Loading...
HomeMy WebLinkAbout14-3785 Supreme Co -nnsylvania A \ C COur Off commo leas For Prothonotary Use Only:il�Cb' rSh et x, C Docket No: CU BE y LIV[� }il Count rqA Pl The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or otherpapers as required by law or rules of court. Commencement of Action: S [T Complaint El Writ of Summons ® Petition © Transfer from Another Jurisdiction EJ Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T PNC Bank, N.A. Jason Rhoads; Rachelle Rhoads a/k/a Rachelle E Rho�l Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? El Yes No (check one) ®x outside arbitration limits O N Is this a Class Action Suit? rl Yes 0 No Is this an MDJAppeal? Yes El No A Name of Plaintiff/Appellant's AttorneAMANDA L. R n Urn ESQ uoc 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 M Intentional Buyer Plaintiff Administrative Agencies Q Malicious Prosecution Q Debt Collection:Credit Card Board of Assessment Motor Vehicle Debt Collection: Other Board of Elections ® Nuisance Dept.of Transportation Premises Liability Statutory Appeal:Other S Product Liability(does not include E mass tort) [3 Employment Dispute: Q Slander/Libel/Defamation Discrimination C El Other: Employment Dispute:Other Zoning Board T Q Other: I [] Other: O MASS TORT rl Asbestos N ® Tobacco Toxic Tort-DES Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS rl Toxic Waste 1l Ejectment Other: � (� Common Law/Statutory Arbitration B El Eminent Domain/Condemnation ® Declaratory Judgment 0 Ground Rent 0 Mandamus ® Landlord/Tenant Dispute Non-Domestic Relations Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY [3Mortgage Foreclosure:Commercial Quo Warranto [3 Dental E] Partition Replevin E3 Legal El Quiet Title [3 Other: E3 Medical 0 Other: Q Other Professional: Updated 1/1/2011 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN,ESQUIRE - ID#04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE -ID#34576 SHERRI J. BRAUNSTEIN,ESQUIRE - ID#90675 , ELIZABETH L. WASSALL,ESQUIRE - ID#77788 C-) _ `" JOHN ERIC KISHBAUGH,ESQUIRE - ID#33078 ro Y:: NICOLE B. LABLETTA,ESQUIRE - ID#202194 rn C-- DAVID NEEREN, ESQUIRE - ID#204252 AMANDA RAVER, ESQUIRE - ID#307028 WOODCREST CORPORATE CENTERCY 111 WOODCREST ROAD, SUITE 200 r CD CHERRY HILL,NJ 08003-3620 ' F. 856-669-5400 pleadings@udren.com - PNC Bank,N.A. COURT OF COMMON PLEAS 3232 Newmark Drive CIVIL DIVISION Miamisburg, OH 45342 CUMBERLAND County Plaintiff c U I V. JASON RHOADS 110 N ARCH ST MECHANICSBURG,PA 17055 RACHELLE RHOADS A/K/A RACHELLE E RHOADS 217 CLAY STREET ENOLA ,PA 17025 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE 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. O THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A sl b3 7S 0'� a� ESA &�Vw 3d 7��s 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt,and any information obtained will be used for that purpose. UDREN LAW OFFICES,P.C. /s/Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road,Suite 200 Cherry Hill,NJ 08003-3620 (856) 669-5400 1. Plaintiff is PNC Bank, N.A.. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: N/A Assignee: N/A Date of Assignment: N/A Recorded Date: N/A Book/Instrument#: N/A Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: Jason Rhoads,Rachelle Rhoads a/k/a Rachelle E Rhoads (hereinafter'Defendants"),are the owners of property located at 217 Clay Street, Enola,PA 17025 ,by virtue of Deed dated 08/30/2007 and recorded 09/11/2007 in Official Records Book Instrument#200735325 at Page n/a of the Public Records of Cumberland County, Pennsylvania(hereinafter the 'Property"). 3. On 08/31/2007 , Defendant(s) and/or their predecessor: RACHELLE RHOADS A/K/A RACHELLE E RHOADS promised to pay to the order of National City Mortgage a division of National City Bank ,the principal sum of $73,500.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 08/31/2007 , Defendant(s) and/or their predecessor: JASON RHOADS RACHELLE RHOADS A/K/A RACHELLE E RHOADS to secure the Note, mortgaged to National City Mortgage a division of National City Bank, the Property which is the subject of this action. The Mortgage was recorded on 09/11/2007 in Official Records Book Instrument#200735326 at Page n/a. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 10/01/2012, and all subsequent payments have not been made, and by its terms,upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s)continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $68,830.40 Accumulated Interest $8,072.91 Accumulated Late Charges $48.36 Escrow Deficit/(Reserve) $2,231.13 PRO RATA MIP/PMI $72.28 Recoverable Balance $3,316.00 Grand Total $82,571.08 The above figures are calculated to 05/14/2014: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 6.89000 %. The per diem interest accruing on this debt is $12.9900 and that sum should be added to the above date and each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at$24.18. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A" WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in. the sum of$82,571.08 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: AMANDA L. RAUER, ESQUIRE RA. L D. # 307023 VERIFICATION I Rodney Carpenter , as an Authorized Signer of the Plaintiff, PNC Bank, N.A., do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff and that the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 461 Name: Rodney Carpenter Title: Authorized Signer Company: PNC Bank, N.A. MJU#: 13020707 CASE#: 13020707-1 " A,'4dierteall Tide Insurance Company ..autanegt No.X51060 SCHEDULE C Legal Description AL1, THAT CERTAIN lot or piece of ground, situate io East Pennsboro Township, County of Cumberland, Commonwealth of Penasyl'vania, niare particularly bounded and described as follows, to wit: 13SOMING at a comer of Clay Street and Lot No. 5 on Martin's Addition; thence northwardly along said lot of ground No. 5 oue hundred thiity (130) feet to an alley; thence westwardly along said alley thirty (30) feet to Lot No.3 on said Martin's Addition; thence southwardty one hundred thirty (130) feet and through the partition wall of (rouses numbered 217 and 219 Clay Street to Clay Street; thence eastwaa-dly along said Clay Street thirty(30)feet to a pobtt,the blase of BEGINNING, HAVING THEREON ERECTED a one-Uif of 8 double franne dwellhsg House known as No. 217 Clay Street J3EJNG Lot No. 4 ou Martin's Addition. FA-3 KLIJKi=5tN I A I IUN Ut- HKIN I tU UQUUMLN 1 USPS CERTIFIED MAIL MCS T f GE- 9207 1969 0043 7100 0260 413198 6-749-98506-0000037-001-01-000-000-000-000 JASON RHOADS 217 CLAY ST ENOLA, PA 17025 Please find enclosed the ACT 91 NOTICE for Loan Number: This is an attempt to collect a debt.Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. DR674/4/11/2014/0005742109 To request information or notify us of an error regarding your account, please send a written request/notice to: PNC Mortgage; PO Box 8807; Dayton, OH 45401-8807 Exhibit A INTFRNFT RFPRINT KLHKtStN I A I IUN Ut- HKIN I LU UUUUN11=N 1 4/11/2014 ACT 91 NOTICE TAS ACTION T 0 SAVE YOUR HOME FROM FORECLOSURE 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 to save your home. This Notice explains how the program works. To see if HEMAP can help,you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your Countyare listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing 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 NOTWICACION EN ADJUNTO ES DE SUMA IMPORTANCIA,PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDINIIR SU HIPOTECA. INTFRNFT RFPRINT Kt=HKtbtN I A I IUN UI- HKIN I LU UUL;UMtN I HOMEOWNER'S NAME(S): RACHELLE E RHOADS JASON RHOADS PROPERTY ADDRESS: 217 CLAY ST ENOLA,PA 17025 LOAN ACCT.NO.: ORIGINAL LENDER: National City Mortgage a division of National City Bank CURRENT LENDER/SERVICER:PNC Mortgage 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 a33)_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 agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE --Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency 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 PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE,IN THE SECTION CALLED"TEMPORARY STAY OF FORECLOSURE". INTFRNFT RFPRINT KLIJKLbLN I A I IUN UI- HKIN I LU UUUUMLN 1 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. AGENCYCA TION --Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 217 CLAY ST ENOLA,PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $639.71 for 10/1/2012 - 12/1/2012, $653.66 for 1/1/2013 - 12/1/2013, $645.29 for 1/1/2014-4/1/2014. Monthly Payments Accrued: $12,344.21 Late Charges Accrued: $48.36 Non-Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $168.00 Speedpay Fees: $0.00 TOTAL AMOUNT PAST DUE: $12,560.57 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 $12,560.57, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (3 0)DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: PNC Mortgage,A Division of PNC Bank,NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 INTFRNFT RFPRINT KLHKtStN I A I IUN Uf HKIN I tU UUUUMtN I 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$50.00.However, if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed$50.00.Any attorney's fees will be added to the amount you owe the lender,which may also include other reasonable costs. If you cure the default within the THIRTY(30)DAY period,you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY(30)DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any time up to one hour before the 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 bynerforming_any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 10 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 any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg,OH 45342 Phone Number: (800) 523-8654 Fax Number: (855)201-6325 Contact Person: Collections Center E-Mail Address: LossMitigation@pncmortgage.com 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 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 home to a buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. INTFRNFT RFPRINT KtF'KtStN I A I IUN Ut- HKIN I LU UUUUMtN I YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling Service/CCCS of Western PA 2000 Linglestown Road Harrisburg,PA 17102 888-511-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg,PA 17104 717-232-9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York,PA 17401 717-855-2752 Maranatha 43 Philadelphia Avenue Waynesboro,PA 17268 717-762-3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg,PA 17325 717-334-1518 PHFA 211 North Front Street Harrisburg,PA 17110 717-780-3940 800-342-2397 INTFRNFT RFPRINT KLNKLSLN I A l IUN UI- HKIN I LU U(JUUMLN I USPS CERTIFIED MAIL 9207 1969 0043 7100 0260 4132 11 0-749-98506-0000039-001-01-000-000-000-000 RACHELLE E RHOADS 110 N ARCH ST MECHANICSBURG, PA 17055 Please find enclosed the ACT 91 NOTICE for Loan Number: This is an attempt to collect a debt.Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage,a division of PNC Bank, National Association will only exercise its rights against the property itself, and is not attempting to collect the discharged debt from you personally. DR674/4/11/2014/0005742109 To request information or notify us of an error regarding your account, please send a written request/notice to: PNC Mortgage; PO Box 8807; Dayton, OH 45401-8807 INTFRNFT RFPRINT Kth'KtStN I A I IUN OF HKIN I LU UODUMtN 1 4/11/2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage onon 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 to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing 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,PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDI IIR SU HIPOTECA. INTFRNFT RFPRINT Kt:HKtStN I A I IUN OF HKIN I LU UODUMtN I HOMEOWNER'S NAME(S): RACHELLE E RHOADS JASON RHOADS PROPERTY ADDRESS: 217 CLAY ST ENOLA,PA 17025 LOAN ACCT.NO.: ORIGINAL LENDER: National City Mortgage a division of National City Bank CURRENT LENDER/SERVICER:PNC Mortgage 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 a3LDAYS 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 agency 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 propeM 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 PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE,IN THE SECTION CALLED"TEMPORARY STAY OF FORECLOSURE". INTFRNFT RFPRINT KtNKtbtN I H I IUN OF HKIN I tU UUUUMtN 1 YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION --Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE.DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 217 CLAY ST ENOLA,PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $639.71 for 10/1/2012 - 12/1/2012, $653.66 for 1/1/2013 - 12/1/2013, $645.29 for 1/1/2014-4/1/2014. Monthly Payments Accrued: $12,344.21 Late Charges Accrued: $48.36 Non-Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $168.00 Speedpay Fees: $0.00 TOTAL AMOUNT PAST DUE: $12,560.57 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 $12,560.57,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: PNC Mortgage,A Division of PNC Bank,NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 INTFRNFT REPRINT KtF'KtStN I A I IUN UI- NKIN I EU UUUUMtN I 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$50.00. However, if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00.Any attorney's fees will be added to the amount you owe the lender,which may also include other reasonable costs.If you cure the default within the THIRTY(30)DAY period,you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY(30)DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any up to one hour before the Sheriffs Sale You may do so by paving the total amount then past due,plus my 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 a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 10 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 any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg,OH 45342 Phone Number: (800) 523-8654 Fax Number: (855)201-6325 Contact Person: Collections Center E-Mail Address: LossMitigation@pncmortgage.com EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it.If you continue to live in the property after the 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 home to a buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments,charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. INTFRNFT RFPRINT KtF'KtbtN I A I IUN UF- F'KIN I tU UUUUMtN 1 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling Service/CCCS of Western PA 2000 Linglestown Road Harrisburg,PA 17102 888-511-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg,PA 17104 717-232-9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York,PA 17401 717-855-2752 Maranatha 43 Philadelphia Avenue Waynesboro,PA 17268 717-762-3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg,PA 17325 717-334-1518 PHFA 211 North Front Street Harrisburg,PA 17110 717-780-3940 800-342-2397 INTFRNFT RFPRINT QPNC KtF'KtStN I H I IUN Ut- F'KIN I tU UUt_.UMtN 1 USPS CERTIFIED MAIL 9207 1969 0043 7100 0260 4132 28 2-749-98506-0000040-001-01-000-000-000-000 JASON RHOADS 110 N ARCH ST MECHANICSBURG, PA 17055 Please find enclosed the ACT 91 NOTICE for Loan Number: This is an attempt to collect a debt.Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation,and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage,a division of PNC Bank, National Association will only exercise its rights against the property itself,and is not attempting to collect the discharged debt from you personally. DR674/4/11/2014/0005742109 To request information or notify us of an error regarding your account, please send a written request/notice to: PNC Mortgage; PO Box 8807; Dayton, OH 45401-8807 INTFRNFT RFPRINT KtHKtStN I A I IUN Ut- HKIN I LU UUUUMtN 1 4/11/2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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 (HEMAPI may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help,,you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing 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 EVIPORTANCIA,PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. IRITFRNFT RFPRINT KtF'FKtStN I A I IUN UF- HKIN I LU UUUUMtN I HOMEOWNER'S NAME(S): RACHELLE E RHOADS JASON RHOADS PROPERTY ADDRESS: 217 CLAY ST ENOLA,PA 17025 LOAN ACCT.NO.: ORIGINAL LENDER: National City Mortgage a division of National City Bank CURRENT LENDEPUSERVICER:PNC Mortgage 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 YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES --If you meet with one of the consumer credit counseling agency 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 conn in which the roe 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 PHFA and received within thirty (30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A IIEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE,IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". INTFRNFT RFPRINT KtF'KtStN I A 11UN Ut- HKIN I tU UUUUMtN 1 YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION --Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE:IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 217 CLAY ST ENOLA,PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $639.71 for 10/1/2012 - 12/1/2012, $653.66 for 1/1/2013 - 12/1/2013, $645.29 for 1/1/2014-4/1/2014. Monthly Payments Accrued: $12,344.21 Late Charges Accrued: $48.36 Non-Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $168.00 Speedpay Fees: $0.00 TOTAL AMOUNT PAST DUE: $12,560.57 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 $12,560.57, 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: PNC Mortgage,A Division of PNC Bank,NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 INTFRNFT REPRINT Kth'KtStN I H I IUN UI- NKIN I tU UUUUMtN I 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 $50.00. However, if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00.Any attorney's fees will be added to the amount you owe the lender,which may also include other reasonable costs. If you cure the default within the THIRTY(30)DAY period,you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY(30)DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paying the total amount then past due, lus 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 a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 10 months from the date of this Notice.A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course,the amount needed to cure the default will increase the longer you wait.You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg,OH 45342 Phone Number: (800)523-8654 Fax Number: (855)201-6325 Contact Person: Collections Center E-Mail Address: LossMitigation@pncmortgage.com 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 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 home to a buyer or transferee who will assume the mortgage debt,provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. INTFRNFT RFPRINT KtF'KtStN I H I IUN Ut- F'KIN I LU UUUUMtN I YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling Service/CCCS of Western PA 2000 Linglestown Road Harrisburg,PA 17102 888-511-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg,PA 17104 717-232-9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York,PA 17401 717-855-2752 Maranatha 43 Philadelphia Avenue Waynesboro,PA 17268 717-762-3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg,PA 17325 717-334-1518 PHFA 211 North Front Street Harrisburg,PA 17110 717-780-3940 800-342-2397 j INTFRNFT RFPRINT F KLt'KLSLN I A I IUN Ut- HKIN I LU UUUUMLN I USPS CERTIFIED MAIL MOUGAGE" 9207 1969 0043 7100 0260 4132 04 3-749.98506-0000038-001-01-000-000-000-000 RACHELLE E RHOADS 217 CLAY ST ENOLA, PA 17025 Please find enclosed the ACT 91 NOTICE for Loan Number: This is an attempt to collect a debt.Any information obtained will be used for that purpose. However, if you have received a discharge in bankruptcy affecting our right to collect your loan as a personal obligation, and if the loan was not reaffirmed in the bankruptcy case, PNC Mortgage, a division of PNC Bank, National Association will only exercise its rights against the property itself,and is not attempting to collect the discharged debt from you personally. DR67014/11/2014/0005742109 To request information or notify us of an error regarding your account, please send a written request/notice to: PNC Mortgage; PO Box 8807; Dayton, OH 45401-8807 INTFRNFT RFPRINT Kth'KtStN I A I IUN UI- NKIN I LU UUC:UMtN 1 4/11/2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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 to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agenc. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing 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 NOTIFICACIUN EN ADJUNTO ES DE SUMA IMPORTANCIA,PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. INTFRNFT RFPRINT KtF'KCStN I A 11UN Uf NKIN I CU UUUUMtN I HOMEOWNER'S NAME(S): RACHELLE E RHOADS JASON RHOADS PROPERTY ADDRESS: 217 CLAY ST ENOLA,PA 17025 LOAN ACCT.NO.: ORIGINAL LENDER: National City Mortgage a division of National City Bank CURRENT LENDEPUSERVICER:PNC Mortgage 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 ka3LDAYS 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 agency 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 propeM 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 PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE,IN THE SECTION CALLED"TEMPORARY STAY OF FORECLOSURE". INTFRNFT REPRINT KtF'KtStN I H I IUN UF- HNIN I tU UUGUMtN I YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION --Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE:IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at: 217 CLAY ST ENOLA,PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $639.71 for 10/1/2012 - 12/1/2012, $653.66 for 1/1/2013 - 12/1/2013, $645.29 for 1/1/2014-4/1/2014. Monthly Payments Accrued: $12,344.21 Late Charges Accrued: $48.36 Non-Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $168.00 Speedpay Fees: $0.00 TOTAL AMOUNT PAST DUE: $12,560.57 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 $12,560.57, 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: PNC Mortgage,A Division of PNC Bank,NA Attention: Collections Center 3232 Newmark Drive Miamisburg, OH 45342 INTFRNFT RFPRINT KtF'KLbLN I A I IUN UF KIN I LU UUUUMtN I 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$50.00. However, if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed$50.00.Any attorney's fees will be added to the amount you owe the lender,which may also include other reasonable costs.If you cure the default within the THIRTY(30)DAY period,you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY(30)DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any time up to one hour before the 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 a Sheriff s Sale of the mortgaged property could be held would be approximately 9 to 10 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 any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg,OH 45342 Phone Number: (800)523-8654 Fax Number: (855)201-6325 Contact Person: Collections Center E-Mail Address: LossMitigation@pncmortgage.com EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You may 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 and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. INTFRNFT RFPRINT KLHKtStN I A I IUN UI- HKIN I LU UUUUMtN I YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling Service/CCCS of Western PA 2000 Linglestown Road Harrisburg,PA 17102 888-511-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg,PA 17104 717-232-9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York,PA 17401 717-855-2752 Maranatha 43 Philadelphia Avenue Waynesboro,PA 17268 717-762-3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg,PA 17325 717-334-1518 PHFA 211 North Front Street Harrisburg,PA 17110 717-780-3940 800-342-2397 INTFRNFT REPRINT FORM 1 111,THE COURT CUMBERLAND COUNTY,EPLEAS� PENNSYLVANIA Plaintiff(s) 10 z vs. )OXSOV-) 1�410AJS�S+OJ F� Defendant(s) + qCivil (P-V --a NOTICE OF RESIDENTIAL MORTGAGE FORECLOS DIVERSION PROGRAM �f You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference. First, within twenty(20)days of your receipt of this notice,you must contact MidPenn.Legal Services at.(717)243-9400 extension 2510 or(800) 822-5288 extension 2510 and request.appointment of a legal representative at no charge to you. Once you.have been appointed.a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date. During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached-hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you d.o 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 arerepresented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference.. Itis not necessary foryou 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. I Respect full miffed: Date [Signatre of for Plaintiff) AMANDA . PARI P, ESQUIRE PA. I.D. # 307028 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 PIease provide the following information to the best of your knowledge: C1JST0MER/PRIMARY Borrower narne(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other Email: #of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You.Closed Your.Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes,provide names, location of court, case number&attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Other transportation.(automobiles,boats,motorcycles): .Model: Year: Amount owed: Value Monthly Income Name of Employers: l.. 2. Additional Income Description(not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2° Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med.(not covered) Auto fuel/repairs Other prop.payment Install.Loan Payment Cable TV Child.Su ort/Alim. Spending Money Day/Chi ld Care/Tu it. Other Expenses i Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes 0 No Q If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: 2 i .......................-............_......._...........................-......I....._........ --........- - Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)assistance? Yes ❑ No ❑ If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes.please indicate the status of those negotiations: Please provide the following information, if know,regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. L/We understand that I/we amiare under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of income Past 2 bank statements Proof of any expected income for the last 45 days V Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation ! (hardship letter) Y Listing agreement(if property is currently on the market) 3 V FORM 3 IN THE COURT OF COMMON PLEAS OF Y : CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff(s) vs. Defendant(s) CIVIL 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 false statements are made subject to the penalties of 1.8 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 I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY. MARK J. UDREN, ESQUIRE- ID#04302 STUART WINNEG,ESQUIRE -ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J.BRAUNSTEIN,ESQUIRE - ID#90675 ELIZABETH L.WASSALL,ESQUIRE -ID#77788 JOHN ERIC KISHBAUGH,ESQUIRE -ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN,ESQUIRE -ID#204252 AMANDA RAVER,ESQUIRE - ID#307028 z ' C7 WOODCREST CORPORATE CENTER !--� =� } 111 WOODCREST ROAD, SUITE 200 �� CHERRY HILL, NJ 08003-3620 856-669-5400 - co =� Pleadings@udren.com PNC Bank,N.A. COURT OF COMMON PLEAS 3232 Newmark Drive,Miamisburg,OH 45342 CIVIL DIVISION Plaintiff CUMBERLAND County V. NO. / v/- S7�'S lr� Jason Rhoads 110 N Arch St Mechanicsburg,PA 17055 Rachelle Rhoads a/k/a Rachelle E Rhoads 217 Clay Street Enola,PA 17025 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J.Udren,Esquire; Stuart Winneg,Esquire; Lorraine Gazzara Doyle,Esquire; Sherri J.Braunstein,Esquire; Elizabeth L.Wassall,Esquire;John Eric Kishbaugh, Esquire;Nicole B.LaBletta,Esquire;David Neeren,Esquire,and Amanda Rauer,Esquire on behalf of the Plaintiff, in the above-captioned matter. UDREN ES,P.C. AM y ESQUIRE P 307028 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r THE PROII-HDNU11P, t 21 JUL -9 Ati 9: 37 CUMBERLAND COUNTY op��U, of Cirinbrr1y OFFICE OF THE WERIFF PNC Bank, N.A. vs. Jason Rhoads (et al.) Case Number 2014-3785 SHERIFF'S RETURN OF SERVICE 06/30/2014 04:03 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jason Rhoads, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 217 Clay Street, East Pennsboro/W. Fairview, Enola, PA 17025. Residence is vacant. 06/30/2014 04:03 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Rachelle Rhoads, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 217 Clay Street, East Pennsboro/W. Fairview, Enola, PA 17025. Residence is vacant. 07/02/2014 05:42 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Rachelle Rhoads at 110 N. Arch Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. J DIMARTLE, DEPUTY 07/02/2014 05:42 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Jason Rhoads at 110 N. Arch Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. MIE DIMARTLE, DEPUTY SHERIFF COST: $72.25 SO ANSWERS, July 03, 2014 (c) CountySuite Sheriff, Teleosoft. Inc. RONNY R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, N.A. 3232 Newmark Drive Miamisburg, OH 45342 Plaintiff v. Jason Rhoads 110 N Arch St Mechanicsburg, PA 17055 Rachelle Rhoads a/k/a Rachelle E Rhoads 110 N Arch St Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: C) Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), JASON RHOADS; RACHELLE RHOADS A/K/A RACHELLE E RHOADS; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Escrow Per Complaint PRO RATA MIP/PMI Recoverable Balance Grand Total FROM TO 05/15/2014 09/15/2014 $68,830.40 $8,072.91 $1,610.76 $48.36 $2,231.13 $72.28 $3,316.00 $84,181.84 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES ARE HEREBY ASSESSED AS.INDICATE DATE: °11 t11• MJU#: 13020707 CASE#: 13020707-1 UDREN LAW OFFICES, P.C. ''BY: 11 to -Ce P Attorney for Plaintiff'`, ct th CL)c3S1 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WLNNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN ESQUIRE - ID#90675 ELIZABETH L. WASSALL, ESQUIRE - ID#777 JOHN ERIC KLSHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 AMANDA RAUER, ESQUIRE - ID#307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadiugs@udreia.com PNC Bank, N.A. 3232 Newmark Drive Miamisburg, 011 45342 Plaintiff v. JASON RHOADS 110 N ARCH ST MECHANICSBURG, PA 17055 RACHELLE RHOADS A/K/A RACHEILE E RHOADS 217 CLAY STREET ENOLA , PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF 3.16c vi COURT OF COMMON PLEAS l MEL DIVISION CUMBERLAND County NO. COMPLAINT IN MORTGAGE FORECLOSURE —4 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 IURING A 507-0,-)cn Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY tviii GM 0°11' reN OFFICE OF THE Sl -f MVP PNC Bank, N.A. Case Number vs. Jason Rhoads (et al.) 2014-3785 SHERIFF'S RETURN OF SERVICE 06/30/2014 04:03 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jason Rhoads, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Prograrn and Complaint in Mortgage Foreclosure as "Not Found" at 217 Clay Street, East PennsborolW. Fairview, Enola, PA 17025. Residence is vacant. 06/30/2014 04:03 PM - Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search and inquiry for the within named Defendant to wit Rachelle Rhoads, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore retums the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 217 Clay Street, East Pennsboro/W. Fairview, Enola, PA 17025. Residence is vacant. 07/02/2014 05:42 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Rachelle Rhoads at 110 N. Arch Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. E DIMARTLE, DEPUTY 07/02/2014 05:42 PM - Deputy Jamie DiMartle, being duly swom according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Jason Rhoads at 110 N. Arch Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. PIEaWL DiMARTLE, DEPUTY SHERIFF COST: $72.25 SO ANSWERS, July 03, 2014 (o CountySuiva Sheriff, 1etosoft Inc UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY MIL, NJ 08003-3620 856-669-5400 PNC Bank, N.A. Plaintiff v. Jason Rhoads, Rachelle Rhoads a/k/a Rachelle E Rhoads Defendant(s) TO: Jason Rhoads 110NArch St Mechanicsburg, PA 17055 Date of Notice: September 2, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE I NO. 14-3785 Civil IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. BY: ES, P tiff A AMANDA :. 'AUER. ESQUIRE PA. 4.D. # 307028 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 13020707 CASE#: 13020707-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, N.A. Plaintiff v. Jason Rhoads, Rachelle Rhoads a/k/a Rachelle E Rhoads TO: Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil Rachelle Rhoads a/k/a Rachelle E Rhoads 110NArch St Mechanicsburg, PA 17055 Date of Notice: September 2, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICJNA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMA ! OBTAINED WILL BE USED FOR THAT PURPOSE. BY: CES, PC. or Plaintiff AMANDA L. RAISER, ESQUIRE PA. L.D. # 307028 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJ1J#: 13020707 CASE#: 13020707-1 Pennsylvania Office 100 W. 3rd Ave. Suite 200 Conshohocken, PA 19428 (PH) 215-568-9500 Mark,. Udren, Esq. Licensed: PA, NJ, II UDREN LAW OFFICES, P. C. New Jersey Office Woodcrest Corporate Center 111 Woodcrest Rd. Suite 200 Cherry Hill, NJ 08003 (PH) 856-669-5400 (FX) 856-669-5399 www.udren.com Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 Florida Office 2101 W. Commercial Blvd Suite 5100 Fort Lauderdale, FL 33309 (PH) 954-378-1757 (FX) 954-378-1758 Re: PNC Bank, N.A. vs. JASON RHOADS, RACHELLE RHOADS A/K/A RACHELLE E RHOADS, Cumberland County C.C.P. No. 14-3785 Civil MJU#: 13020707 CASE#: 13020707-1 Dear Sir or Madam: Enclosed please find Affidavit of Non -Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non -Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance in this matter. Sincerely yours, Kevin Kerr Foreclosure Specialist MJU/ Enclosures MJU#: 13020707 CASE#: 13020707-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingl@udren.com PNC Bank, N.A. Plaintiff v. JASON RHOADS, RACHELLE RHOADS A/K/A RACHELLE E RHOADS, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 EXHIBIT A THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), JASON RHOADS, RACHELLE RHOADS A/K/A RACHELLE E RHOADS, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: September 15, 2014 MJU#: 13020707 CASE#: 13020707-1 Attorney for =tiff p." f.77- ; • _ • , Department of Defense Manpower Data Center Status Report Pursuant to Servicerneinbers Civil. Relief Act. Last Name: RHOADS First Name: RACHELLE Middle Name: Active Duty Status As Of: Sep -15-2014 Results as of : Sep -15-2014 07:01:08 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ' •►' - - - No ' NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA , NA _ .. _ No • NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notcation End Date Status Service Component NA NA , No NA This response reflects whether the individual or his/her unit has received early notification to -report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 01. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support, This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOM Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: MDJ2H1C60010570 Department of Defense Manpower Data Center Reprt 3t to Servicemembers Civil Relief Act. Last Name: RHOADS First Name: JASON Middle Name: Active Duty Status As Of: Sep -15-2014 Results as o1: Sep -15-2014 06:59:35 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA . - _ No ' NA This response reflects the individuals' active duty status based on the Ac13ve Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA ,NA _ _ _ No ' NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Dale The Member or His/Her Unit Was Notified o1 a Fulu e Cell -Up to Active Dutyon Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No . NA This response reflects whether the. individual or hisfhher unit has received early notification to report tor active duty Upon searching the data banks of the Department of Defense Manpower Data Center,,based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOM, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: UD77L1A6E00F150 Department of Defense Manpower Data Center Ste Rart fl Servicemembcx Civil P:eiief Act. Last Name: RHOADS First Name: RACHELLE Middle Name: E Active Duty Status As Of: Sep -15-2014 Results as of : Sep -15-2014 07:01:50 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA NA No NA This response reflects the individuals' active duly lus based on the Active Duty. Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA NA - r i No' NA This response reflects where the individual left active duty stelus within 367 dayspreceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Steil Date Order Notification End Date Status Service Component NA NA - No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call 10 active service authorized by the President or the Secretary of Defense under 32 USC § 502(9 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: YDG7V1A6Q0107A0 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadinudren.co PNC Bank, N.A. v. Plaintiff Jason Rhoads Rachelle Rhoads a/k/a Rachelle E Rhoads Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 84,181.84 Interest From 09/16/2014 $ 2,208.30 to Date of Sale 03/04/2015 Ongoing Per Diem of $12.99 to actual date of sale including if sale is held at a later date. (Costs to be added) MJ14: 13020707 CASE#: 13020707-1 wxk aS C2r 1L,.SOILti akkt UDREN LAW OFFICES, P.C. Attorne or Plain i of Re sve UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings ' udren.com PNC Bank, N.A. v. Jason Rhoads Rachelle Rhoads a/k/a Rachelle E Rhoads Plaintiff Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil CERTIFICATE OF ACT 91 —c3 kc/) r ern t• ) 72, I hereby state that as the attorney for the Plaintiff in the above -captioned matter -7- zcD C7=5 El Act 91 procedures have been fulfilled' f l Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: ti Attorney or Plaintiff e UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadinls ' udren.com PNC Bank, N.A. v. Plaintiff Jason Rhoads Rachelle Rhoads a/k/a Rachelle E Rhoads Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County CD 1-..' MORTGAGE FORECLOSURES', rfl Wrn r -r1 l �- -s -0;-.~1 • NO. 14-3785 Civil C) C. AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: JASON RHOADS 110 N ARCH ST MECHANICSBURG, PA 17055 RACHELLE RHOADS A/K/A RACHELLE E RHOADS 110NARCH ST MECHANICSBURG, PA 17055 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Attorney for Plaintiff n r Ili L .. EF G I UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ! s r udren. PNC Bank, N.A. v. Plaintiff Jason Rhoads Rachelle Rhoads a/k/a Rachelle E Rhoads Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County r MORTGAGE FORECLOSURE r a NO. 14-3785 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, N.A., Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 217 Clay Street, Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Jason Rhoads 110 N Arch St Mechanicsburg, PA 17055 Rachelle Rhoads a/k/a Rachelle E Rhoads 110 N Arch St Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Jason Rhoads 110 N Arch St Mechanicsburg, PA 17055 Rachelle Rhoads a/k/a Rachelle E Rhoads 110 N Arch St Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, N.A. 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders — None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 217 Clay Street Enola, PA 17025 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: ,-� MJU#: 13020707 CASE#: 13020707-1 UDREN LAW OFFICES, P.C. Lt, BY: v l' 1! L Attorney for Plaintiff R e • Lc i'• UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, N.A. Plaintiff JASON RHOADS, RACHELLE RHOADS A/K/A RACHELLE E RHOADS Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jason Rhoads 110 N Arch St Mechanicsburg, PA 17055 CP cn rL Your house (real estate) at 217 Clay Street, Enola, PA 17025 is scheduled to be sold at the Sheriffs Sale on 03/04/2015 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $84,181.84, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, N.A. Plaintiff V. JASON RHOADS, RACHELLE RHOADS A/K/A RACHELLE E RHOADS Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil NOTICE OF SHERIFFS SALE OF REAL PROPERTY TO: Rachelle Rhoads a/k/a Rachelle E Rhoads 110 N Arch St Mechanicsburg, PA 17055 Your house (real estate) at 217 Clay Street, Enola, PA 17025 is scheduled to be sold at the Sheriffs Sale on 03/04/2015 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $84,181.84, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.cepa.net PNC BANK, N.A. Vs. JASON RHOADS RACHELLE RHOADS a/k/a RACHELLE E. RHOADS WRIT OF EXECUTION NO 14-3785 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $84,181.84 L.L.: $.50 Interest FROM 9/16/2014 TO DATE OF SALE 3/4/2015 - ONGOING PER DIEM OF $12.99 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE. Atty's Comm: Due Prothy: $2.25 Atty Paid: $221.00 Other Costs: Plaintiff Paid: Date: 9/17/14 (Seal) By: Deputy REQUESTING PARTY: Name: NICOLE LABLETTA, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 202194 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com PNC Bank, N.A. Plaintiff v. JASON RHOADS, RACHELLE RHOADS A/K/A RACHELLE E RHOADS, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: = 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. Dated: /0 (D 11 MJU#: 13020707 CASE#: 13020707-1 UDREN LAW OFFICES, P.C. B.#4 Atto eys or Plaintiff J. Eric Kishbaugh, Esquire PA ID 33078 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com PNC Bank, N.A. v. Jason Rhoads Rachelle Rhoads a/k/a Rachelle E Rhoads Plaintiff Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 PNC Bank, N.A., Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 217 Clay Street, Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Jason Rhoads 110 N Arch St Mechanicsburg, PA 17055 Rachelle Rhoads a/k/a Rachelle E Rhoads 110 N Arch St Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Jason Rhoads 110 N Arch St Mechanicsburg, PA 17055 Rachelle Rhoads a/k/a Rachelle E Rhoads 110 N Arch St Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: PNC Bank, N.A. 3232 Newmark Drive Miamisburg, OH 45342 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 217 Clay Street Enola, PA 17025 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: /0 /0 /1 MJUM 13020707 CASE#: 13020707-1 UDREN LAW OFFICES, P.C. BY: A to for Plaintiff J. Eric Kishbaugh, Esquire PA ID 33078 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, N.A. Plaintiff v. JASON RHOADS; RACHELLE RHOADS A/K/A RACHELLE E RHOADS; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): JASON RHOADS; RACHELLE RHOADS A/K/A RACHELLE E RHOADS; PROPERTY: 217 Clay Street, Enola, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 03/04/2015 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 13020707 CASE#: 13020707-1 It hit A Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 E Registered El Insured LIl COD F Certified LI Return Receipt for Merchandise n Int'l Recorded Del, n Express Mail Check Registered appropriate block for Mail: With Postal Insurance Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Recetpt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Hand ing Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 2 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 3 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 4 14-3785 CV Tenants/Occupants 217 Clay Street Enola, PA 17025 5 03/04/2015 7 I I U.S. POST' -1„ PP. jefk2: 17r • • .4144' L .7 '. zip 0800 . 02 1" 0001 • rr< 8 9 10 12 13 14 15 Total number of Pieces Listed by Sender Listed by Sender 4 Total Numb Recei ecl a Recei7charges o Pieces s Office PostmanPerR'Ilarne , ofReceiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $50,000 per p`ece subject to a limit of 5500,000 per occurrence. The maximum indemnity payable an Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling apply only to third and forth class par Is. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Jason Rhoads - MJU# 13020707-1 (Cumberland County) Rachelle Rhoads a/k/a Rachelle E Rhoads - MJU# 13020707-1 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PNC Bank, N.A. Plaintiff v. JASON RHOADS; RACHELLE RHOADS A/K/A RACHELLE E RHOADS; et al ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-3785 Civil Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: » (0 (� %iiOrMOh: io UDREN LAW OFFICES, P.C. BY. torne " for Plaintiff J. Eric Kishbaugh, Esquire PA ID 33078 PNC Bank, NA. et. al.. Plaintiff(s) vs. Jason EZhoads.,et. al., Defendant(s) r Service of Process by APS International, Ltd. 1-800-328-7171 .cps INTERNATIONAL ; APS International Plaza �7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File N: 131298-0001 AFFIDAVIT OF SERVICE -- Individual UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd.. Ste. 200 Cherry Hill, NJ 08003-3620 State of: County of: Service of Process on: Jv C> 1.a . ss. 1 „one\.(2 C. -1A 1?-\ Name of Server: Date/Titne of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: --Jason Rhoads Court Case No. Cumberland Co 14 -3785 -Civil undersigned, being duly sworn, deposes and says that at the time,, `o�fN ,sIervice. s/he was of legal age and was not a party to this action; that on they"day of 20 k4 , at y) •%o'clock M at 110 N Arch Street the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property . in Mechanicsburg. PA 17055 A true al ect copy of the aforesaid document(s) was served on: Jaso !toads S/By personally delivering them into the hands of the person to be served. 13y delivering them into the hands of a person of suitable age• who verified, or who upon questioning stated. that he/she resides with Jason Rhoads at the place of service, and whose relationship to the person is: Description of Person Th erson receiving documents is described as follows: Sex : Skin Color Orici-p : Hair ColoAn f jo iY\ : Facial Hair Apprge y • Approx. Height ° 1 Du I ; Approx. Weight Receiving Documents: Signature of Server: To the be , . y knowledge and belief. said person was not engaged in the US Military at the a of cervi e. Tatty of pe co rec orin o before me this V,, 20 i-gnature o rver APS International, Ltd. COMMONW ALTH OF PENNSY VAN1A NOTARIAL SEAL Tammie L. Crutcher, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 9, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES Notary Public / (Commission Expires) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@ udren.eom PNC Bank, N.A. Plaintiff v. JASON RHOADS, RACHELLE RHOADS A/K/A RACHELLE E RHOADS Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jason Rhoads 110 N Arch St Mechanicsburg, PA 17055 Your house (real estate) at 217 Clay Street, Enola, PA 17025 is scheduled to be sold at the Sheriffs Sale on 03/04/2015 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $84,181.84, obtained by Plaintiffabove (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 EGui05i D PNC Bank, NA. et. al., Plaintiff(s) vs. Jason Rhoads, et. al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd.. Ste. 200 Cherry Hill, NJ 08003-3620 c@)nla . ) ss. Name of Server: Date/Time of Service: Place of Service: Documents Served: Service of Process by APS International, Ltd. 1-800-328-7171 l APS 119ft.RNATtp1V,1►, / APS International Plaza 7800 Glenroy Rd. N.! Minneapolis, MN 55439-3122 APS File #: 131298-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: —Rachelle Rhoads, aka Rachelle E. Rhoads Court Case No. Cumberland Co 14 -3785 -Civil 1 `VQ LOCA, . undersigned. being duly sworn. deposes and says that at the time of service, sThe was of legal age and was not a party to this action: that on the �__ ay of he ( , 201 _. at, -':3.D1 o'clock LM in Mechanicsburg, PA 17055 at 110 N Arch Street the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Rachelle Rhoads, aka Rachelle E. Rhoads Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: By personally delivering them into the hands of the person to be served. V.-1.3.; delivering them into the hands of.T.t L R KC\S . a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Rachelle Rhoads, aka Rachelle E. Rhoads at the place of service, and whose relationship to the person is: NiS\cric The person receiving documents is described as follows: Sex • Skin Color (d1ji ¥Q ; Hair Colorhf Cx o(\ : Facial Hair Approx. Age A : Approx. Height �' I Di' : Approx. Weight To th• t of my knowledge and belief. said person was not engaged in the US Military at service. nder pena rue and co Subscribed and (vor to before me this ignatur o Server APS International, Ltd. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Tammie L. Crutcher, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 9, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES Notary Public (Commission Expires) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s udren.com PNC Bank, N.A. Plaintiff v. JASON RHOADS, RACHELLE RHOADS A/K/A RACHELLE E RHOADS Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rachelle Rhoads a/k/a Rochelle E Rhoads 110 N Arch St Mechanicsburg, PA 17055 Your house (real estate) at 217 Clay Street, Enola, PA 17025 is scheduled to be sold at the Sheriffs Sale on 03/04/2015 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $84,181.84, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) xIiibt YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE, 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sherif the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ahn D UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, Ni 08003-3620 856-669-5400 pleadings udren.com PNC Bank, N.A. Plaintiff v. JAS N RHOADS RAC LLE RHOADS A/K/A RACHELLE E RHOADS TO T DISC Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3785 Civil PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE CAA C.) ri E PROTHONOTARY: *ndly mark the above captioned matter as JUDGMENT WITHDRAWN and ACTION NTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: 11/1) MJU#: 13020707 CASE#: 13020707-1 UDREN LAW OFFICES, P.C. BY: Attome for Plaintiff e 1.6:1 ?MD 20 194 0,v0A sb-c1 01,a- Vt.-14 "-Nerc& 2--lt,c 2$ rb-PhaLdied, tro- UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin udren.com PNC Bank, N.A. Plaintiff V. JASON RHOADS RACH ELLE RHOADS A/K/A RACHELLE E RHOADS Defendant(s) nio nchLen ATTORNEY FaiitLiNtIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE n ""... NO. 14-3785 Civil PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter as JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: MJU#: 13020707 CASE#: 13020707-1 UDREN LAW OFFICES, P.C. BY: Attome for Plamtiff PO 20 194 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net PNC BANK, N.A. Vs. JASON RHOADS RACHELLE RHOADS a/k/a RACHELLE E. RHOADS NO 14-3785 Civil Term CIVIL ACTION – LAW WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $84,181.84 L.L.: $.50 Interest FROM 9/16/2014 TO DATE OF SALE 3/4/2015 - ONGOING PER DIEM OF $12.99 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE. Atty's Comm: Due Prothy: $2.25 Atty Paid: $221.00 Other Costs: Plaintiff Paid: Date: 9/17/14 11Aitaii David D. uel , Prothonot• (Seal) By: REQUESTING PARTY: Name: NICOLE LABLETTA, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 202194 Deputy TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Cart at Carlisle, Pa. This I 1 day of __#-- . , 20 .i.H.— Prothnnu'o*y