust Street,Dept.2009 Des Moines,IA .50391-2009 Phone Number: 800-356-3442 Fax Number: 866-262-3202 EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's 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 or X. may not(CHECK ONE) 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 andcosts are paid prior to or at the sale and that other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE T:HE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. PA ACT91 Page 4of6 7196 9006 9297 1594 2431 Gv • 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(3)TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSUREPROCEEDING 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 CAN BE LOCATED ON THE ATTACHED LIST OF COUNSELING AGENCIES LOCATED IN THE STATE OF PENNSYVANIA In accordance with.the Fair Debt Collection Practices Act,Title 15, U.S.0 16920),you may dispute the validity of this debt,or any.portion thereof, if you do so in writing within thirty(30)days after the receipt of this notice. If you dispute the validity of this debt, or any portion thereof within this thirty(30) days period we will provide you with written verification thereof,otherwise the debt will be assumed to be valid. Sincerely, Nationwide Advantage Mortgage Company 1100 Locust Street,Dept. 2009 Des Moines, 1A 50391-2009 800-356-3442 FEDERAL LAW REQUIRES US TO ADVISE YOU THAT NATIONWIDE ADVANTAGE MORTGAGE COMPANY IS A DEBT COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT INDEBTEDNESS AS YOUR PERSONAL OBLIGATION—IF YOU ARE REPRESENTED BY AN ATTORNEY.PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE NUMBER. PA ACT91 Page 5 of6 7196 9006 9297 1594 2431 FORM 1 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY, 1100 Locust St., Dept. 2009 PENNSYLVANIA Des Moines, IA 50391-2009 Plaintiff vs. NO. TODD E. ANTHONY AND EVELYN R. ANTHONY 77 Mountain Street Rear A a/k/a 77 Mountain Street = Mount Holly Springs, PA 17065 4 } C> Defendants 1 D T NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the.residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First,within twenty(20) days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with 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 attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: June 09, 2014 Date Signature of Counsel or PI ' tiff 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: CUSTOMERIPRIMARY • 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? CO-BORROWER 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 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: L 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 N 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: L'ender'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 FORM 3 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY, 1100 Locust St., Dept. 2009 PENNSYLVANIA Des Moines, IA 50391-2009 Plaintiff VS. NO. TODD E. ANTHONY AND EVELYN R. ANTHONY 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Defendants 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. 1 understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY, 1100 Locust St., Dept. 2009 PENNSYLVANIA Des Moines, IA 50391-2009 Plaintiff vs. NO. TODD E. ANTHONY AND EVELYN R. ANTHONY 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Defendants 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 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 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. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 1,d1 c o CUMBERLAND COUITP; PENNSYLVANIA Nationwide Advantage Mortgage Company vs. Case Number Todd E. Anthony (et al.) 2014-3580 SHERIFF'S RETURN OF SERVICE 06/24/2014 01:15 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Shane Ayers, Friend of defendant, who accepted as "Adult Person in Charge" for Todd E. Anthony at 77 Mountain Street -Rear A a/k/a 77 Mountain St., Mt. Holly Springs Borough, Mount Holly Springs, PA 17065. RYAN BURGETT, DEPUT 06/24/2014 02:22 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Shane Ayers, friend, who accepted as "Adult Person in Charge" for Evelyn R. Anthony at 77 Mountain Street -Rear A a/k/a 77 Mountain St., Mt. Holly Springs Borough, Mount Holly Springs, PA 17065. SHERIFF COST: $51.91 June 25, 2014 (c) CountySuite Sheriff, Teleosoft. Inc. RYAN BURGETT, D SO ANSWERS, RONIV R ANDERSON, SHERIFF i ' 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 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 Plaintiff VS. TODD E. ANTHONY AND No. 14-3580 Civil EVELYN R. ANTHONY 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Defendants PLAINTIFF'S MOTION TO REMOVE CASE FROM THE CUMBERLAND COUNTY RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM Plaintiff, Nationwide Advantage Mortgage Company 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 June 24, 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, Nationwide Advantage Mortgage Company, respectfully requests this case be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. MARTHA E. VON ROSENSTIEL, P.C. BY: ��q"LAIZ, M A Heather Riloff, Esquire PA Attorney ID No. 309906 Attorney for Plaintiff 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Dated: August 26, 2014 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 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY CUMBERLAND COUNTY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 Plaintiff VS. TODD E. ANTHONY AND No. 14-3580 Civil EVELYN R. ANTHONY 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Defendants 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: TODD E. ANTHONY AND EVELYN R. ANTHONY 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 by regular first class mail, postage prepaid, deposited with the United States Postal Service on August 26, 2014. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. BY: Heather Riloff, Esq ire Attorney for Plainti Dated: August 26, 2014 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 ROSE STIEL, P.C. BY: Heather Riloff, Es r Attorney for Plainti Date: August 26, 2014 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 c-, Plaintiff VS. rr TODD E. ANTHONY AND : No. 14-3580 Civil cn r-- EVELYN R. ANTHONY 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 Defendants ORDER OF COURT • Ci AND NOW, this 3 day ofr« , 2014, the Defendants 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. CDpt'E3 /'alt 14, Ally a. Uva Kr scS'4i lcd cLV E043 /i 4L ,1 41/3ffy BY THE COURT: PLAINTIFF: Nationwide Advantage Mortgage Company DEFENDANT Todd E. Anthony and Evelyn R. Anthony SERVE UPON: Todd E. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 AFFIDAVIT OF SERVICE COURT OF COMMON PLEAS Cumberland COUNTY COURT NO. 14-3580 Civil TYPE OF ACTION XX Notice of Sheriff's Sale SPECIAL INSTRUCTIONS: please serve defendant personally Sheriffs Sale Date:3/4/2015 or adult in charge of premises T41 E SERVED Served and made known to N Defendan on t e day of l4. o'clock, r . N., at / / 7 b o.#,) 4-A;4-A;N) t �/,Ava o wealth of Penne 1j'ania, in the manner eacribed below: 011 Sr -3s P,A �.L PRO rJ; 3;6 tj 7 N1? 2l?!40Ci 30 PN 3:02 C'JHCEf,L.,',; I PE''i'Snc ��irr ©4 L e r , 20t4, et Defendant personally served. Manager/Clerk of place of lodging in which Defendant resides. Agent or person in charge of Defendant's office Adult family e4err with whom Defendant resides. iii Relationship is M. 1'ttetC_ Adult in charge of Defendant's residence who or usual place of business. Other refused to give name/relationship. _ I If • t Description: Age�Height 6e- G' t� Weight � "� `,/Di�NI CC- v " , a competent adult, being duly sworn according to law, depose and state that I personally handed 5 to N 1N1 a true and correct copy of the Notice of Sheriff's Sale issued in the captioned case on the date and at thea dress indicated above/ Sworn o and subscri befor a his rl day of 20 Notary: NOT Race W Sex f Other On the Moved day of Unknown 20. at No Answer 5.`•5"- 20 . SS NOTARIAL SEAL ' LUCILLE H CARTY Notary Public LETTERKENNY N COUNTY My Commission Expires Novi 30, 2015 o'clock . M., Defendant NOT FOUND because:.. Vacant Time of Attempt: Date of Attempt: Result: Sworn to and subscribed before me this day 200_. of Notary: By: ATTORNEY Martha E. Von Rosenstiel, P.G. 649 South Avenue, Unit 6 Secane, PA 19018 610-328.2887 AFFIDAVIT OF SERVICE PLAINTIFF: Nationwide Advantage Mortgage Company DEFENDANT Todd E. Anthony and Evelyn R. Anthony SERVE UPON: Evelyn R. Anthony 77 Mountain Street Rear A a/k/a 77 Mountain Street Mount Holly Springs, PA 17065 SPECIAL INSTRUCTIONS: please serve defendant personally or adult in charge of premises S rued and made len to l" it_ ,a4- o'clock, . M., at 'j ascribed below: / COURT OF COMMON PLEAS Cumberland COUNTY COURT NO. 14-3580 Civil TYPE OF ACTION XX Notice of Sheriff's Sale �`( �T1]�'t 34620 -DN �� :;OTAR; 2Ci10Ci 30 pt'1 3.02 COU tT¥ LAMA Sheriffs Sale Date:31412015,r� tw SERVED �t ,r f ant, or the 7 ay of , 24 y , at C mm veil/ of Penne Iva in t e mean N P Y manner � C Oil Stet N9, jV personally served. Manager/Clerk of place of lodging in which `<Defendant Adult family 1.....- with whom efendant resides. Defendant resides. Agent or person in charge of Defendant's office Relationship is Q V - I N ^ �a K/ . Adult in charge of Defendant's residence who or usual place of business. Other refused to give name/relationship. _ /1 I - 1 Descripti n: Age ewes to S e Y r A�'' f�/►� �•�/ the date and at th addfess Indicated a ove. Sworn to and subsc • - • beto`: - th • ` of ■ fr Notary: / NOT .-+.i ►, ' On the Moved N 1� day. l 4-. Weight /0 Race Bv: Sex I Other , a competent adult, being duly sworn according to Taw, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale issued in the captioned case on 1 day of - , 20 ,a1 Unknown No Answer o'clock M., Defendant NOT F Vacant NOTARIAL SEAL LUCILLE H CARTY Notary Public LETTERKENNY TWP, FRANKLIN_ COUNTY fission Expires Nov 30, 2015 Time of Attempt , Date of Attempt: Result: Sworn to and subscribed before me this day of Notary: 200 . By: ATTORNEY Martha E. Von Rosenstlel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887