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HomeMy WebLinkAbout14-4304 Supreme Court of Pennsylvania Court of Common Pleas ForProthonotart•Us Onit°: Civil Cover Sheet Docket No: ' Cumberland County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service of leadin .s or other papers as required by law or rules of court. S Commencement of Action: E x Complaint ❑Writ of Summons ❑Petition C ❑Transfer from Another Jurisdiction ❑ Declaration of Takia Lead Plaintiffs Name: FEDERAL NATIONAL Lead Defendant's Name:MICHELE LYNN THORN T MORTGAGE ASSOCIATION("FANNIE MAE") T •O N Are money damages requested? : o Yes X No Dollar Amount Requested: within arbitration limits A Check one outside arbitration limits Is this a Class Action Suit? ❑❑ Yes 0 No Is this an MDJA eal? ❑ Yes ❑X No Name of Plaintiff/Appellant's Attorney:Martha Von Rosenstiel,Esq. ❑ Check here if you are a Self-Represented(Pro Se Litigant N nture of the Case: Place an"1" to the left of the ONE case category that most accurately describes your PRLW-4RY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do no,•include Hass Tort) CONTRACT(do not Inclsrde Judgments) CIN'IL APPEALS Intentional ❑Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑Debt Collection:Credit Card ❑ Board of Assessment. Motor Vehicle ❑Debt Collection:Other ❑ Board of Elections ❑'utsance ❑ Dept.of Transportation Premises Liability ❑ Stanztory Appeal:Other +S ❑ Product Liability{does ntot include mass to?-0 ❑Ernploynnent Dispute: E E:] Slander/Libel/Defamation Discrimination C ❑ Other: ❑Employruent Dispute:Other ❑ Zoning Board T ❑ Other: Other: O MASS TORT ❑ Asbestos Tobacco Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOi-S Toxic Waste Other. ❑Ejectment ❑Connnon Law/Statutory Arbitration B ❑Eminent.Domain/Condennuntion ❑Declaratory Judgment ❑Ground Rent. Mandamus Landlord/Tenant Dispute 8 Non-Domestic Relations x❑Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ❑Mortgage Foreclosure:Commercial ❑Quo Warranto ❑ Dental ❑Partition ❑Replevin Legal ❑Quiet Title ❑Other- ❑ Medical ❑Other: Other Professional.: Updated 1/112011 tt`r�-- r.;� MARTHA E. VON ROSENSTIEL P.C. �i,rt ; 34667CFC-AB Martha E. Von Rosenstiel, Esquire/No. 52634 ? fr ` Heather Riloff, Esquire/No. 309906 4 1j; ,, r „ 649 South Avenue, Suite 7 i`S"ER 0L0- ;- Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 ( U Plaintiff V. NO. J v MICHELE LYNN THORN 516 North Bedford Street Carlisle, PA 17013 Defendant CIVIL ACTION—MORTGAGE FORECLOSURE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims Le han demandado a usted en la corte. Si usted quiere defenderse de set forth in the following pages,you must take action within twenty estas demandas expuestas en las paginas siguientes,usted tiene (20)days after this complaint and notice are served,by entering a veinte(20)dias de plazo al partir de la fecha de la demanda y la written appearance personally or by attorney and filing in writing with notificacion. Hace falta a sentar una comparencia escrita o en the court your defenses or objections to the claims set forth against you. persona o con un abogado y entregar a la corte en forma escrita sus You are warned that if you fail to do so the case may proceed without defensas o sus objeciones a las demandas en contra de su persona. you and a judgment may be entered against you by the court without Sea a visado que si usted no se defiende,la corte toma ra medidas y further notice for any money claimed in the complaint or for any other puede continuar la demanda en contra suya sin previo aviso o claim or relief requested by the plaintiff. You may lose money or notificacion. Ademas,la corte puede decidir a favor del demandante property or other rights important to you y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT LLEVE ESTA DEMANDA A UN ABOGADO ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN TELEPHONE THE OFFICE SET FORTH BELOW.THIS PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT ESTA OFICINA LE PUEDE PROVEER INFORMACION HIRING A LAWYER.IF YOU CANNOT AFFORD TO HIRE A SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A WITH INFORMATION ABOUT AGENCIES THAT MAY UN ABOGADO,LE PODEMOS DAR INFORMACION OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A REDUCED FEE OR NO FEE PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 S' 717-249-3166 800-990-9108 nVlk } (I U S( 3 010 F9 4 l THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §16929 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS,YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE,NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. 34667CFC-AB Martha E. Von Rosenstiel, Esquire/'No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff V. NO. MICHELE LYNN THORN 516 North Bedford Street Carlisle, PA 17013 Defendant CIVIL ACTION- MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Federal National Mortgage Association ("Fannie Mae"), a corporation organized and existing under the laws of the United States of America, with offices for the conduct of business at 3900 Wisconsin Avenue, NW, Washington, DC 20016-2892. 2. Defendant, Michele Lynn Thorn is the mortgagor and real owner of premises 516 North Bedford Street, Carlisle, PA 17013, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor, and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor, and real owner to Mortgage Electronic Registration Systems, Inc. as Nominee for Members 1st Federal Credit Union on October 31, 2008, which mortgage was recorded on November 7, 2008 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instrument No. 200836472, secured on premises 516 North Bedford Street, Carlisle, PA 17013 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to Federal National Mortgage Association by written assignment dated April 25, 2012 and recorded on May 8, 2012 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instrument No, 201213650. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from December 2013 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 116,419.94 Interest from 11/1/2013 to 7/12/2014 at $14.75 per diem $ 3,732.22 Accrued late charges $ 305.91 Accrued Escrow deficit $ 1,262.65 Attorney's Fee $ 1,650.00 Returned Check Charges $ - 75.00 Speedpay Charges $ 20.00 Property Inspections $ 105.00 Total $ 123,570.72 1 9. Plaintiff sent to obligated defendant, mortgagor and real owner a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 as amended by Act 160 of 1998 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of$123,570.72, plus per diem interest at $14.75 from July 13, 2014 to the date of judgment plus costs thereon. MARTHA E. VON ROSENSTI L, P.C. BY: Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff VERIFICATION Jehmtte Half hereby states that he/she is the l orecl6sure Specialist of Seterus, Inc., as authorized subservicer for Federal National Mortgage Association("Fannie Mae"), a corporation organized and existing under the laws of the United States of America,plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Federal National Mortgage Association("Fannie Mae") and verifies that the statements made in the foregoing Complaint in Federal National Mortgage Association ("Fannie Mae") v. Michele Lynn Thorn relating to the property located at 516 North Bedford Street, Carlisle, PA 17013 are true and correct to the best of his/her information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: " e Hall Title: reclosure Specialist Seterus, Inc., as authorized subservicer for Federal National Mortgage Association ("Fannie Mae"), a corporation organized and existing under the laws of the United States of America Dated: EXHIBIT I LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected, situate in the First Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING on the North by property now or formerly of Edward Baker and wife; on the East by North Bedford Street; on the South by property now or formerly of John Grissinger and on the West by an alley. CONTAINING a frontage of 19 feet 6 inches, more or less, on North Bedford Street, and running a depth at an even width 120 feet to the alley aforesaid; the northern line of the property hereby conveyed running through the middle of the partition wall between property herein described and property now or formerly of Edward Baker and wife aforesaid. BEING improved with a two-story dwelling known as 516 North Bedford Street, Carlisle, Pennsylvania 17013. 4 PARCEL IDENTIFICATION NO: 02-20-1800-027, CONTROL#: 02000030 EXHIBIT II seterusTm Physical Address 14523 SW Millikan Way;Suite 200; Beaverton,OR 97005 Business Hours(Pacific Time) Monday-Thursday 5 a.m.to 8 p.m. Friday 5 a.m.to 6 p.m. Payments February 2, 2014 PO Box 11790;Newark,NJ 07101-4790 Correspondence VIA CERTIFIED AND FIRST CLASS MAIL PO Box 2008;Grand Rapids,MI 49501-2008 Phone 866.570.5277 Ll 78R Fax THORN,MICHELE LYNN 866.578.5277 516 N BEDFORD ST Website CARLISLE,PA 17013 www.seterus.com Loan number:! serviced by Seterus,Inc. Please read the following important notice about your loan. Sincerely, Seterus,Inc. Enclosures: Act 91 Notice,PHFA list of HEMAP-approved agencies,How to Avoid Foreclosure THIS COMMUNICATION IS FROM A DEBT COLLECTOR AS WE SOMETIMES ACT AS A DEBT COLLECTOR. WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER,IF YOU ARE IN BANKRUPTCY OR RECEIVED A BANKRUPTCY DISCHARGE OF THIS DEBT,THIS LETTER IS NOT AN ATTEMPT TO COLLECT THE DEBT,BUT NOTICE OF POSSIBLE ENFORCEMENT OF OUR LIEN AGAINST THE COLLATERAL PROPERTY. COLORADO:FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.COLORADOATTORNEYGENERAL.GOV/CA. Seterus,Inc.maintains a local office at 355 Union Boulevard,Suite 250,Lakewood,CO 80228.The office's phone number is 888.738.5576. NEW YORK CITY: 1331537, 1340663, 1340148. TENNESSEE: This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance.Seterus,Inc.is licensed to do business at 14523 SW Millikan Way,Beaverton,OR. z I:ale 1 of 6 Date: February 2, 2014 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and that the lender/servicer intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 800.342.2397. (Persons with impaired hearing can call 717.780.1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA,PUES AFECT.A SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM"EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDINIIR SU HIPOTECA. Page 2 of 6 HOMEOWNER'S NAME(S): THORN,MICHELE LYNN PROPERTY ADDRESS: 516 N BEDFORD ST CARLISLE,PA 1701.3-1913 LOAN ACCT.NO.: ORIGINAL LENDER: MEMBERS 1ST FEDERAL CREDIT CU CURRENT LENDER/SERVICER: Seterus,Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE. WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983(THE "ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act,you are entitled to a temporary stay of foreclosure on your mortgage for thirty(30)days from the time of this Notice(plus three(3)days for mailing). During that time you must arrange and attend a "face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33)DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this Notice,the lender/servicer may NOT take action against you for thirty(30)days after the" date of this meeting. The names,addresses, and telephone numbers of designated consumer credit counseling_a eg ncies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender/servicer immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice(see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so,you must fill out, sign, and file a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender/servicer from filing a foreclosure action,your application MUST be forwarded to PHFA and received within thirty(30)days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING,THEN THE LENDER/SERVICER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY,AS EXPLAINED ABOVE,IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." Page 3 of 6 YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER/SERVICER FROM STARTING A FORECLOSURE ACTION,BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE,THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty(60) days to make a decision after it receives your application. During that time,no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE:IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY,THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy,you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up-to-date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender/servicer on your property located at: 516 N BEDFORD ST CARLISLE,PA 1701.3-1913 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE REGULAR MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Payments: December 1, 2013 through February 1,2014 in the amount of$864.26 each Total: $2,592.78 Past Due Installments: $2,592.78 Other Open Charges: Prior Servicer Charges Seterus,Inc. Charges Late Charges 0.00 278.10 278.10 Property Inspections 0.00 30.00 30.00 Returned Check Charges 0.00 75.00 75.00 Speedpay Charges 0.00 20.00 20.00 Total Past Due Installments&Charges $2,995.88 Less Suspense(Balance) 0.00 TOTAL AMOUNT PAST DUE $2,995.88 Pk,-,e 4 of 6 HOW TO CURE THE DEFAULT--You may cure the default within THIRTY(30)DAYS of the date of this.notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER/SERVICER, WHICH IS $2,995.88,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES,WHICH BECOME DUE DURING THE THIRTY(30)DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: Seterus,Inc. PO Box 11790 Newark,NJ 07101-4790 IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY(30)DAYS of the date of this Notice,the lender/servicer intends to exercise its rights to accelerate the morteage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in regularly scheduled installments. If full payment of the total amount past due is not made within THIRTY (30)DAYS,the lender/servicer also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender/servicer refers your case to its attorneys,but you cure the delinquency before the. lender/servicer begins legal proceedings against you,you will still be required to pay the reasonable attorney's fees that were actually incurred,up to $50.00. However, if legal proceedings are started against you,you will have to pay all reasonable attorney's fees actually incurred by the lender/servicer even if they exceed$50.00. Any attorney's fees will be added to the amount you owe the lender/servicer,which may also include other reasonable costs. If you cure the default within the THIRTY(30)DAY period,you will not be required to pay attorney's fees. OTHER LENDER/SERVICER REMEDIES-- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO THE SHERIFF'S SALE-- If you have not cured the default within the THIRTY(30)DAY period and foreclosure proceedings have begun,you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due,reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender/servicer and by performing any other requirements under the mortage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five(5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender/servicer. Page 5 of 6 HOW TO CONTACT THE LENDER/SERVICER: Name of Lender/Servicer: Seterus,Inc. Address: PO Box 2008 Grand Rapids,MI 49501-2008 Phone Number: 866.570.5277 Fax Number: 877.649.0743 Contact Irerson(s):.Shannon Stock or Nathan Wetzel E-Mail Address: ExternalCommunications@seterus.com EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender/servicer at any time. ASSUMPTION OF MORTGAGE--You_may or X may not sell or transfer your home to a buyer or transferee who will asuume the mortgage debt,provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED,IF YOU CURE THE DEFAULT. • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER/SERVICER. • TO SEE PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Enclosed is a list of CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY. Page 6 of 6 i FORM 1 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY, 3900 Wisconsin Avenue,NW PENNSYLVANIA Washington, DC 20016-2892 t/" L VS. s Plaintiff s. NO. rn MICHELE LYNN THORNCD IU ', 516 North Bedford Street .._ Carlisle, PA 17013 CD Defendant �CD a H NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First,within twenty(20) days of your receipt of this notice, you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date, During that meeting, you must_, provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an a tempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Res tfully submitted: July 14, 2014 Date Signature of Counsel for Plaintiff } 4 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSrOMERIPRIMARY APPLICATION Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes❑ No❑ Listing date: Price: Realtor Name: Realtor Phone: Borrower Occupied: Yes❑ No❑ Mailing Address(if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? Mailing Address: City: _ State: Zip: _ Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? INFORMATIONFINANCIAL First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: _ Loan Number: Total Mortgage Payments Amount:$ Included Taxes and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy?Yes❑ No❑ If yes,provide names, location of court,case number&attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ _ $ Other: $ $ Automobile#1:Model: Year: Amount owed: Value: Automobile#2:Model: Year: Amount owed: Value: Other transportation(automobiles, boats,motorcycles): Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description(not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses:(Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2° Mortgage Utilities Car Payments) Condo/Neigh.Fees Auto Insurance Med.(not covered) Auto fuel/repairs Other Prop.Payment Install. Loan Payment Cable TV Child Support/Alien. Spending Money Day/Child Care/Twit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes[] No If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes❑ No R If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company(Name): Contact: Phone: I/We, _ authorize the above named to use/refer this information to my lender/servicer for.the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement(if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed FORM 3 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY, 3900 Wisconsin Avenue, NW PENNSYLVANIA Washington, DC 20016-2892 Plaintiff VS. NO. MICHELE LYNN THORN 516 North Bedford Street Carlisle, PA 17013 Defendant REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY, 3900 Wisconsin Avenue, NW PENNSYLVANIA Washington, DC 20016-2892 Plaintiff vs. NO. MICHELE LYNN THORN 516 North Bedford Street Carlisle, PA 17013 Defendant 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 i Court of the defendant/borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation'Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Q,�ec• • •••4 ©FF"CE OF Tkm $ pRIFF i -i0 OIF1,,. C 1 tit r'ROTHONOri�,; 2u#4 AUG 26 AM 10: 05 CUMBERLAND COUNTY PENNSYLVANIA Federal National Mortgage Association vs. Michele Lynn Thorn Case Number 2014-4304 SHERIFF'S RETURN OF SERVICE 08/14/2014 05:21 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Michael Lynn Thorn at 516 North Bedford Street, Carlisle Borough, Carlisle, PA 17013. SHERIFF COST: $35.27 SO ANSWERS, August 15, 2014 (c) CountySuile Shenfr, TeIeosoft, Inc. RONNY R ANDERSON, SHERIFF MARTHA E. VON ROSENSTIEL, P.C. Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff vs. MICHELE LYNN THORN 516 North Bedford Street Carlisle, PA 17013 Defendant : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No. 14-4304 Civil PLAINTIFF'S MOTION TO REMOVE CASE FROM THE CUMBERLAND COUNTY RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM Plaintiff, Federal National Mortgage Association ("Fannie Mae") by and through its undersigned counsel, Martha E. Von Rosenstiel, P.C., Heather Riloff, Esquire, hereby respectfully requests that this Honorable Court enter an Order granting its Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, and in support thereof, avers as follows: 1. This matter has been assigned to the Honorable Kevin A. Hess, P.J. for matters concerning the Residential Mortgage Conciliation Program. 2. This is a residential mortgage foreclosure action. 3. On or about August 14, 2014, service of the Mortgage Foreclosure Complaint was completed in this action and the 60 day stay of proceedings went into effect pursuant to the February 28, 2012 Administrative Order. 4. As of October 17, 2014, 60 days after service of the Complaint and Notice, Plaintiff has not received notice of a Conciliation Conference date, nor a Diversion Program Financial Worksheet 5. Neither Plaintiff nor its undersigned counsel has received any communication from a housing counselor on the Defendant's behalf. 6. Plaintiff respectfully requests that it be permitted to proceed with its foreclosure action. WHEREFORE, Plaintiff, Federal National Mortgage Association ("Fannie Mae"), respectfully requests this case be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. Dated: October 17, 2014 MARTHA E. VON ROSENSTIEL, P.C. Qtther Riloff, Es uire PA Attorney ID No 309 Attorney for Plaintiff 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 BY: MARTHA E. VON ROSENSTIEL, P.C. Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff vs. MICHELE LYNN THORN 516 North Bedford Street Carlisle, PA 17013 Defendant COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No. 14-4304 Civil CERTIFICATION OF SERVICE Heather Riloff, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, and proposed order in the above matter was made upon the Defendants: MICHELE LYNN THORN 516 North Bedford Street Carlisle, PA 17013 by regular first class mail, postage prepaid, deposited with the United States Postal Service on October 17, 2014. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. BY: Dated: October 17, 2014 Heather Riloff, Esq Attorney for Plaintif VERIFICATION HEATHER RILOFF, ESQUIRE, hereby states that she is the Attorney for the Plaintiff in this action and that the statements made in the forgoing Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, are true and correct to the best or her information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: LHo, Heather Riloff,i Attorney for Pla%'iff Date: October 17, 2014 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY 3900 Wisconsin Avenue,NW Washington, DC 20016-2892 Plaintiff VS. No. 1.4-4304 Civil MICHELE LYNN THORN 516 North Bedford Street Carlisle,PA 17013 Defendant ORDER OF COURT AND NOW, this Z•$lday of air , 2014,the Defendants having failed to comply with the requirements of the Cumberland County Administrative Order dated February 28, 2012, it is hereby ORDERED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. The temporary stay on this matter is terminated. BY THE COURT: J. �� o rq z --f 1 r-- cc 1'9 IT 1J. D M, / "7� /U/2t{/Iy =Cryl #34667CFJ-DN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,.PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff V. : NO. 14-4304 Civil MICHELE LYNN THORN Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Michele Lynn Thorn for want of an answer. (X) Assess Damages as Follows Debt Interest from 7/13/14 to 12/16/14 At $14.75 per diem Total $ 123,570.72 $ 2,315.75 $ 125,886.47 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to fIe this Praecipe was mailed or delivered to the party against whom judgment is to be entered : nd to his attorney of record, if any, after the default occurred and at least (10) days prior to th; date of the filing 'of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 This ).bday of e MARTHA E. VON ROSEN`TIEL, P.C. rartha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Jeniece D. Davis, Esquire Attorneys for Plaintiff , 2014 judgment is entered in favor of the Plaintiff and against Defendant(s), Michele Lynn Thorn by default for ant of an answer and damage `; sessed at the sum of $125,886.47 as per the above certification. Prothonotary, Cum.'r anounty (�-� 105S1 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610)328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff v. MICHELE LYNN THORN Defendant TO: Michele Lynn Thorn 516 North Bedford Street Carlisle, PA 17013 #34667CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14-4304 Civil IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: 10/31/14 Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Jeniece D. Davis, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 IIe`ather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff vs. MICHELE LYNN THORN Defendant(S) : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No: 14-4304 Civil II -L1, NON MILITARY AFFIDAVIT Martha E. Von Rosenstiel, P.C. by the undersigned hereby certifies that: 1. I am the attorney for the plaintiff herein. 2. The individual involved in this action is the owner of the premises described in the mortgage underlying this action. 3. The procedures of the Law Office of Martha E. Von Rosenstiel, P.C. are designed to discover facts concerning the military status of the mortgagor(s) and/or real owner(s). 4. Said procedures were followed in connection with the instant foreclosure proceeding. 5. Inquiry made with the Department of Defense, has confirmed that the defendant(s) is/are not in the military. 6. On information and belief, named mortgagor(s) and real owner(s) is/are not incompetent nor a service member in military service as defined by the Servicemembers Civil Relief Act, 50 U.S.C. App Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsifi'ation to authorities. Dated: December 16, 2014 MARTHA E. VON ROSENSTIEL, P.0 BY rartha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Jeniece D. Davis, Esquire Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Michele Lynn Thorn 516 North Bedford Street Carlisle, PA17013 FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") PLAINTIFF VS. MICHELE LYNN THORN DEFENDANT(S) David D. Buell, Prothonotary : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO: 14-4304 CIVIL Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below in the amount of $125,886.47 on December 16, 2014. X David D. Buell Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings laIla��'f If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this telephone number:610-328-2887. Commonwealth of Pennsylvania COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") v. MICHELE LYNN THORN 34667(; W E-llN COURT OF COMMON PLEAS DOCKET NO. 14-4304 Civil ATTORNEY I.D. #52634 ATTORNEY I.D. #309906 ATTORNEY I.D. # 208967 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 12/17/2014 to 6/3/2015 At6% TOTAL* *Plus costs to be endorsed PREM: 516 North Bedford Street, Carlisle, PA 17013 t ts.--)s<< °`' RNie_ $ 125,886.47 3,496.61 $ 129,383.08 MARTHA E. VON ROSENS IEL, P.C. artha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Jeniece D. Davis, Esquire Attorneys for Plaintiff s-.‹C-DL0--e 00. dU(Asg. fd/efi THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Vs. NO 14-4304 Civil Term CIVIL ACTION — LAW MICHELLE LYNN THORN WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See. legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $125,886.47 L.L.: $.50 Interest FROM 12/17/2014 TO 6/3/2015 AT 6% - $3,496.61 Atty's Comm: Due Prothy: $2.25 Atty Paid: $194.02 Plaintiff Paid: Date: 12/18/1.4 rI (Seal) . Other ts: Dav�'r Buell, Pr. honotary By: Deputy REQUESTING:PARTY: Name: MARTHA VON ROSENSTIEL, ESQUIRE Address: 649 SOUTH AVENUE, SUITE 7 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634 #34667 -DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 • (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE : COURT OF COMMON PLEAS ASSOCIATION ("FANNIE MAE") : CUMBERLAND COUNTY Plaintiff VS. : NO: 14-4304 CIVIL MICHELE LYNN THORN Defendant(s) LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected, situate in the First Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING on the North by property now or formerly of Edward Baker and wife; on the East by North Bedford Street; on the South by property now or formerly of John Grissinger and on the West by an alley. CONTAINING a frontage of 19 feet 6 inches, more or less, on North Bedford Street, and running a depth at an even width 120 feet to the alley aforesaid; the northern line of the property hereby conveyed running through the middle of the partition wall between property herein described and property now or formerly of Edward Baker and wife aforesaid. BEING improved with a two-story dwelling known as 516 North Bedford Street, Carlisle, Pennsylvania 17013. PARCEL IDENTIFICATION NO: 02-20-1800-027, CONTROL #:.02000030 IMPROVEMENTS: Residential dwelling Tax Parcel # 02-20-1800-027 TITLE TO SAID PREMISES IS VESTED IN Michele Lynn Thorn, by Deed from Jason A. Randalls and Michelle J. Randalls, h/w, dated 10/31/2008, recorded 11/07/2008 in Instrument Number 200836471. l MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff VS. MICHELE LYNN THORN Defendant(s) #34667CAM - DN : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO: 14-4304 CIVIL AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 LI4 DEC I D F ; 3: 23 CU,,;i3ER r ,., FEN;!SYL4 nA':i�' Martha E. Von Rosenstiel, P.C. by the undersigned attorney for the Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 516 North Bedford Street, Carlisle, PA 17013: 1. Name and address of owners(s) or reputed owner(s) Michele Lynn Thorn 516 North Bedford Street Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Michele Lynn Thorn 516 North Bedford Street Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Target National Bank, Target Visa 213 East Main Street Carnegie, PA 15106 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim 1 Courthouse Square Carlisle, PA 17013 Cumberland Register of Wills County Courthouse Carlisle, PA 17013 Attorney General of the U.S. C/O Assistant Attorney General Tax Division U.S. Department of Justice P.O. Box 227 Washington, DC 20044 PA Department of Revenue Inheritance Tax division, P.O. Box 280601 Harrisburg, PA 17128 Family Court/Domestic Relations 1 Courthouse Square ,Carlisle, PA 17013 PA. Department of Revenue Bureau of Compliance Attn: Sheriff Sale Section P.O. Box 218230 Harrisburg, PA. 17128-1230 Dept of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Pennsylvania Department of Revenue Bureau of Individual Taxes PO Box 280603 Harrisburg, PA 17128-0603 Cumberland County Adult Probation 4 East Liberty Avenue Carlisle, PA 17013 Occupant 516 North Bedford Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct upon Information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. .S. Section 4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSE (STIEL, P.C. BY. M Pha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Jeniece D. Davis, Esquire Attorneys for Plaintiff Dated: December 15, 2014 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff vs. MICHELE LYNN THORN Defendant(s) #34667-CWE-DN 2014Dt C 18 i'(r' 3: 23 Cts; ,3 i,'t.,;;; ,O COU14TY PCfi:'SYEA/AN/A : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No: 14-4304 Civil CERTIFICATE TO THE SHERIFF I hereby certify that I am the attorney of record for the plaintiff in this action again real property and further certify that this property is: XX• FHA — Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including, but not limited to: (a) Service of the Notice on the Defendants (b) Expiration of the 30 days since Service of the Notice (c) Defendants' failure to request or appear at meeting with mortgagee or Consumer Credit Counseling Agency (d) Defendants' Failure to file application with the Homeowners Emergency Assistance Program I further agree to indemnify and hold harmless the Sheriff for any false statement _'ven herein. BY RTHA E. VON ROSE 6STIEL, P.C. ha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Jeniece D. Davis, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff Federal National Mortgage Association : COURT OF COMMON PLEAS ("Fannie Mae") : CUMBERLANDCOUNTY 3900 Wisconsin Avenue, NW Washington DC 20016-2892 Plaintiff vs. : No: 14-4304 Civil Michele Lynn Thorn 516 North Bedford Street Carlisle, PA 17013 Defendants AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE Martha E. Von Rosenstiel, P.C. by the undersigned for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the last known addresses of the defendants are: 1. Name and address of owners(s) or reputed owner(s) and/or defendant(s) in the judgment: Michele Lynn Thorn 516 North Bedford Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct upon information and belief. I understand that false'statements herein are made subject to the penalties of 18 P C.S. Section 4904 relating to unsworn falsification to authorities. BY: MARTHA E. VON ROSENS IEL, P.C. M. E. Von Rosenstiel, Esquire Heather Riloff, Esquire Jeniece D. Davis, Esquire Attorneys for Plaintiff 34667CAM-DN MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION ("FANNIE MAE") Plaintiff vs. MICHELE LYNN THORN Defendant(s) Ti,E Pi;OT ONO : • Will DEC i 8 PH 3: 23 0U;•iii3Ef;Lf,;i0 COUNTY PEHt!3YEVANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No: 14-4304 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO ALL PARTIES IN INTEREST AND CLAIMANTS: The real estate and improvements, if any, located at and known as 516 North Bedford Street Carlisle, PA 17013 will be sold by the Sheriff of Cumberland County on Date of Sale: June 03, 2015 Time of Sale: 10:00 a.m. Place of Sale: Cumberland County Court House, 1 Courthouse Square, Carlisle, PA 17013. This sale is being held on a Judgment in Mortgage Foreclosure filed under Docket No. 14-4304 Civil in the Court of Common Pleas of Cumberland County by Federal National Mortgage Association ("Fannie Mae"), Plaintiff against Michele Lynn Thorn, Defendant(s). Judgment was entered on December 16, 2014 in the amount of $125,886.47. The property was seized and taken in execution as the property of Michele Lynn Thorn. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN tract of land with improvements thereon erected, situate in the First Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING on the North by property now or formerly of Edward Baker and wife; on the East by North Bedford Street; on the South by property now or formerly of John Grissinger and on the West by an alley. CONTAINING a frontage of 19 feet 6 inches, more or less, on North Bedford Street, and running a depth at an even width 120 feet to the alley aforesaid; the northern line of the property hereby conveyed running through the middle of the partition wall between property herein described and property now or formerly of Edward Baker and wife aforesaid. BEING improved with a two-story dwelling known as 516 North Bedford Street, Carlisle, Pennsylvania 17013. PARCEL IDENTIFICATION NO: 02-20-1800-027, CONTROL #: 02000030 IMPROVEMENTS: Residential Dwelling A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Judgment was recovered in the Court of Common Pleas of Cumberland County Civil Action No. 14-4304 Civil. You should check with the Sheriff's Office by calling (717) 240- 6390 to determine the actual date of the filing of the schedule. No further notice of the filing of the Schedule of Distribution will be given. Ronny R. Anderson, Sheriff of Cumberland County ATTORNEY FOR PLAINTIFF: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Heather Riloff, Esquire / No. 309906 Jeniece D. Davis, Esquire /No. 208967 Attorneys for Plaintiff 649 South Avenue, Unit #6 Secane, PA 19018 Phone: (610) 328-2887 Fax: (610) 328-2875