HomeMy WebLinkAbout14-4033 I
Supreme Coy ft'oUPennsylvania
COurteofCOmMo&.P1eas For Prothonotary Use Only:
Cll ><lCc►ver�Sheet
_ ,. Docket No:
CUMBER NO` County
The information collected on this form is used solely for court administration purposes. This forret does not
supplement or replace the f ling and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S El Complaint 0 Writ of Summons Petition
ril Transfer from Another Jurisdiction 0 Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
T CITIMORTGAGE, INC. JENNIFER A. NUGENT&THE UNITED STATES OF/W _
Dollar Amount Requested: Owithin arbitration limits
I Are money damages requested? 0 Yes El No ' (check one) noutside arbitration limits
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N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? 0 Yes E No
A Name of Plaintiff/Appellant's Attorney: POWERS, KIRN&ASSOCIATES, LLC
Check here if you have no attorney(are a Self-Represented (Pro Set Litigant)
Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim,check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS
Intentional [ Buyer Plaintiff Administrative Agencies
( Malicious Prosecution Debt Collection:Credit Card 13 Board of Assessment
Motor Vehicle Debt Collection:Other 0 Board of Elections
0 Nuisance El Dept.of Transportation
Premises Liability Statutory Appeal:Other
S Product Liability(does not include
E mass tort) �Employment Dispute:
El Slander/Libel/Defamation Discrimination
C 0 Other: Employment Dispute:Other Zoning Board
.j. Other:
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I Other:
! O MASS TORT
0 Asbestos
N Tobacco
Toxic Tort-DES
® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste 0 Ejectment [I Common Law/Statutory Arbitration
B Other:
Eminent Domain/Condemnation Declaratory Judgment
Ground Rent Mandamus
Landlord/Tenant Dispute Non-Domestic Relations
Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial Quo Warranto
D Dental 0 Partition Replevin
[3 Legal 0,Quiet Title 0 Other:
0 Medical 0 Other:
E] Other Professional:
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Updated 1/1/2011
' POWERS,KIRN&ASSOCIATES,LLC
Jill Manuel-Coughlin,Esquire Id.No. 63252r F/1
Jolanta Pekalska,Esquire Id.No. 307968 Ft's' D /c
Harry B.Reese,Esquire Id.No.310501 rF;'DD
Daniel C.Fanaselle,Esquire Id.No. 312292 +
Matthew J.McDonnell,Esquire Id.No. 313549 -9
1310 Industrial Boulevard, Suite 202 ��� RC j
Southampton,PA 18966 Pi Pdh/ 4 A'D CDJ
iy
(215)942-2090 ATTORNEYS FOR PLArMT4*l lA 1 y'
CITIMORTGAGE,INC. COURT OF COMMON PLEAS
1000 TECHNOLOGY DRIVE
O'FALLON,MO 63368 CIVIL DIVISION
PLAINTIFF CUMBERLAND COUNTY
vs.
NO. Iq
JENNIFER A.NUGENT COMPLAINT IN
JOSEPH WILLIAM NUGENT MORTGAGE FORECLOSURE
714 VERONICA LANE
ENOLA,PA 17025
THE UNITED STATES OF AMERICA
228 WALNUT STREET, SUITE 220
P.O.BOX 11754
HARRISBURG,PA 17108
DEFENDANTS
NOTICE
You have been sued in Court. If you'wish to defend against the claims set forth in the following pages,you must
take action within twenty(20)days after this Complaint and notice are served,by entering a written appearance personally
or by attorney and filing in writing with the court your defense 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. 1F YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S.Bedford Street
Carlisle,PA 17013
717-249-3166
800-990-9108 I l
Q
ra 103, 75�a
C (C� 3KO6
�� �8as8
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IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.0 § 1692 et seq. (1977),
DEFENDANT(S)MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF.
IF DEFENDANT(S)DO SO IN WRITING WITHIN THIRTY(30)DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S)WITH
WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE
VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY(30)DAYS OF RECEIPT OF THIS
PLEADING,COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30)DAY
PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY (20)DAYS, YOU MAY OBTAIN AN
EXTENSION OF THAT TIME. FURTHERMORE,NO REQUEST WILL BE MADE TO THE COURT
FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY(30)DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER,IF YOU REQUEST PROOF OF THE DEBT OR THE
NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY(30)DAY PERIOD
THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT,THE LAW REQUIRES US TO
CEASE OUR EFFORTS(THROUGH LITIGATION OR OTHERWISE)TO COLLECT THE DEBT
UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
POWERS,KIRN&ASSOCIATES, LLC
Jill Manuel-Coughlin,Esquire Id.No. 63252
Jolanta Pekalska, Esquire Id.No. 307968
Harry B.Reese,Esquire Id.No. 310501
Daniel C.Fanaselle,Esquire Id.No. 312292
Matthew J. McDonnell,Esquire Id.No. 313549
1310 Industrial Boulevard, Suite 202
Southampton,PA 18966
(215)942-2090 ATTORNEYS FOR PLAINTIFF
CITIMORTGAGE, INC. COURT OF COMMON PLEAS
1000 TECHNOLOGY DRIVE
O'FALLON, MO 63368 CIVIL DIVISION
PLAINTIFF CUMBERLAND COUNTY
VS. NO.
JENNIFER A.NUGENT COMPLAINT IN
JOSEPH WILLIAM NUGENT MORTGAGE FORECLOSURE
714 VERONICA LANE
ENOLA,PA 17025
THE UNITED STATES OF AMERICA
228 WALNUT STREET, SUITE 220
P.O. BOX 11754
HARRISBURG,PA 17108
DEFENDANTS
CIVIL ACTION MORTGAGE FORECLOSURE
1. CitiMortgage, Inc. (hereinafter referred to as"Plaintiff') is a Corporation with a principal
place of business in O'Fallon, Missouri.
2. Jennifer A Nugent and Joseph William Nugent(hereinafter referred to as"Defendants")
are adult individuals residing at the address indicated in the caption hereof.
3. Plaintiff brings this action to foreclose on the mortgage between Defendants and itself as
Mortgagee by Assignment. The Mortgage, dated November 28, 2008,was recorded on
July 15, 2010 in the Office of the Recorder of Deeds in Cumberland County in Mortgage
Instrument#201019053. Plaintiff is the Mortgagee by Assignment by virtue of an
Assignment of Mortgage recorded on February 27,2012. in the Office of Recorder of
Deeds in Cumberland County in Instrument#201205694.A copy of the Mortgage and
Assignment of Mortgage is attached and made a part hereof as Exhibits `A' and `B'.
s �
` 4. The Mortgage secures the indebtedness of a Note executed by Jennifer A. Nugent on
November 28, 2008 in the original principal amount of$258,445.00,which is payable to
Plaintiff in monthly installments with an interest rate of 6.125%. A copy of the Note is
attached and made a part hereof as Exhibit `C'.
5. The land subject to the mortgage is 714 Veronica Lane,Enola,PA 17025. A copy of the
Legal Description is attached as part of the Mortgage as Exhibit `A' and incorporated
herein.
6. Barbara A,Nugent,Joseph William Nugent and Jennifer A.Nugent are the Record
Owners of the mortgaged property located at 714 Veronica Lane,Enola,PA 17025.
7. Barbara A.Nugent departed this life on July 7, 2004. Title to the subject property passed
to Joseph William Nugent and Jennifer A.Nugent by operation of law. Proof of death is
attached and made a part hereof as Exhibit `D'.
8. The Mortgage is now in default due to the failure of Defendants to make payments as
they became due and owing. As a result of the default,the following amounts are due:
Principal Balance $279,345.03
Interest to 08/01/2014 $7,856.55
Accumulated Late Charges $494.75
FHA/PMI Premium to 8/1/2014 $293.55
Escrow Advance Balance $1,482.75
Less Unapplied Funds ($1,803.51)
TOTAL $287,669.12
plus interest from 08/02/2014 at$28.6998 per day, costs of suit and attorney's fees.
9. Plaintiff is not seeking a judgment of personal liability(or an in personam judgment)
against the Defendants in the Action;however,Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists.
10. If Defendants have received a discharge of personal liability in a bankruptcy proceeding,
this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal
liability discharged in bankruptcy, but only to foreclose the mortgage and sell the
mortgaged premises pursuant to Pennsylvania Law.
11. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a
defaulting mortgagor with a Notice of Homeowners' Emergency Mortgage Assistance
("Act 91 Notice")35 P.S. Section 1680.403c.
12. The Notice of Homeowners' Emergency Mortgage Assistance was required and Plaintiff
sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to
the Defendants by regular and certified mail on February 7, 2014. A copy of the Notice
is attached and made a part hereof as Exhibit `E'.
13. The United States of America is named as a party pursuant to 28 U.S.C. Section 2410
because the United States of America holds a Federal IRS Tax Lien filed against Barbara
A.Nugent on March 24, 2008(No.:2008-1863)in the amount of$35,300.86. A copy of
the Federal Tax Lien is attached and made a part hereof as Exhibit`F'.
WHEREFORE,Plaintiff requests the court enter an in rem judgment against the Defendants, in the sum
of$287,669.12,together with interest, costs, fees and charges collectible under the mortgage, including,
but not limited to attorney's fees and costs,and for the foreclosure and sale of the mortgaged property.
P ERS,KI &ASSOCIATES,LLC
BY: ./I , �04
Jill Manuel-Coughlin,Esqui,e Id.No. 63252
❑ Jolanta Pekalska,Esquire Id.No. 307968
❑ Harry B. Reese, Esquire Id.No. 310501
❑ Daniel C. Fanaselle,Esquire Id.No. 312292
❑ Matthew J. McDonnell,Esquire Id.No. 313549
Attorneys for Plaintiff
F
EXHIBIT «A
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After Recording Return To:
A GREAT MORTGAGE CO ,
INC.
921 PLEASANT LLEY AVE '
MOUNT LA ,NJ 08054
(856) -6200
Prepared By:
MARIA CONCANNON
A GREAT MORTGAGE COMPANY,
INC. i
921 PLEASANT VALLEY AVE j
MOUNT LAUREL,NJ08054
(856) 702-6200
Property Address:
i
714 VERONICA LANE
SNOLA,PA 17025 l
PN:09-12-2991-253 i
i
[Space Above This Line For Recording Data]
MORTGAGE
• NUGSNr_
Loan i
MINA. +
Case H:
THIS MORTGAGE("Security instrument")is given on NOVEMBER 28, 2008.The mortgagor is
JOSEPH WILLIAM NUGENT AND JENNIFSR A NUGENT, HUSBAND AND WIFE("Borrower").
This Security Instrument is given to Mortgage Electronic Registration Systems,Inc.("MEAS")(solely as ,
nominee for Lender,as hereinafter dcfined,and Lender's successors and assigns),as beneficiary.MERS is
organized and existing under the laws of Delaware,and has an address and telephone number of P.O.Box
2026,Flint,MI 48501-2026,tel.(888)679-MFRS.A GREAT MORTGAGE COMPANY, INC. ("Lender") s
is organized and existing under the laws of NW JERSEY, and has an address of 921 PLEASANT i
VALLEY AVS,MOUNT LAUREL,NJ 08054.Borrower owes Lender the principal sum of TWO HUNDRED
FIFTY SIGHT THOUSAND FOUR HUNDRED FORTY FIVE Dollars(U.S.$25S,445.00).This debt j
is evidenced by Borrower's note dated the same date as this Security instrument("Note"),which provides for
monthly payments,with the full debt,if not paid earlier,due and payable on JANUARY 1, 2039.This
Security.Instrument secures to Lender:(a)the repayment of the debt evidenced by the Note,with interest,
and all renewals,extensions and modifications of the Note;{b)the payment of all other sums,with interest,
advanced under paragraph 7 to protect the security of this Security instrument;and(c)the performance of j
Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose,
Borrower does hereby mortgage,grant and convey to MERE(solely as nominee for Lender and Lender's
successors and assigns)and to the succcqsors and assigns of MERS the following described property located
in cumBBRLAND County,Pennsylvania:
LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HRREOF-
which has the address of 714 VERONICA LANE,ENOLA,Pennsylvania 17025("Property Address");
TOGETHER WITH the improvements now or hereafter erected on the property,and all easements,
appurtenances,and fixtures now or hereafter a part of the property.All replacements and additions shall also
FHA PENNSYLVANIA MORTGAGE
4y 400.9 page 1 of 9
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be covered by this Security Instrument.All of the foregoing is referred to in this Security Instrument as the i
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"Property."
Borrower understands and agrees that MERS holds only legal title to the interests granted by
Borrower in this Security Instrument;but,if necessary to comply with law or custom,MERS(as nominee for
Lender and Lender's successors and assigns)has the right:to exercise any or all of those interests,including,
but not limited to,the right to foreclose and sell the Property;and to take any action required of Lender
including,but not limited to,releasing or canceling this Security'Instrument.
BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and
has the right to mortgage,grant and convey the Property and that the Property is unencumbered,except for
encumbrances of record.Borrower warrants and will defend generally the title to the Property against all
claims and demands,subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform
covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real j
property.
UNIFORM COVENANT'S.Borrower and Lender covenant agree as follows:
1.Payment of Principal,Interest and Late Charge.Borrower shall pay when due the principal of, !
and interest on,the debt evidenced by the Note and late charges due under the Note.
2.Monthly Payment of Taxes,insurance,and Other Charges.Borrower shall include in each
monthly payment,together with the principal and interest as set forth in the Note and any late charges,a sum
for(a)taxes and special assessments levied or to be levied against the Property,(b)leasehold payments or
ground rents on the Property,and(c)premiums for insurance required under paragraph 4.In any year in
which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban
Development("Secretary"),or in any year in which such premium would have been required if Lender still i
held the Security Instrument,each monthly payment shall also include either: (i) a sum for the annual I
mortgage insurance premium to be paid by Lender to the Secretary,or(ii)a monthly charge instead of a
mortgage insurance premium if this Security Instrument is held by the Secretary,in a reasonable amount to
be determined by the Secretary.Except for the monthly charge by the Secretary,these items are called
"Escrow Items"and the sums paid to Lender are called"Escrow Funds."
Lender may,at any time,collect and hold amounts for Escrow Items in an aggregate amount not to }.
exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate
Settlement Procedures Act of 1974, 12 U.S.C.Section 2601 et seg.and implementing regulations,24 CFR
Part 3500,as they may be amended from time to time ("RESPA"),except that the cushion or reserve
permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are
available in the account may not be based on amounts due for the mortgage insurance premium.
Items exceed the amounts permitted to be held by
If the.amounts held by Lender for Escrow
RESPA,Lender shall account to Borrower for the excess funds as required by RESPA.If the amounts of '
funds held by Lender at any time are not sufficient to pay the Escrow items when due,Lender may notify the
Borrower and require Borrower to make up the shortage as permitted by RESPA.
The Escrow Funds are pledged as additional security for all sums secured by this Security
Instrument.If Borrower tenders to Lender the full payment of all such sums,Borrower's account shalt be
credited with the balance remaining for all installment items(a),(b),and(c)and any mortgage insurance
premium installment that Lender has not become.obligated to pay to the Secretary,and Lender shall promptly
refund any excess funds to Borrower. immediately prior to a foreclosure sale of the Property or its i
acquisition by Lender,Borrower's account shall be credited with any balance remaining for all installments
for items(a),(b),and(c).
FHA PENNSYLVANIA MORTGAGE
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3.Application of Payments.All payments under Paragraphs i and 2 shall be applied by Lender as
follows:
First,to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly
charge by the Secretary instead of the monthly mortgage insurance premium; i
Second,to any taxes,special assessments,leasehold payments or mound rents,and fire,flood and
other hazard insurance premiums,as required;
Third,to interest due under the Note;
Fourth,to amortization of the principal of the Note;and
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t fifth to late charges due under the Note. 1
4.Fire,Flood and Other Hazard insurance. Borrower shall insure all improvements on the
Property, whether now in existence or subsequently erected, against any hazards, casualties, and
contingencies,including fire,for which Lender requires insurance.This insurance shall be maintained in the
amounts and for the periods that Lender requires.Borrower shall also insure all improvements on the
Property,whether now in existence or subsequently erected,against loss by floods to the extent required by
the Secretary.All insurance shall be carried with companies approved by Lender.The insurance policies and
any renewals shall be held by Lender and shall be include loss payable clauses in favor of,and in a form
acceptable to, Lender.
In the event of loss,Borrower shall give Lender immediate notice by mail.Lender may make proof 1.
of loss if not made promptly by Borrower.Each insurance company concerned is hereby authorized and
directed to make payment for such loss directly to Lender,instead of to Borrower and to Lender jointly.All
or any part of the insurance proceeds may be applied by Lender,at its option,either(a)to the reduction of the
indebtedness under the Note and this Security Instrument,first to any delinquent amounts applied in the order
in Paragraph 3, and then to prepayment of principal,or(b)to the restoration or repair of the damaged E
Property.Any application of the proceeds to the principal shall not extend or postpone the due date of the
monthly payments which are referred to in Paragraph 2,or change the amount of such payments.Any excess
insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this
Security Instrument shall be paid to the entity legally entitled thereto.
In the event of foreclosure of this.Security Instrument or other transfer of title to the Property that
extinguishes the indebtedness,all right,title and interest of Borrower in and to insurance policies in force
shall pass to the purchaser.
'Maintenance and Protection of the Property;Borrower's Loan
S.Occupancy,Preservation
Application;Leaseholds.Borrower shall occupy,establish,and use the Property as Borrower's principal
residence within sixty days after the execution of this Security Instrument(or within sixty days of a later sale
or transfer of the Property)and shall continue to occupy the Property as Borrower's principal residence for at
least one year after the date of occupancy,unless Lender determines that requirement will cause undue
hardship for Borrower,or unless extenuating circumstances exist which are beyond Borrowers control.
Borrower shall notify Lender of any extenuating circumstances.Borrower shall not commit waste or destroy,
damage or substantially change the Property or allow the Property to deteriorate,reasonable wear and tear
excepted.Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default.
Lender may take reasonable action to protect and preserve such vacant or abandoned Property.Borrower
shall also be in default if Borrower,during the loan application process,gave materially false or inaccurate
information or statements to Lender (or failed to provide Lender with any material information) in
connection with the loan evidenced by the Note,including,but not limited to,representations concerning
Borrower's occupancy of the Property as a principal residence.If this Security Instrument is on a leasehold,
Borrower shall comply with the provisions of the lease.If Borrower acquires fee tide to the Property,the
leasehold and fee title shall not be merged unless Lender agrees to the merger in writing.
6.Condemnation.The proceeds of any award or claim for damages,direct or consequential,in
FHA PENNSYLVANIA MORTGAGE Page 1 0{ 9
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connection with any condemnation or other taking of any part of the Property,or for conveyance in place of
condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the
indebtedness that remains unpaid under the Note and this Security instrument. Lender shall apply such
proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any
delinquent amounts applied in the order provided in Paragraph 3,and then to prepayment of principal.Any
application of the proceeds to the principal shall not extend or postpone the due date of the monthly
payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess
proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security
Instrument shall be paid to the entity legally entitled thereto.
7.Charges to Borrower and Protection of Lender's Rights in the Property.Borrower shall pay {
all governmental or municipal charges,fines and impositions that are not included in Paragraph 2.Borrower
shall pay these obligations on time directly to the entity which is owed the payment.if failure to pay would i
adversely affect Lender's interest in the Property,upon Lender's request Borrower shall promptly furnish to j
Lender receipts evidencing these payments. I
If Borrower fails to make these payments or the payments required by Paragraph 2,or fails to
Perform any other covenants and agreements contained in this Security Instrument, or there is a legal
proceeding that may significantly affect Lender's rights in the Property(such as a proceeding in bankruptcy,
for condemnation or to enforce laws or regulations),then Lender may do and pay whatever is necessary to I
protect the value of the Property and Lender's rights in the Property,including payment of taxes,hazard.
insurance and other items mentioned in Paragraph 2.
Any amounts disbursed by Lender under this Paragraph shall become an additional debt of
Borrower and be secured by this Security Instrument.These amounts shall bear interest from the date of
disbursement at the Note rate,and at the option of Lender shall be immediately due and payable.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower:(a)agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to
Lender,(b)coniests in good faith the lien by,or defends against enforcement of the lien in,legal proceedings \
which in the Lendees opinion operate to prevent the enforcement of the lien,or(c)secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. if Lender
determines that any part of the Property is subject to a lien which may attain priority over this Security
Instrument,Lender may give Borrower a notice identifying the lien.Borrower shall satisfy the lien or take
one or more of the actions set forth above within 10 days of the giving of.notice. :
8.Fees.Lender may collect fees and charges authorized by the Secretary. '
9.Grounds for Acceleration of Debt,
(a)Default.Lender may,except as limited by regulations issued by the Secretary in the case of
payment defaults, require immediate payment in full of all sums secured by this Security
Instrument if.
(i)Borrower defaults by failing to pay in full any monthly payment required by this Security
Instrument prior to or on the due date of the next monthly payment,or
(ii)Borrower defaults by failing,for a period of thirty days,to perform any other obligations
contained in this Security Instrument.
(b)Sale Without Credit Approval.Lender shalt, if permitted by applicable law(including
Section 341(d)of the Garn-St Germain Depository Institutions Act of 1982, 12 U.S.C. 1701j-
3(d))and with the prior approval of the Secretary,require immediate payment in full of all sums
secured by this Security Instrument if:
(i)All or part of the Property,or a beneficial interest in a trust owing all or part of the
Property,is sold or otherwise transferred(other than by devise or descent),and
(ii) The Property is rot occupied by the purchaser or grantee as his or her principal
FFA PFNNSYLVANIA MORTGAGE
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residence,or the purchaser or grantee does so occupy the Property,but his or her credit has i
not been approved in accordance with the requirements of the Secretary. i
(c)No Waiver.If circumstances occur that would permit Lender to require immediate payment I
in full,but Lender does not require such payments,Lender does not waive its rights with respect
to subsequent events.
(d)Regulations of HUD Secretary.In many circumstances regulations issued by the Secretary �.
will limit Lender's rights,in the case of payment defaults,to require immediate payment in full
and foreclose if not paid,This Security Instrument does not authorize acceleration or•foreclosure
if not permitted by regulations of the Secretary.
(e)Mortgage Not Insured.Borrower agrees that if this Security Instrument and the Note are not
determined to be eligible for insurance under the National Housing Act within 60 days from the
date hereof,Lender may,at its option,require immediate payment in full of all sums secured by
this Security Instrument.A written statement of any authorized agent of the Secretary dated
subsequent to 60 days days from the date hereof,declining to insure this Security rnstrumcnt and
the Note,shall be deemed conclusive proof of such ineligibility.Notwithstanding the foregoing,
this option may not be exercised by Lender when the unavailability of insurance is solely due to j
Lender's failure to remit a mortgage insurance premium to the Secretary. '
10.Reinstatement.Borrower has a right to be reinstated if Lender has required immediate payment
in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument.This
right applies even after foreclosure proceedings are instituted.To reinstate the Security Instrument,Borrower
shall tender in a lump sum all amounts required to bring Borrower's account current including,to the extent
they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and
customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon
reinstatement by Borrower,this Security Instrument and the obligations that is secures shall remain in effect
as if Lender had not required immediate payment in full. However, Lender is not required to permit
reinstatement if,(i)Lender has accepted reinstatement after the commencement of foreclosure proceedings
within two years"immcdiately preceding the commencement of a current foreclosure proceeding,(ii)
reinstatement will preclude foreclosure on different grounds in the future,or(iii)reinstatement will adversely
affect the priority of the lien created by this Security Instrument.
11. Borrower Not Released;Forbearance By Lender Not a Waiver.Extension of the time of
payment or modification of amortization of the sums secured by this Security Instrument granted by Lender j
to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or
Borrower's successors in interest. Lender shall not be required to commence proceedings against any 3
successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums
secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's
successors in interest.Any forbearance by Lender in exercising any right or remedy shall not be a waiver of i
or preclude the exercise of any right or remedy.
12.Successors and Assigns Bound;Joint and Several Liability;Co-Signers.The covenants and
agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and
Borrower,subject to the provisions of Paragraph 9(b).Borrower's covenants and agreements shall be joint
and several. Any Borrower who co-signs this Security Instrument but does not execute the Note:(a)is co-
signing this Security Instrument only to mortgage,grant and convey that Borrower's interest in the Property
under the terms of this Security Instrument;(b)is not personally obligated to pay the sums secured by this
Security Instrument;and(c)agrees that Lender and any other Borrower may agree to extend,modify,forbear
or make any accommodations with regard to the term of this Security Instrument or the Note without that
Borrower's consent.
13.Notices. Any notice to Borrower provided for in this Security Instrument shall be given by
delivering it or by mailing it by first class mail unless applicable law requires use of another method.The
FNA PENNSYLVANIA MORTGAGE
40 400.9 Pagc 5 of 0
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notice shall be directed to the Property Address or any other address Borrower designates by notice to
Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any
address Lender designates by notice to Borrower.Any notice provided for in this Security Instrument shall be
deemed to have been given to Borrower or Lender when given as provided in this paragraph. 1
14.Governing Law;Severability.This Security Instrument shall be governed by federal law and
the law of the jurisdiction in which the Property is located.In the event that any provision or clause of this
Security Instrument or the Note conflicts with applicable law,such conflict shall not affect other provisions }
of this Security Instrument or the Note which can be given effect without the conflicting provision.To this !
end the provisions of this Security Instrument and the Note are declared to be severable. j
15.Borrower's Copy.Borrower shall be given one conformed copy of the Note and of this Security.
Instrument.
16.Hazardous Substances.Borrower shall not cause or permit the presence,use,disposal,storage, !
or release of any Hazardous Substances on or in the Property.Borrower shall not do,nor al low anyone else to
do, anything affecting the Property that is in violation of any Environmental Law. The preceding two !
sentences shall not apply to the presence,use,or storage on the Property of small quantities of Hazardous
Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of
the Property. '
Borrower shall promptly give Lender written notice of any investigation,claim,demand,lawsuit or
other action by any governmental or regulatory agency or private party involving the Property and any j
Hazardous Substance or Environmental Law of which Borrower has actual knowledge.If Borrower learns,or i
is notified by any governmental or regulatory authority, that any removal or other remediation of any I
I
'Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary
remedial actions in accordance with Environmental Law.
As used in this paragraph 16, "Hazardous Substances"are those substances defined as toxic or 7
hazardous substances by Environmental Law and the following substances: gasoline, kerosene,other
flammable or toxic petroleum products,toxic pesticides and herbicides, volatile solvents, materials
containing asbestos or formaldehyde,and radioactive materials.As used in the paragraph 16,"Environmental
Law"means federal laws and laws of the jurisdiction where the Property is located that relate to health,
safety or environmental protection. =
t '
NON-UNIFORM COVENANTS.Borrower and Lender furlher covenant and agree as follows:
17.Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents
and revenues of the Property.Borrower authorizes Lender or Lender's agents to collect the rents and revenues
and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents.However,prior 1
to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security
Instrument,Borrower steal I collect and receive all rents and revenues of the Property as trustee for the benefit
of Lender and Borrower.This assignment of rents constitutes an absolute assignment and not an assignment
for additional security only.
if Lender gives notice of breach to Borrower:(a)all rents received by Borrower shall be held by I
Borrower as trustee for benefit of Lender only,to be applied to the sums secured by the Security Instrument; !
(b)Lender shall be entitled to collect and receive all of the rents of the Property;and(c)each tenant of the
Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the
tenant.
Borrower has not executed any prior assignment of the rents and has not and will not perform any
act that would prevent Lender from exercising its rights under this Paragraph 17.
Lender shall not be required to enter upon,take control of or maintain the Property before or after
FHA PENNSYLVANIA MORTGAGE
400.9 Page 6 or 9
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giving notice of breach to Borrower.However,Lender or a judicially appointed receiver may do so at any j
time there is a breach.Any application of rents shall not cure or waive any default or invalidate any other
right or remedy of Lender.This assignment of rents of the Property shall terminate when the debt secured by I
the Security Instrument is paid in full.
18, Foreclosure Procedure.If Lender requires immediate payment in full under paragraph 9,
Lender may initiate foreclose by judicial proceedings and/or invoke any other remedies permitted by j
applicable law.Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in
this paragraph 18,including,but not limited to,reasonable attorneys'fees and costs of title evidence to the j
extent permitted by applicable law.
If the Lender's interest in this Security instrument is held by the Secretary and the Secretary requires
immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale j
provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act")(12 U.S.C. 3751 of seq.)by
requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the
Property as provided in the Act.Nothing in the preceding sentence shall deprive the Secretary of any rights j
otherwise available to a Lender under this Paragraph 18 or applicable law
19.Release.Upon payment of all sums secured by this Security Instrument,this Security Instrument
and the estate conveyed shall terminate and become void.After such occurrence,Lender shall discharge and ?
satisfy this Security Instrument without charge to Borrower.Borrower shall pay any recordation costs.
20.Waiver.Borrower,to the extent permitted by applicable law,waives and releases any error or
defects in proceedings to enforce this Security instrument,and hereby waives the benefit of any present or I
-future laws providing for stay of execution,extension of time,exemption from attachment,levy of sale,and ;
homestead exemption.
21.Reinstatement Period.Borrower's time to reinstate provided in paragraph 10 shall extend to
one hour prior to the commencement of bidding at a Sheriffs sale or other sale pursuant to this Security
Instrument.
t
22.Purchase Money Mortgage.If any of the debt secured by this Security Instrument is lent to
Borrower to acquire title to the Property,this Security Instrument shall be a purchase money mortgage.
23.Interest Rate After Judgment.Borrower agrees that the interest rate payable after a judgment
is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time i
under the Note. i.
24. Riders to this Security Instrument. If one or more riders are executed by Borrower and
recorded together with this Security Instrument,the covenants of each such rider shall be incorporated into
and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s)
were in a part of this Security Instrument. f
The Following Rider(s)are to be executed by Borrower and are attached hereto and made a part thereof 1
(check box as applicable]:
❑Condominium Rider ❑Growing Equity Rider ❑Adjustable Rate Rider
❑Planned Unit Development Rider ❑Graduated Payment Rider
❑Other(s)(specify]
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FHA PENNSYLVANIA MORTGAGE
403k 400.9 Page 7 of 9
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BY SIGNING BELOW,Borrower accepts and agrees to the terms contained in pages I through 5 of
this Security Instrument and in any rider(s)executed by Borrower and recorded with it.
This is a contract under seal and may be enforced under 42 Pa.C.S.Section 5529(b). t
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BO WER - J.MIFS NUGIMT - ATE -
�1 og
{
J 5- WILL NII HNT - DATE -
(Space Sclow This Line For Acknowledrmentl
STATE OF f
COUNTY OFt:'►b k t)'
On •this the �4 day of dam? }r'y %�6og before me
trbrl(�. el day
, the undersigned officer, personally appeared
- �r •--�I!1��t�—n.,�L 7Piltnt P.r 1� �l�—
known to me(or satisfactorily proven)to be the person(s)whose name(s)are subscribed to the within
instrument and acknowledged that he/she/they executed the same for the purposes therein contained.
In witness whereof,I hereunto set my hand and official seal. i
Notary Public
COMMONWEALTH OF PENNSYLVANIANmrw S"
y
88ftm A.RiC4ar08on,Notary pubic My Commission Expires:
North Newton Twp„CumberfsAd County
My Commissbn Expires Aug.2,2012
Member,Peansytv8nla AsaWatlon o/N,I,,,e5
i
FHA PENNSYLVANIA MORTGAGE
�.sy 400.9 Page 9 of 9
N i
TITLE INSURANCE COMMITMENT `
Issued by Park Avenue Abstract
AGENT FOR LANDAMERICA NJ TITLE INSURANCE COMPANY
i
Commitment Number: PEN-1061
I
SCHEDULE C i
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or tract of land situate in East Pennsboro Township, Cumberland
County, Commonwealth of Pennsylvania,more particularly bounded and described as follows,to }
i
wit:
I
BEGINNING at a point on the Southern dedicated right-of-way line of Veronica Lane at the
dividing line of Lots Nos. 87 and 88,said point also being located 296.20 feet West of the
Western extremity of an arc connecting the Southern dedicated right-of-way line of Veronica E
Lane and the Western dedicated right-of-way of Brisbain Lane;thence by line of Lot No. 87,
South 22 degrees 26 minutes 01 second East, 105 feet to a point; thence by line of other lands of
Westwood Hills, South 67 degrees 33 minutes 59 seconds West,76.20 feet to a point at the
dividing line of Lots Nos. 89 and 88;thence by Lot No. 89,North 22 degrees 26 minutes 01
second West, 105 feet to a point on the Southern right-of-way line of Veronica Lane; thence by
said right-of-way line,North 67 degrees 33 minutes 59 seconds East,76.20 feet to a point at the
dividing line of Lots Nos. 87 and 88,the place of BEGINNING.
BEING Lot No.88 on the Final Subdivision Plan for Westwood Hills,Phase 11,recorded in Plan
Book 84,Page 117.
SUBJECT to a 25-foot Drainage Easement and a variable width Drainage and Wetland Easement
as shown on the above mentioned Subdivision Plan.
SUBJECT to restrictions,conditions and easements as set forth on the above mentioned
Subdivision Plan.
UNDER AND SUBJECT,NEVERTHELESS,to conditions,restrictions,easements and rights-
of-way of record.
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NJRB 3-08
Effective 2/15107 ?
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CERTIFICATE OF RESIDENCE: I do certify that the precise address of the within named Mortgagee is
3300 S.V.34th Avenue, Suite 101,Ocala,FL 34474 or ox 2026,Flint,MI 48501-90Z6.
Signatu
Agent on behalf of: ort ee
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Aare�rc�►�
918 S, gbe/7t, urs ;.
S0�Q �/hte e gbstrto••
rdale� J�0 e p.
8p83
FHA PENNSYLVANIA MORTGAGE
453� 400.9 Page 9 of 9
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ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE -
CARLISLE,PA 17013
717-240-6370
Instrument Number-201019053
Recorded On 7/15/2010 At 11:07:39 AM *Total Pages- 11
*Instrument Type-MORTGAGE
Invoice Number-69158 User ID-ES
*Mortgagor-NUGENT,JOSEPH WILLIAM
*Mortgagee-MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC
*Customer-PARK AVE ABSTRACT INC
'�FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS/ACCESS TO $23.50
JUSTICE DO NOT DETACH
RECORDING FEES - $23.50
RECORDER OF DEEDS This page is now part
PARCEL CERTIFICATION $10.00
FEESof this legal document.
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $74.00
I
I Certify this to be recorded
in Cumberland County PA
�1 pp CfIW$�
�!�/
RECORDER d D2DS
nao _
*-Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
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EXHIBIT 44B"
. 1.
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Prepared by:
CitiMortgage, Inc.
6801 Colwell Blvd., MS 2790
Irving, TX 75039
Return to:
CitiMortgage, Inc.
P.O. Box' 790021 !
i
St. Louis, M0 63179-0021 j
UPI: 09-12-2992-253 ASSIGNMENT OF MORTGAGE
' MERS Pho;
KNOW ALL MEN BY 'THESE PRESENTS that. MORTGAGE ELECTRONIC j
REGISTRATION SYSTEMS, INC., a Delaware corporation, whose address is P.O. Box j
2026, Flint, iVII 48541-2026,.as nominee for A GREAT MORTGAGE COMPANY, INC,
OF NEW JERSEY, its successors and assigns, hereinafter "Assignor" the holder of the
Mortgage hereinafter mentioned, for and in consideration of the sum of ONE DOLLAR ($1.00)
lawful money unto it in hand paid by CitiMortgage Inc., "Assignee" at the time of execution
hereof, sell, assign, transfer and set over unto the said Assignee, the receipt whereof is hereby
acknowledged, does hereby grant, bargain, its successors and assigns, ALL THAT CERTAIN
Indenture of Mortgage given and executed by JOSEPH WILLIAM NUGENT AND
JENNIFER A NUGENT, HUSBAND AND WIFE to A GREAT MORTGAGE r
COMPANY, INC. OF NEW JERSEY, bearing the date 11/28/2008, in the Amount of !
$258445, said Mortgage being recorded on 7/15/2010 in the County of Ctw) ERLAND,
Commonwealth of Pennsylvania, in DOC#201019053.
Being Known as Premises:714 VERONICA LANE ENOLA PENNSYLVANIA 17025
Parcel No: 09-12-2992-253
09-12-2992-253:09-12-2992-253
Together with all Rights, Remedies and incidents thereunto belonging. And all its Right, Title,
Interest,Property,Claim and Demand,in and to the same:
TO HAVE, HOLD, RECEIVE AND TAKE, all and singular the hereditaments and premises
hereby granted and assigned, or mentioned and intended so to be, with the appurtenances unto.
Assignee, its successors and assigns, to and for its only proper use, benefit and behoof forever,
subject, nevertheless, to the equity of redemption of said Mortgagor in the said Indenture of
Mortgage named,and hislhcr/their heirs and assigns therein.
IN WITNESS WHEREOF, the said "Assignor" has caused its Corporate Seal to be herein
affixed and these presents to be duly executed by its proper officers
[Remainder of page left intentionally blank;signature Mage immediately follows]
Lssued by
Park Aveaaue Abstract _
AGENT FOR COMMONWEALTH LAND TITLE INSURANCE
COWANY
SCE:MULE C
LEGAL DR8CRiP lOrj "
File Numbs Policy Num
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ALL THAT CERTAIN lot or tract of land situate in Fast Pemtsboro Township,Cumberland County.
Commonwealth of Pennsylvania,more petticularly bounded and descnbcd as follows,to wit:
j BEGINNING at a point on the Southem dedicated tight-of-way line of Veronica Lane at the dividing line
f of Lots Nos.87 and 88,said point also being lommod 2%.20 feet West of the Western extremity of an arc
cotmecting the Southern dedicated right-of-way line of Veronica Lane and the Western dedicated right-
of-way of Brisbein bane;thence by line of Lot No.87,South 22 deg=26 minutes 01 second East,-105
feet to a point;thence by line of other lands of Westwood Hills,South 67 dog m 33 minutes 59 seconds
WM 76.20 feet to a point at the dividing lint of Lots Nos:89 and 88,thence by Lot No.89,North 22
degreos 26 minutes 41 second Wcst,105 feat to a point on the Southem right-of-way line of Veronica ;.
Lane;thence by said right-of-way line,North 67 degrees 33 minutes 59 seronds East,76.20 feet to a point
' at the dividing line of Lots Nos.87 and 88,the place of BEGINNING.
BEING Lot No.88 on the Final Subdivision Plan for Westwood Hills,Phase A rocotd-d in Pian Book
84,Page 117.
SUBTFt'T to a 25-foot Drainage l~awment ad a variable width Drainage acrd W ctland Easement as
shown on the above mentioned Subdivision Plan.
SUBJECT to restrictions,oonditions and eascmcats as set forth on the above mentioned Subdivision Plan.
F.
i UNDER ANI)SUBJECT,NEVERTHELESS,to coalitions,restrictions,tsscmems and Tights-of way of
record.
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Loan Pd q(as modMW by TIRSOP)
e/e7/200e
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this
MORTGAGE ELECTRONIC
REGISTRATION SYSTEINIS,
INC.,a Delaware corporation,as
nominee for A GREAT
MORTGAGE COMPANY,INC. 1
OF NEW JERSEY,its successors {�
and assigns
By.
Sealed and Delivered ,Vice Presi t
in the presence of us;
Attest:
State of Texas
County of Dallas
This instrument s cknowledged before m n ��
byQ3,0r vt�of M rtgage Electronic Registration
Systems, Inc., a Delaware corporation,on behalf of said corporation. I
i
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i (Personalized Seal) Notary ublic's Signature
i
The precise address of the
within named Assignee is:
1000 Technology Drive,
cy B}" �tX!1� �,� 1 —2240 224 Ho4LK SANCHEZ�
tExp
_�y Commission Wires
Apri126,2915
After Recording Return to:
CitiMort-age,Inc. j
P.O.Box 790021
St.Louis,MO 63179-0021
3
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Prepared by:
CitiMortgage, Inc.
6801 Colwell Blvd.,_\IS 2790
Ir 'ng,TX 7
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ASSIGNMENT OF MORTGAGE
Mortgage E,1ectr6nic.Registration.Systems,
Inc.,a Delaware Corporation,-as nominee i
for A GREAT MORTGAGE.COMPANY,
NC. OF NEW JERSEY.its-6ccessors and
assigns
TO
CitiMortgage Inc.
Premises: '
714 VERONICA LANE ENOLA
PENNSYLVANIA 17025
Please return this recorded document to,
CitiMortgage,Inc.
P.O.Sox 790021
St.Louis,MO 63179-0021
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ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY -
1 COURTHOUSE SQUARE
CARLISLE,PA 1.7013 -
717-240-6370 _ T,
Instrument Number-201205694
Recorded On 2127/2012 At 11:52:54 AM * Total Pages-6
*Instrument Type- kSSIGNMENT OF MORTGAGE
Invoice Number-102792 User 1A-KW
*Mortgagor-NUGENT,BARBARA A
"Mortgagee-CITIMORTGAGE INC
*Customer-PK&J
FEES
STATE WRIT TAX $0.50 Certification Page
STATE JCS/ACCESS TO $23.50
'JUSTICE DO NOT DETACH
RECORDING FEES - $13.50
RECORDER OF DEEDS This page is now part
PARCEL CERTIFICATION $10.00
FEES of this legal document.
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $52.50
i
f
I Certify this to be recorded
in Cumberland County PA
r e a
Q t
° RECORDER O D EDS
i
1769
*-Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
4
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EXHITBIrl", 6GC"
tA
ALLOtiGE TO NOTE
HDOEHT
1
MINN
ALI ON IF TO NOTE DATED NOVEMBER 28, 2008 IN TIIE At,4OUNT OT$258,445 00 i.
IN}AVOR OE A GREAT MORTGAGE COMPANY, INC AND CXLLUTED BY JENNIFER A NUGENT
PROPER IY ADDRESS 714 VERONICA LANE, ENOLA, PA 17025
i
PAS'TO Till.ORDER Of
(-(Tl HORT(y�6C, JA)ca.
\VII11omn..(DURSfONNOVEMBER 28, 2008
BY A GREA? MORT GE COMPAW' INC
921 PL£ASAN X LLECY,AVE
MOUNT 7ullT 08054
NA N11'
RYAN P ALTOS
1'1TL)
ply to the Ord=of
rcc raonm w :+�
a
mtl eaar�tt� '
�Atatgege,loc
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EXHIBIT 4 4U 5
Nlugent,Barbara Ann-Baltimore Sun Page I of 1
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HOME NEWS LOCAL SPORTS RAVENS BUSINESS ENTERTAINMENT LIFE HEALTH OPINION Iv1ARKETPLACE SERVICES !
j
Home--•Ccilections-+Cockeysville t
Recommend C j
Nugent, Barbara Ann
1
Jury 09.2004 10 0
On July 7,20D4,BARBARA ANN(nee Vanderbosch);Waved mother of Mary Ann j.}a
Caskey and her husbarid.Joseph and Joseph W.Nugent and hiswife Jennifef;dear -`--' ` -`___..-•' -•• f
brother of Joseph James Vaneerboscr;cherished grandmother of Sarah Nugent,Ced and Sean Caskey.Nicholas and
Mc Kenna Nugent The family will receive friends in the Lemmon Funeral Home of 01.113ney Valley.Inc.,10 W.Padonla
Road(at York Road),Timonium-Cockeysville•on Friday from 2 to 4 and 7 to 9 P.M.A Memorial Mass%,A]be celebrated j
In the S1.Joseph Church,Cockeysville,on Saturday,July 10 at 10 A.M.Interment St.Joseph Church Cemetery. i
Fullerton.In lieu of flowers,contributions may be directed in Mrs.Nugent's name b the Disabled Veterans of America,
P.O.Box 14301,Cincinnati,Ohio 45250.0301.
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The att-new Audi A3. _ ............
tyc!fty„rrr lP[P:1.r..+c�.r\'a:rtV P•.�,:M1.N:ct.
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http://articles.battimoresun.com/2004-07-09/news/0407090429_J_nugent joseph-church-... 06/23/2014
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EXHIBIT "E"
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Citifoortgao,Inc. PRESORT
PO Box 9090 First Ciass Mall
'Temecula,CA 92563-9090 U.S.Postage and
-----------
Fees Paid
W SO
Send Payment t6:
Citit lortgage,Inc. 7, ___ _• .
PO Box 889196
Des tloincs,lA 54369-9198
i
2014020;-166
III��zrIII�IIh1�f1�11R11,'1�"t13t�l�lu!„I�,,tlh�ltlll�,,,,1,
JENNIFER A N:UGENT
S66d;Comaspondenceto: 714:VERGNiCA LN
664ol .aije.Inc. ENOLA,PA 17025-155
64{10 Lt-s Colinas Bt rd.
INing,.TX 75039
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CITIPAACT91
Sent Via Certified Mail
Date: 02A37/2014 7196 9006 9297 2239 3749
JENNIF18R A NUGENT
714 VERONICA LN
2140L-A, PA 17025-1554
RE: Property Address: 71.4 VERONICA T-ANE-
ENOLA-. PA 17025
(,"ftiMort,,ave Loan 4:
CT91I `ICK
SM -rE'
TAKE ATN v
YO'ur'TR MIF'i Iff-ROM
FLOSURE
This is an offlicial notice that the mortgage on your home is in default, and the lender
intends t4foreclose. Spotific informafWn about-the nature of the default is provided in
the attached pages:
The HOMFONVNEWS KMERGENCY MORTGAGE ASSISTANCE PROGRAM
OJENMAP) may be able to hell)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 Wth you when you meet with the founseling Agyncy.
The nanieiddress, and.phone number of Consumer Credit Counseling iftencies serving
-YOW.C0g4y are listed at the end of this Notice. If You have any uestions, you Ma 11 the
Pennsylvania HousingFu*ance Agency telt-free at 1-800.-342-2301. (Persons with impaired
hearing can call(717)780-1869).
This Notice'contaijas important legal information. 1.
f you have any questions,
representatives at the Consumer Ckedit Counseling Agency may be able to help explain
it. You ixiav:also want to contact an attorney in your area. The local bar association
may be able to help you find a lawyer.
LA NOTJF1CAcj6N EN ADJUINTO ES DE SLINIA INIPORTANCIA, PUTS AFECTA, SU DERECITO A
CONTINUAR VIVIENDO EN SU CASA. S1 NO COMPRENDE EL CONNTENIDO DE ESTA NOTIFICAC16N
013TENGA UNA TRADUCC16N IN"MEDIATANITENTE LLNIVIANDO ESTA AGENCIA (PENNSYLVANIA
gm 1 of 6 7196 9006 9297 2235 3749
HOUSING FINANCE AGENCV� SEN CARGOS AL -NUMU10 ARRIBA, PUEDE SER
E LEGIBLE PARA. UN PRtSTAMO POR EL kROGRANIALLANIADO "RONMEOWNER's EMERGENCY
YIL PUEDE SALVAR SU CASA jj:E LA PERDIDA DEL
ORTC TA
AG.E.ASSUS' NCEPROGRAINT' EI, CUA
DKRECUT.O:A R.EI)IMIR,,SU HIPOTECk.
HOMEOWNER'S NAME(S): JENWER.A NUGENT
JOSEPH 14TILLIANI NUGENT
PROPERTY ADDRESS 714 VERONICA LANE
ENOLA,PA 17025
LOAN ACCT.NO.',
ORIGLNAL LENDER: A GREAT MORTGAGE COMWANY,INC.
-CURRENT LENDERiSERVICER: CifiMottgage,Inc.
HONTEOWNTERIS EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINAINCIAL ASSISTANCE WHICH:CAN SAVE YOUR
ROME FROM
ROM FORFC LOSURE AND HELP YOU MAKE FUTURE MORTGAGE
PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OT THE'HONTEONVNE FUS
ASSISTANCE ACTOF.-1983 (THE"ACT"),YOU lIAY BE ELIGIBELIGIBLEIM
FOR EERGENCY 4001 �k
G GE
ASSIS'T'ANCE:
e W'YOUR DEFAULT HAS BEE`CAUSED BY CIRCUNISTANCES.B.EYOND YOUR CONTROL,
# TF-VOU TIAVE A REASONABEE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE:
PAYINIENTS,AND
0* TH
- IFYOU MEET OTHER E
PENNSYLVANIA HOUSING T1INA*'_E AGENCY.
TEMPORARY, STAY OF FORECLOSURE — Under the Act, you are entitled to a temporary stay of
-foreclosure on yoiir mortgage for thirty(30)days from the date,of this Notice(plus three(3) days for mailing).
buthig that time. you must.arrange and attend a "face-to4ace" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR, WITTMN
fFI1RTY-T- j1RF,E
(3't) BAYS OF THE 'DATE OV TFfIS NOTICE: 'IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO
THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT,"FXyl?un�4&
BOW TO BRING YOUR MORTGAGE UP TO DAM
CONSUMER CREDIT COUNSELING AGENCIES if you .meet with one of the -consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you fol thirty.(30)
days after the date of this meeting. The naives.addresses and telephone numbers of designated.c6ivsurAer credit
counseling agencies for the county in which
the property is located are set forth at the end crftfiis-Notice. It is
only necessary to schedule one face-to-face mecting.. Ad-vise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTALNCE —Your mortgage is in default for the reasons set forth
later in this Notice (see follorMno pages for specific information about the nature of.y6ur default.) You have
the,right to apply for financial assistance from the Homeovoid'sErnergency Mortgage Assistance Program.
To do so, you must fill out, sip and file a completed Homeowner's Emergency Assistance Program
A 1011
pplicad with one of the designated consumer credit counseling agencies listed at the end of this Notice.
Oqilv consumer credit counseling agencies have applications for the program andthey will assist you in
CITIPAACT91
Page 2 of 6 7196 9006 9297 2235 37k9
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subrtiitting 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 PELTA and receiti,ed within thirty(30)
days of your face-to-mace meeting with the counseling'agency. i
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YOU SHO,UID FILE A HE_ AP APPLICATIO?AS SOD-AS POSSIBLF. IF YOU HA TIE ti 1EETfNG`YF7T}7
A COLSVSEL1NG AGENCY'137THIN 33 DAYS OF THE POST;31A$E DATE OF'THIS NOTICE AND FILE.9 N
APPLICATION lf'IT11 J RFA I17TRIN 30 .DAYS OF.T&4T iVEE7T'V'.G' THEN TIIE LENDER FULL BE
TE.WPORARILY PREVENTED rRO*,If SIIRTIA—V A FORECLOSURE AGAINST .: .`OUR .PROPERTY, AS i
EXPT.AI,NEDABOYE;, IAVTHE SECTIONCALLED 7`61PORARYSQAYOFFOREe-WSURE". i
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YOU HAVE THE RIGHT TO FILE A II£iIfAP APPLICATION EIIEN.BE.Y6M) THESE T13ft PERIODS. A i
F,.9T1<APPLICATION HILL NOT PREVENT THE LENDER FROMST<3R;.7NG A FOR.FCIO.SURE ACTION,.
BtTT-IF Y OU7?APPLICATION IS Ef?EiYTUALLY API"R.OVED AT AiVY T]AfE BEFORE,4:,S.1r4'RIFF'S SALE,
THE FORECLOSUREJULL SE STOPPED.
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AGENCI,'*f1CTfON -= Mailable funds-.for-emergency.mortgage assistance:are very. limited. They."vill be
disbursed by tfie.agency nnddr the eligibility'criteria established by the Act. The Pennsylvania.Housing
Finance Ageneyitias:sixty(60)°days to make a decision after it-feeeives your application. During th,0111xae, no
foreclosure proceedings will be pursued against.you if you have met tlic time requirements set forth dbove. i
You•Arill be notified directly by thb Pennsylvania.Housing Finance Agency of its decision on your application• i
v f
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FII:,ING.OF A.PETITION IN
B.M KRUPTCY,THE TOLLOWING PAR'f OF THIS:S'OTJCE IS FOR INFORkIATION PURPOSES
ONLY AND SHOULD NOT BE CONSt.DERED AS AiNe TO CO.I:E ECT THE DEBT. , }
(Tf you have Iiled,bankruptcy you.can still apply for Emergency Morf;age Assistance,) j
HOW.TO CURE YOUR NIO:RTGAGE DEFAULT(Bring it up to.date).
NATURE OP'`THE DEFAI I F—The MOTGAGE debt held by the above lender on your property located«t: i
714 VERONICA LANE
E146LA,PA 17025'
IS SERIOUSLY IN DEFAULT because: I
1
YOU HAVE NOT(MADE NIONTAVY MORTGAGE PAYN:IENTS for the following months and the following
amounts ate now past,dile'.
i
1.2101113 through 02/0111A i
3 r.$1,857.811inolrth
i�.352.7I/lat'e. harge`month
t
$5,678.S5
i
Other charges(explainiitcmizc):
Unapplied finds in the amount of:
i
TOTAL AMOUNT PAST DUE: $4,370.04
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11OW TO CURE THE DEFAULT- You may cure the default within TIER1Y(30) DAYS of the date-6f this notice
BY PAYING THE TOTAL. AMOUNT PAST DUE TO THE LENDER, 13rHICH IS $4,370.09. PLUS ANY
MORTGAGE PAYMENTS AND LATE CHr1RGES WHICH BECOME DUE- DURING THE THIRTY (30) DAY
PERIOD,:. Payments must be made ciihcr,by cash. cashier's check:. certified check or inoncy order mad_ a oa bya le and
stilt to:
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C"sriMorr�dagc,Inc.
P.O.'BOX 183040
` Columbus,OR 4321.8-3040
C1'r1P.AACr9 t
p� 3Ar( 7196 9006 9297 2235 3749 i
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1F'VOCT DO NOT CURE,THE DAFAI:TLT--:If you do not'aure the default wf.thin TIURTY(aft)DAYS of the.date of '.
this Notice., the lender intends fo:exercise Its rig)tts to aeeelerate the mortna2e debt. This tucans that the entire
outstanding balance of this debt:will be considered due iminediately and you may lose the chance to pay the-Mortgage
in monthly installments. 1f full payment of the total amount past due is not made within THIRTY (30) DAYS, the
lender also intends to instruct its 2tturnoys to start legal action to foreclose upon your tnort,-a,.jed property
I
IF THE`: lO:RTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the i
mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before,the louder begins
legM proceedings against you, you will still be required to pay the rt��tsonable attorney's fees that were actually
incuired, Lip to S50:00. Noivevcr, if legal procerdines are started against you, you will have to pay all reasonable I
attorney's fees actually-incurred by the lender even if they exceed$50.00. Any attorney's fees will be added to the I
amount:you owe the lender, which may also include other reasonable costs, I:f you care the default within the
THIR.-TY(30)DAY period,you will not bd required to pay attorztO.v's fees. j
OTHER LEND ER`REyl:ED1ES. The.lender may also sue.ybu personally for the unpaid principal,balance and all
other sums4tte under, the mortgage.
I
RIC.H'T°TO CURT.to'1)EFAU"LT PRI{3It TO SliERIFF'S SALE--If you have not cured the default withip-the i
THIRTY (30.).DAY per gt!'and force]ostrrc pi aeclinga have begun,:vou still have the ri bt to cure the default.and
prcvcnt:tle.5aie.:at any time'ttr to.one.hour befoi fhc Shetiit's Sale. lyou'tiiay..do so by payint;the total.amount hien I
pact due, plus tiny 6te:or other charAcs then-due,.reasonable aito?ney's fees and costs connected with th61 ycelpsurc !
sale an znv other costs connected with the�tieriFt's Sale as soeci.fied in t; tinb the he lender and by�terfot-min an
other reg uir'ements under the mortgage Curing your default u►the manner serforth in this nutice-iAll restore your
mortgage to the same positlon'aslfyou had never defaulted.
t
EARLIEST POSSIBLE SHERIFF'S.SALE DATE--It is estimated dial the earliest date that such a Sheriff's Sale of
the-.-mortgaged property could be held-woul.d be approximately 6 months from the date.o.f this Notice. A notice of the
actual ti't6 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 cxactly'Fvhat the required payment or action frill be by �
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contacting.the lender.
HOIti O CONTACI'111.E.LENDF,9-
Naive of Lender: Citilvlortgage,Inc. t
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Address: P.O.Box 12218
Tucson,AZ 85732-2218
Phone Number: 1-877:=362-0175
FavNthnber: Tn866-940-8147
Contact Person: ;vlarkA.nthony Hartland
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E-Niall Address: markanthony.b.hartland(iciti.eom i
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EFFECT OF SHERIFF'S SALE -- You should realize that.a Sheriff's Sale will end your ownership ofthe mortgaged
property and your tight to occupy it. If you continue to live in.the property alter thcMcriff s Sale,a laA•suit to remove
you and your furnishings ana.other belonginos:could be started by the lender at anytime.
ASSUMPTION .Ol' IyIORTGAGE -- You inay not sell or transfer your home to a buyer or transferee v ho wilt
assume the mortgage debt,provided that all the outstanding payments, charges and a.#.t.arney's fees and costs are paid
prior to or at the sale and that the other requirements of the mortgage arc satisfied.
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CITIPAACT91
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YOU-INIAY ALSO HAVE'THE RIGHT:
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• TO:SELL TME PROPERTY TO OBTAIN hIONEY TO PAY OFF TI-IL-MORTGAGE DEBT OR TO
BORR&V MONEY FROIM ANOTITER LENDING INSTITUTION TO PAY OFF THIS DEBT. j
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• TO HAVE T13`IS DEFAULT CURED BY ANY• ITIRD PARTY ACTING ON YOUR BEHALF.
• TO FIAVE TIIE MORTGAGE`RESTORED TO THE SAME-POSITION AS IF NO D.EFAULT I'IAD !
OCCURall I:F YOU CURE THE DEFAULT. .(i-IOW) VER,YOU.DO NOT HAVE THIS RIGHT
TO CURE YOUR'DEFAULT NIORE TRAIN:THREE 71MES IN ANY CALENDAR'YEA-R..) 1
1
• TO ASSERT TIIE NONEXIS'rFN10E OF'A 1?.✓FAULT IN ANY FOREC U.RI� PROCEEDING
OR-ANY OTHEWLANYSi_TIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS_
• TC3 ASSERT ANY OTHERDEFENSE YOU BELIEVE YOU MAY HAVE TO SUCI•I ACTION BY
THE.LENDER.
• TO SEEK PROTECTION LTIDEk TH'E FEDERAL BANKRUPTCY LAW,
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN.BE LOCAT.ED ON
T.R-E AT TACEIED LIST
This is an attempt to collect a debt and any information obtained"ill be-used for that purpose.
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C11PIPtu1C T91
Page 5of6 7196 9006 9297 2235 3749
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HEIVIAP Consumer. Credit Coualseling.Agencies .....
CUMBERLAND County
Report last upda:d:10?16.2011 W.43AM
Ai4-wiiage.Credit.Cut;tnseliugServicY/CCCSofWestern.PA Community.Aetiou:Comrois.6onofCapi6fkcgion'
206.1inglestown Road 1514.Dern Street:
Hfarricburg..PA.17162 Hartishur&PA.17104
8SS-511.2221 717=232-9757
Housing Alliance of York/Y..1;onsing.Recoorces Vlaranatba i
29Q-NVesi:Ma.rl et Street 43 MlMelphia Avenue
York,PA ,I7401 Waynesboro,PA 17265
717.355-275_ 717-762-3285
PathStone Corporation Pai lst6neCorporati6¢
1625.NotthJ~r6n't.Sr 450.Cte*&(Ahd Ave
Harrisburgy,PA.1-:71'02 Cbatubashurg,PA.17201
717:234-6616 717=264-59:0.
PA Interfaith Community Programs.Lic PUPA
40 EHigh.Street 211.North Fr6i t Street
• Gettysburg,PA.1-7325 Himisbirrg.PA.171,t0 -
717-334-1513 717-780-3940:...5()0=342-2397
• s
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CitlMortgage,Inc. PRESORT
PC Box 9090
Temecula,Cry 92589-90913 First-Cfass_Mait
f US.Postageand
Fees Paid
W SO
Send Payment to:
CitiMortgage,Inc.
PC Sox 6889196
Des Moines,IA 50358-$198
20140207-168
„I'EIEEI'thl'�[I"�'IlElut1111EIt1E["tl'li�l1'1(ttltlllilt'li
JOSEPH WILLIAM NUGENT
Send Corrsspdn. .. etc; 714 VERONICA LN
CitiMortgage,Inc: ENULA, PA 17025-1554
6400 Las Colinas Blvd'.
Irving,TX 75039
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CiTIPAACT91
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Sent Via Certified Mail
Date: 02/07/2014 7196 9006 9297 2235 3732
J09EPII WILLIAM N•UGENT
714 VERONICA LN
ENOLA, P.A 17025-1554
RE: Property Address: 71.4 VERONiCA.LANE
ENOLA, PA 1702.E
CitilMortgage Loan 9 i
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ACT 9`1 NOTIC".E
TAKE ACT-ION _T_0 SAV"E"
_)(OURM H&OM-VE"i
FIR"" i
FORECLOX-SURE t
1
This is an official notice that the mortgage on your home is in default, and the:tender
intends to foreclose. Specific information about::the naturae of the default is provicleil in
i
the attached'j)anes.
The HOTNI TEOWNEWS EMERGENCY MORTGAGE ASSISTANCE PROGRAM
;
(HEMAP) may be mile to help save your Dome. This Notice explains how the proL_am
w[irks.
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To see if HEMAP can help, you must ATEET NYITH A CONSUMER CREDIT I
COUNSFLI:NG AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE.
Tale this Notice with you when you meet with the Counseling Agency. I
;
The name address and phone number of Consumer Credif Counseling Agencies serving
your Courily are listed at.'the end of this'Notice. If you have anygues66ns,'you.may call:the
Pennsvlvania Housing Finafibe Agency toll-free at 1-800-342-2397. (Persons u-ith impaired
hearing can calf(717) 780-1869).
This Notice contains-important legal information. If you have any questions, {
representatives at the Constuner 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
ina'y'he able to help you find a lar v&. j
LA NOTIFICACIO! EN ADJUNTO ES DE SLYMA 11M.PORTANCIA, PCTES AFECTA SU D.ERECBO- A
CONTINIfAR YINIENDO EN SU CASA. 'SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
08TENCA L►SIA 7'RABUCCI6N ININTEDIAT.,1 VIENTF. LL.k-MANDO ESTA AGENCIA (PENNSYLVANIA
Cl7'iP.4AC:1`71
Parc't of 6 7196 9006 9297 2235 3732
ROUSING F'INANiZE AGENCY) SIN CARGOS 1L NUMERO tMENCIONADO ARRIBA. PUEDE SER
ELEGIBLE PARA UN PRESTANTO POR.!EL PROGRAN'IA LLAMADO "IlOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAIM" EL CU:iL PUEDE SALVAR SU C.NSA DE LA I'ERDIDA DEL f
DER-ECHO A REDIMI:R.SU HI PO FCA. �
11ONIEOWN1t:R'S NAME(S): JOSEPH WIf.;.LIAM NUGENT
JENNIFER A NU.GENT .
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PROPERTY ADDRESS. 714 VEROMCA LANE
ENOLA,PA 17025
LOtLN ACCs:NO.:
ORIGINAL LENDER: A GREAT MORTGAGE COMPANY,INC. E �I
CURRENT LENDERr' ERVTCER: Cft4Mottga6`e, inc.
HOMEOWNER'S EMERGENCY MORTGAGE .ASSISTANCE
PROGRAM
i
YOU.MAY in-:ELIGIBLE FOIL T'I.N.ANC.IAL ASSISTA\CE-WHICH CAN SA4T YOUR
HOME FROM..FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE
PAYMENTS
IF YOU CONbIPLY Fr ITH THE PROVISI=ONS OF THE HONfEONNNER'S E.,MERGENCY 4IORTGA G1
: SSI ST AN'CE ACT OF 1:9$$.(THE"ACTT),YOU MAY BE E.L.WIBLE FOR EMERGENCY INJORTGAGE
ASSISTANCE:.
• i
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOItiD YOUR CONTROL,
• IF YOU HAVE A REASONABLE, PROSPECT OF BFINC ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
• IF YOU:MEET OTHER ELIGIBILITY REQUIRENMEN'TS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY,
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TEMPORARY STAY OF.FORECLOSUR.E -- 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)day&for rnaitin;).
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. THISt1EETING MUST OCCUR XVITHLN
THIRTY-THREE (33) DAYS OF THE DATE QF IFAS NOTICE. IF YOU DO NOT APPLY FOR
EMLRGENCY.MORTGAGE ASSIST_4NCE YOU MUST BRING YOUR MOR'T`GAGE.UP TO DATE.
THE PART_OF THIS.ADTICE CALLED."HONG'TO CURE YOUR MORTGAGE DEFAULT,"ENPLAUNS
HOW TO:BRING YOURMORTGAGE UP TO DATE:
CONSUIVIER CREDIT COLTNSELING AGENCIES — If you meet with one of the consumer credit'
counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty(30) .
days after the date of this;meeting. The names addresses and telephone numbers of desi,ntated 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 mcetin�,;. Advise your.lender immediatety of your intentions.
APPLICATION FOR.tb10RTGAGE 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 ll.omeoAner`s Fmergencv Mortgage Assistance Program.
To do so, you must fill out, sign and file a completed klomeowner'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
Crrtt'AAcrn;
Page 2 of 6 ?196 9006 9297 2235 3732
YOU MAY'ALSO HAVE THE RIGHT:,
• TO SELL THE PROPERTY TO OBTAIN41ONNEY TO PAY OFF THE-MORTGAGE DEBTOR TO,
BORROW MONEY FROM ANOTHER LENDING INSTITUTION'*f'0-PAY OFFTHIS DEBT.
• Ti HAVET14IS DEFAULl.-COREDBY ANY'THIRD PARTY ACTING ON YOTJR Br--;I-.IALF.
• To HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT ITAD
OCCU'R-RED,IF YOU CURE THE DEFAULT. (11O 'EVER, DO NOT HAVE THIS RIGHT
TO CLTRE YOUR DEFACTILT;MORE THAN THREE TIMES IN CALENDAR YEAR).
TO ASSERT THE NOINE-XISTENCE, OF A DLFAULT IN ANKY' FORECLOSLTRE PROCEEDING
OR.ANY OTf IER LAWSUIT INSTIT I*rrf.D TINDER THE MORTGAGE DOCUNtENTS...
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY IIAVE TO SUCH ACTION BY
HE LEINDER.
TO SEEK, PROTECTION ENDER THE FEDERAL BANKRUPTCY LAW.
CONSUNIER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE LOCATED'ON
ITIE ATTACHED LIST
This is an attempt to collect a debt anti auy information obtained xvill be used for that purpose,
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HEMAP Consumer. Credit CounseiinaALyendes..
CUMBERLAND County
Rcpoi last 0031 d:}Q+16P3013.10:43 AM j
Atli antage.Credit.Counseling Service/CCCS.of Western PA Consnsunity.Actiou Commission of Csgital Region
2000 Linglestottn Road €514 Derry Street
lfarrishurgg,PA:17€02 Harrisburg,PA.17104
SSS.511-2227 7€7-232-4757
Housing Alliance of York/P.Housing.-Aesources Maranatha
290WcsrMarketStreet 43 Philadelphia Avenue
Fork.;PA 1:74111 Wu nesboro,PA 1726.8
711:955=275? 717-762-3285
PathStone Corpoiation PathStone Corporation
1625:'V"vrthFront St 450 Cleveland rive
Harristmirg,PA 17102 Chambersburg,PA.17201
717-234-6616 717-264-59.13
PA Interbith Cbbin unity Programs Inc PUFA
40 E High Street 21 t North Front Street
Gettysbttr P.A..17325 11arisburg,PA.171.1.0
71.7-334-1519 717-780-3940...;;1111-3142-23117
j
HC
hige646 7196 9006 9297 2235 3732
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EXHIBIT "F"
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uepartment of the Treasury-Internal Revenue Service
Farm bb8 v'1f)(c) II
(Rev.Februsty 20041 Notice of FedexA Tax U@I;e � 0 P. l n.-3 F 7-4
i
Area: Serial Number For.Optional Use by Recording office i
WAGE & INVEST14&NT AREA #1 'I d Jg� Orbi
Lien Unit Phone: (800) 829-1650 �-• /' i
As provided by section 63211, 6322,and 6323 of the Internal revenue 1
Cade,we are SIVIng a notice that taxes (Including InteMst and pmuldes)
have been assessed apfnst'the folilowfitgpnanted taxpay4er.We have made
a demand for payment of this fiabli ty, but It romIns unpaid. 'Therefore,
them is a lien In favor of the titt3t4ed States on all propearty and rl&b to ��h Q
pwperty betong#ng to this taxpayer for the amount of these taxes, and
addhlonal penalties, Interest, and costs that may accrue. 't"'
M, ;
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•r•••- ��' lTl�
Name of Taxpayer BARBARA A NUGENT
Residence "714 VERONICA LN z =C
ENOLA, PA 17025-1554
cn
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iMPORTANT RELEASE INFORMATION:For each assessment listed below, i
unless notice of the lien is refiled by the date given in column(e),this notice shell, 1-•
on the day following such date, operate as a certificate of release as defined
in IRC 8325(a). f
Tax Peeled Date of Last Da
r for unpaid Balance
Kind of Tax Uding ldentlfytng plumber Assessment Rebllltl g of Assassatent i
a) b) c d e
1040 12/31/2000 XXX-X 11/13/2006 12/13/2016 3615.42
1040 12/31/2001 XXX-v* 11/13/2006 12/13/201.6 8348.87
1040 12/31/2002 .XXX 11/13/2006 12/13/2016 12178.19
1040 12/31/2003 XXX-. 11/13/2006 12/13/2016 9400.02 i.
1040 12/31/2004 XXX-Y- 07/30/2007 08/29/2017 1758.36
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Place of Filing -
Prothonotary
Cumberland County Total $ 35300.86
I Carlisle, PA 17013
f
This notice was prepared and signed at D£TltOIT, MI , on this,
the day day of March 2008
i
Signature A ACiS !
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tar DEBRA K. HiIRST (800) 829-7650 i
(WOM Certificate of officer authollzed by law to take acknowledgment Is not esoentiel to the validity of Notice of Federal Tax lion
Rev.Rul.71-466,1971.2 C.8.409) form 66A
(17tC){Rev.2-2000.)
Pert 1•Kept BY Rweordhta t3ftfek 'AT.140 80026X !
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t is t
VERIFICATION
Loa-G -)N , hereby states that he sh is employed as Vice President —
Document Control of CitiMortgage, Inc., the Plaintiff in this matter, and is authorized to make
this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage
Foreclosure are true and correct to the best of my information and belief.
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904
relating to unsworn falsification to authorities.
AFFIANT:
By: &M'Aa-
Print: a
Title: i� p �� �` employed by CitiMortgage, Inc.
Plaintiff. T— f
Date:
FILE#: 14-0569
NAME:NUGENT,JENNIFER A. &JOSEPH WILLIAM
CF � ffTNFIt; ^
211'i�' J�1L ' 01d01�,��.
31
CUA;BERL
PEENS vL At��q�T y
POWERS,KIRN&ASSOCIATES,LLC
Jill Manuel-Coughlin,Esquire Id.No. 63252
Jolanta Pekalska,Esquire Id.No. 307968
Harry B. Reese,Esquire Id. No. 310501
Daniel C. Fanaselle,Esquire Id.No. 31.2292
Matthew J.McDonnell,Esquire Id. No. 313549
1310 Industrial Boulevard, Suite 202
Southampton, PA 18966
(215)942-2090 ATTORNEYS FOR PLAINTIFF
CITIMORTGAGE, INC. COURT OF COMMON PLEAS
1000 TECHNOLOGY DRIVE
&FALLON,MO 63368 CIVIL DIVISION
PLAINTIFF CUMBERLAND COUNTY
NO. ly
� b3� tv �
VS.
JENNIFER A.NUGENT COMPLAINT IN
JOSEPH WILLIAM NUGENT MORTGAGE FORECLOSURE
714 VERONICA LANE
ENOLA, PA 17025
THE UNITED STATES OF AMERICA
228 WALNUT STREET, SUITE 220
P.O. BOX 11754
HARRISBURG,PA 17108
DEFENDANTS
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action you may be
able to participate in a court supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer you must take the following steps to be eligible for a conciliation
conference. First within twenty 20 days of your receipt of this notice you must contact MidPenn Legal Services at
717 2439400 extension 2510 or 800 8225288 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 do so and a conciliation
{ conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to
work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer you and your lawyer must take the following steps to be eligible
for a conciliation conference.It is not necessary for you to contact MidPenn Legal Service for the appointment of a
legal representative. However you must provide your lawyer with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. if you and your lawyer complete a financial worksheet in the
format attached hereto your lawyer will prepare and file a Request for Conciliation
Conference with the Court,which must be filed with the Court within sixty 60 days of the service upon you of the
foreclosure complaint. If you do so and a conciliation conference is scheduled you will have an opportunity to meet
with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the
mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME YOU MUST ACT QUICKLY AND TAKE THESTEPS
REQUIRED BY THIS NOTICE THIS PROGRAM IS FREE.
Date Re ectfully submitted,
Jill Manuel-Coughlin,Esquire Id.No. 63252
❑ Jolanta Pekalska,Esquire Id.No. 307968
❑ Harry B.Reese,Esquire Id.No. 310501
❑ Daniel C. Fanaselle,Esquire Id.No. 312292
❑ Matthew J. McDonnell,Esquire Id.No. 313549
Attorneys for Plaintiff
Cumberland County Residential Mortgage Foreclosure Diversion
Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge
CUSTOMER/PRIMARY APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale?Yes ❑ No ❑ Listing date: Price: $
Realtor Name Realtor Phone
Borrower Occupied? Yes ❑ No ❑
Mailing Address(if different)
City State: Zip:
Phone Numbers: Home: Office: Cell:
Other:
Email:
Number of people in household How long:
CO-BORROWER
Mailing Address:
City: State Zip:
Phone Numbers: Home:
Office: Cell: Other:
Email:
Number 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)Model:
Year: Amount owed$: Value: $
` MONTHLY INCOME
Name of Employers
1.
2.
3.
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 $
2nd Mortgage $ Utilities $
Car Payment(s) $ Condo/Neigh.Fees $
Auto Insurance $ Med not covered $
Auto fuel/repairs $ Other prop payment $
Install Loan Payment $ Cable TV $
Child Support/Alimony $ Spending Money $
Day/Child Care Tuition $ Other Expenses $
Amount Available for Monthly Mortgage Payments Based on Income Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes please provide the following information
Counseling Agency:
Counselor:
Phone Office: Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP)assistance
Yes ❑ No ❑
If yes please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency Yes ❑ No ❑
' If yes please indicate the status of those negotiations:
Please provide the following information if known regarding your lender's or lender loan
servicing company Lender Contact(Name)
Phone
Servicing Company(Name)
Contact: Phone
AUTHORIZATION
I/We authorize the above named to use/refer this information to my
lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We
understand that I/we am/are under no obligation to use the services provided by the above named
Borrower Signature Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and
Jill Manuel-Coughlin,Esquire,lender counsel:
Proof of income
Bank statements to cover the last 60 day period
If self employed,we must have the last 3 bank statements from both their business and personal bank accounts.
Proof of any expected income for the last 45 days
Dodd Frank Certificate
4506T-EZ form
Copy of last two months utility bill
Letter explaining reason for delinquency and any supporting documentation
Hardship letter
Listing agreement if property is currently on the market
Jill Manuel-Coughlin,Esquire
1310 Industrial Boulevard
2"d Floor, Suite 202
Southampton,PA 18966
(tel)215-942-2090
(fax)215-942-8661
Attention:Panjola Al,ikaj
Panj o1a.alikai gpki l lc.com
(tel)215-942-2090
#14-0569
POWERS K1RN & ASSOCIATES, LLC
JILL MANUEL-COUGHLIN, ESQUIRE Id. No. 63252
JOLANTA PEKALSKA, ESQUIRE Id. No. 307968
HARRY B. REESE, ESQUIRE Id. No. 310501
DANIEL C. FANASELLE, ESQUIRE Id. No. 312292
MATTHEW J. MCDONNELL, ESQUIRE Id. No. 313549
EIGHT NESHAMINY INTERPLEX, SUITE 215
TREVOSE, PA 19053
(215) 942-2090
OCT 1 t-} ►' 1: 20
(�tL``'NS i�i'c
CitiMortgage, Inc.
vs.
Jennifer A. Nugent
Joseph W. Nugent
Plaintiff
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
No. 14-4033 Civil
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
of your costs.
Kindly mark the above case DISCONTINUED WITHOUT PREJUDICE, upon payment
Dated: ACO t' (c
❑ Jill Manuel -Coughlin, Esquire Id. No. 63252
❑ Jolanta Pekalska, Esquire Id. No. 307968
❑ Harry B. Reese, Esquire Id. No. 310501
,g -Daniel C. Fanaselle, Esquire Id. No. 312292
o Matthew J. McDonnell, Esquire Id. No. 313549
Attorneys for Plaintiff
#14-0569
POWERS KIRN & ASSOCIATES, LLC
JILL MANUEL-COUGHLIN, ESQUIRE Id. No. 63252
JOLANTA PEKALSKA, ESQUIRE Id. No. 307968
HARRY B. REESE, ESQUIRE Id. No. 310501
DANIEL C. FANASELLE, ESQUIRE Id. No. 312292
MATTHEW J. MCDONNELL, ESQUIRE Id. No. 313549
EIGHT NESHAMINY INTERPLEX, SUITE 215
TREVOSE, PA 19053
(215) 942-2090
CitiMortgage, Inc.
vs.
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Jennifer A. Nugrent CUMBERLAND COUNTY
Joseph W. Nugent
Defendant(s) No. 14-4033 Civil
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the Praecipe to Discontinue Without
Prejudice was sent by first class mail, postage pre -paid, upon the following on the date listed below:
Jennifer A. Nugrent
714 Veronica Lane
Enola, PA 17025-1554
Dated: i(-0
Joseph W. Nugent
714 Veronica Lane
Enola, PA 17025-1554
O Jill Manuel -Coughlin, Esquire Id. No. 63252
O Jolanta Pekalska, Esquire Id. No. 307968
o Harry B. Reese, Esquire Id. No. 310501
,Daniel C. Fanaselle, Esquire Id. No. 312292
o Matthew J. McDonnell, Esquire Id. No. 313549
Attorneys for Plaintiff