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HomeMy WebLinkAbout14-4105 Supreme Co» 01 ennsylvania Cour ofl,C&hnM0 Pleas For Prothonotary Use Only: Ct i.1,C:MI _et Docket No: CU , B NO County Mp 6 The information collected on this form is used solely.for court administration purposes. This form does not supplement or replace the filing and sen4ce ofpleadings or other papers as required by law or rules of court. Commencement of Action: S x9 Complaint ® Writ of Summons ® Petition E ® Transfer from Another Jurisdiction 0 Declaration of Taking � C Lead Plaintiff's Name: Lead Defendant's Name: RIVERVIEW BANK JACK H. LENKER T I Are money damages requested? i]Yes Dollar Amount Requested: ®within arbitration limits No O (check one) Boutside arbitration limits N Is this a Class Action Suit? ®Yes El No Is this an MDJAppeal? ® Yes No A Name of Plaintiff/Appellant's Attorney: ROBERT G. RADEBACH ® Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ® Intentional ® Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution I® Debt Collection:Credit Card ® Board of Assessment Motor Vehicle ® Debt Collection:Other ® Board of Elections 0 Nuisance Dept.of Transportation ® Premises Liability Statutory Appeal:Other S ® Product Liability(does not include E mass tort) 0Employment Dispute: © Slander/Libel/Defamation Discrimination C ® Other: Employment Dispute:Other ® Zoning Board T © Other: l Q Other: O MASS TORT ® Asbestos N ® Tobacco j ® Toxic Tort-DES © Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Ejectment ❑ Common Law/Statutory Arbitration Bi ® Other: 13� © Eminent Domain/Condemnation Declaratory Judgment Ground Rent Mandamus Landlord/Tenant Dispute Non-Domestic Relations Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure:Commercial ®Quo Warranto 0 Dental 13Partition D Replevin iJ Legal ® Quiet Title [3 Other: 0 Medical © Other: ® Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA RIVERVIEW BANK R Plaintiff ' MUD vs U k� nr V) -- C)c a JACK H. LENKER and ROSEMARY LENKER t--2: -: Defendant NOTICE TO DEFEND 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 AN 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 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 REDUECED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 1-800-990-9108 717-249-3166 �l13. -25, 1pddr /363 7 Robert Radebach, Esquire 912 North River Road Halifax, PA 17032 717-896-2666 robradebachatty@aol.com PA. I D#19255 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RIVERVIEW BANK, f/k/a FIRST NATIONAL BANK OF MARYSVILLE, a Division of RIVERVIEW NATIONAL BANK, CIVIL ACTION - LAW Plaintiff vs. NO. j JACK H. LENKER and ROSEMARY LENKER, MORTGAGE FORECLOSURE Mortgagors and Real Owners, Defendants COMPLAINT 1. The Plaintiff, Riverview Bank, f/k/a First National Bank of Marysville, a Division of Riverview National Bank, Mortgagee, is a banking corporation having an office at 200 Front Street, Marysville, ,Perry County, Pennsylvania 17053. 2. The Defendant, JACK H. LENKER, is an adult individual who resides at 6030 Edward Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. The Defendant ROSEMARY. LENKER, is an adult individual who resides at 6030 Edward Drive, Mechanicsburg, Cumberland County, Pennsylvania. 4. On October 14, 2009, the Defendants, JACK H. LENKER and ROSEMARY. LENKER, executed and delivered a Mortgage upon premises as hereinafter described to the First National Bank of Marysville, a Division of Riverview National Bank, now known as Riverview Bank which Mortgage is in the principal amount of$249,519.80. Said Mortgage was duly recorded on November 9, 2009, in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, at Instrument No. 2009337764. 5. Said Mortgage has not been assigned. 6. The premises subject to the lien of the Mortgage are described as follows: ALL THAT CERTAIN piece or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, being bounded and described according to a survey made by Michael C D'Angelo, Registered'Surveyor, dated December 1, 1976, as follows, to wit; BEGINNING at a point at the Southern side of Edward Drive, which point is one hundred eighty feet(180')(erroneously set forth in prior deed as one hundred seventy and zero hundredths feet(170.00')) in a westerly direction by same, Ronald Road at the division line of Lots 133 and 134 on the hereinafter mentioned Plan of Lots; thence South thirty-one degrees (31')twenty-nine minutes (29')West, along said division line, a distance of one hundred ten and forty-seven hundredths feet(110.47') to a point at the division lines of Lots 134 and 151; thence North sixty degrees(60°)thirty-two minutes (32')West, along said division line and beyond, a distance of 7seventy-five and five hundredths feet(75.05')to a point at the division line of Lots 134 and 135 of said Plan; thence North thirty-one degrees(31')twenty-nine minutes(29')West, along said division line, a distance of one hundred thirteen and six hundredths feet(113.06')to a point on the Southern side of Edward Drive; thence South fifty-eight degrees(58')thirty-one(31') minutes East, along the Southern side of Edward Drive, a distance of seventy-five feet(75')to a point, the place of BEGINNING. BEING Lot No, 134 on Plan of Noll Acres, which plan is recorded in Plan Book 10, Pagel 7, HAVING thereon erected a one story frame house known as 6030 Edward Drive. BEING the same premises which Rosemary Lenker, by her deed dated February 25, 1998, and recorded in the Perry County Recorder of Deeds office in Book 173, Page 210 granted and conveyed to Jack H. Lenker and Rosemary Lenker, his wife. BEING designated as Cumberland County UP1:10-19-1604-113. 7. Said Mortgage is in default because the Defendants have failed to make the monthly installments payments due on May 5,2014, and thereafter on a regular basis. The following amounts are due on said Mortgage: Principal Amount Due $ 211,331.39 Accrued Interest $ 9,381.59 Accrued late charges $ 438.72 Attorney collection fee $ 10,566.57 TOTAL AMOUNT DUE $ 231,718.27 , 8. The purpose of the filing of this Complaint in Mortgage Foreclosure is to proceed to have the in described premises sold by the Sheriff of Cumberland County at a judicial sale pursuant to the statutory provisions of the Commonwealth of Pennsylvania and pursuant to the applicable rules of Court relevant to Mortgage Foreclosure as promulgated by the Supreme Court of Pennsylvania. 9. Plaintiff avers that notices required by Act 6 of 1974, and Act 91 of 1993, were given to the Defendants on May 13, 2014. WHEREFORE, Plaintiff demands judgment against the Defendants for the total amount of$231,718.27, together with interest at $63.39941 per day from July 3, 2014,a11 costs of suit, and for the Foreclosure Sale of the said premises described in Paragraph 6 above. Respec I tted Robert G. Radeba h, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RIVERVIEW BANK, f/k/a FIRST NATIONAL BANK OF MARYSVILLE, a Division of RIVERVIEW NATIONAL BANK, CIVIL ACTION - LAW Plaintiff vs. NO. Iq -q16 JACK H. LENKER and ROSEMARY. LENKER, MORTGAGE FORECLOSURE Mortgagors and Real Owners, Defendants AFFIRMATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA C.S.A. §4904 relating to unsworn falsification to authorities. DATED: `1 RIVERVIEW BANK, f/k/a FIRST NATIONAL BANK OF MARYSVILLE, a Division of RIVERVIEW NATIONAL BANK, By: o A- -' A. Wim Van Olden, Vice President Chief Credit Officer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RIVERVIEW BANK, Plaintiff 'TM° VS CIVIL ACTION - LAW JACK H. LENKER and NO. L/, e�ld 5— ROSEMARY LENKER, Mortgagors and IN MORTGAGE FORECLO#OkE- Q _- un Real Owners, Defendants = T,ra � . NOTICE OF RESIDENTIAL MORTGAGE FORECLOE DIVERSION PROGRAM . ` You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty(20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or(800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with 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 Wbifted: AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS R p Date: (61f ( obertG. Radebach, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RIVERVIEW BANK, f/k/a FIRST NATIONAL BANK OF MARYSVILLE, a Division of RIVERVIEW NATIONAL BANK, CIVIL ACTION - LAW Plaintiff vs. NO. JACK H. LENKER and ROSEMARY LENKER, MORTGAGE FORECLOSURE Mortgagors and Real Owners, Defendants REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RIVERVIEW BANK, f/k/a FIRST NATIONAL BANK OF MARYSVILLE, a Division of RIVERVIEW NATIONAL BANK, CIVIL ACTION - LAW Plaintiff vs. NO. JACK H. LENKER and ROSEMARY LENKER, MORTGAGE FORECLOSURE Mortgagors and Real Owners, Defendants : CASE MANAGEMENT ORDER AND NOW, this day of , 20 , the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2)which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 1 The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i'= ; LE o- Ci. F I Cs, Sheriff E h THE PROTHONQi TAR: of evirthetz, Jody S Smith Chief Deputy Richard W Stewart Solicitor OFT lCE 4F r y'HERIFF 2014 JUL 31 AM IU: 38 CUMBERLAND COUNTY PENNSYLVANIA Riverview Bank vs. Case Number Jack H Lenker (et al.) 2014-4105 SHERIFF'S RETURN OF SERVICE 07/17/2014 07:15 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Rosemary Lenker, wife, who accepted as "Adult Person in Charge" for Jack H Lenker at 6030 Edward Drive, Hampden Township, Mechanicsburg, PA 17055. DE IS FRY, DEFe4re-- 07/17/2014 07:15 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Rosemary Lenker at 6030 Edward Drive, Hampden Township, Mechanicsburg, PA 17055. SHERIFF COST: $55.79 SO ANSWERS,. July 18, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. RONR ANDERSON, SHERIFF Robert Radebach, Esquire 912 North River Road Halifax, PA 17032 717-896-2666 robradebachatty@aol.com PA. ID# 19255 Attorney for Plaintiff 204s p ,a0 5% a i 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RIVERVIEW BANK, f/k/a FIRST NATIONAL BANK OF MARYSVILLE, a Division of RIVERVIEW NATIONAL BANK, Plaintiff v. JACK H. LENKER and ROSEMARY LENKER, Mortgagors and Real Owners, Defendants : CIVIL ACTION - LAW NO. 14-4105 : MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE AND NOW, September da, 2014, I, Robert G. Radebach, Esquire, Attorney for Plaintiff, hereby certify that I served a copy of the Notice Pursuant to Pa.R.C.P. No. 237.1(a)(1) in the above -captioned matter upon Jack H. Lenker and omaty Lenker, Defendants, on September 18, 2014, by depositing the same i e United tates Mail, postage prepaid and via Certificate of Mailing (see Certifica1 f Mailing a ched hereto and hereby made a part hereof), in the post office at Harrisburg, Pennsyiania, addressed as follows: Jack H. Lenker 6030 Edward Drive Mechanicsburg, PA 17050 /"' Ro• -rt G. Radebach, Esquire 912 North River Road Halifax, PA 17032 (717) 896-2666 I.D.# 19255 Attorney for Plaintiff uo.-emary, en 6030 Eo and rive ani burg, PA 17050 1 Robert Radebach, Esquire 912 North River Road Halifax, PA 17032 717-896-2666 robradebachatty@aol.com PA. ID# 19255 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RIVERVIEW BANK, f/k/a FIRST NATIONAL BANK OF MARYSVILLE, a Division of RIVERVIEW NATIONAL BANK, . CIVIL ACTION - LAW Plaintiff v. : NO. 14-4105 JACK H. LENKER and ROSEMARY LENKER, : MORTGAGE FORECLOSURE Mortgagors and Real Owners, Defendants To: Jack H. Lenker and Rosemary Lenker, Defendants Date of Notice: September 18, 2014 IMPORTANT NOTICE Pursuant to Pa.R.C.P. No. 237.1(a)(1) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BYATTORNEYAND 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 UNITED STATES Certificate 0. POSTAL. SERVICE, Mailin9 Thai CerlahiGilt of halialanq harara011.% VaaaiWICe foal en:aal Na, Oren pte Called 14 USPS lo IN,, loffil Mary be ,j,14 to, OhnielataK 000 anliaMAtaanif mast from _ Robert G. Radebach, Esquire 912 North River Road Halifax, PA 17032 to _3acK EI. Ly ------- t\lle0anICSIapal_ 0056 PS Form 3817. April 2007 PSN 7530-02-000-9065 • 2. POilfitath Hi!fia UNITED STATES Certifica liOf f POSTAL SERVICE Fn+s CenAute W MarLnq Pr O.rdrs esnatntr tnat mad rtat peen prtscnteo to USPSO for rnanmq this form may pr used lar domeia[ and mtrrnauonar man F torn Robert G. Radebach, Esquire 912 North River Road Halifax, PA 17032 PS Form 3817. April 200/ PSN 7530.02-000-9065 Postman~ Hoc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RIVERVIEW BANK, fka, FIRST NATIONAL BANK OF MARYSVILLE, a Division of : RIVERVIEW NATIONAL BANK, : Plaintiff vs. JACK H. LENKER and ROSEMARY LENKER, Mortgagors and Real Owners, Defendants Civil Action - Law No. 14-4105 MORTAGE FORECLOSURE PRAECIPE FOR ENTRY OF APPEARANCE 737 i, ; TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendant, Rosemary Lenker, in the action referenced above. 5;7e, t. Date gif itic . t Koch, Esq. PA Attorney number 98956 6 Clouser Road Mechanicsburg, PA 17055 717-691-1882 IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA-,. , pi RIVERVIEW BANK, fka, Civil Action - Law �;,�f SEPr FIRST NATIONAL BANK PEP�tS YL, y fr. tjf OF MARYSVILLE, a Division of : RIVERVIEW NATIONAL BANK, Plaintiff vs. JACK H. LENKER and ROSEMARY LENKER, Mortgagors and Real Owners, Defendants No. 14-4105 MORTAGE FORECLOSURE ANSWER TO COMPLAINT IN MORTAGE FORECLOSURE 1. Admitted, to the best of knowledge and belief. 2. Denied. Jack Lenker is deceased. 3. Admitted. 4. Admitted as to the transaction. 5. Admitted, to the best of knowledge and belief. 6. Admitted with the proviso that the property was never recorded in Perry County as mistakenly stated. 7. Neither admitted nor denied. The mortgage was for the purpose of securing a business loan for Bradley L. Lenker and Edward Donbach. Since all payments on the loan were made by Bradley L. Lenker and/or Edward Donbach, the defendant has no knowledge of the status of monthly payments. In addition, Ms. Lenker does not have knowledge of or access to the figures used in the complaint. 8. Neither admitted nor denied. Ms. Lenker has no knowledge of the plaintiffs purpose in filing this complaint. 9. Ms. Lenker has no recollection of receiving the documents stated. For the reasons stated above, the Defendant Rosemary Lenker asks this court to deny the Plaintiffs requests for an order of a foreclosure. Date chch, sq. PA Attorney number 98956 6 Clouser Road Mechanicsburg, PA 17055 717-691-1882 VERIFICATION I, Rosemary Lenker, verify that the statements made in the foregoing document are true and correct. I understand that any false statements contained herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities for any false statements. 1J9Z2 41g•oi'l Date CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copies of the Praecipe for Entry of Appearance and the Answer to Complaint in Mortgage Foreclosure, case 14-4105, upon the plaintiff, by depositing same in the United States Mail, first class mail, postage prepaid, on the 29th day of September 2014, from Mechanicsburg, Pennsylvania, addressed as follows: Robert Radebach, Esquire 912 North River Road Halifax, PA 17032 RESPECTFULLY SUBMITTED, d Koch, Esquire 6 Clouser Road Mechanicsburg, PA 17055 (717) 691-1882 ID# 92956