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Home My WebLink About14-4981 Supreme Court of Pennsylvania Court of Common Pleas For Prothonolan-Use Onty. -, A I Civil Cover Sheet Docket No: Cumberland County ) The information collected on this form is used solely for court administration purposes. This form does not sup, le e t or replace the slim and set-vice qfpleadiW or other pgpers as uired by law or rules ofcourt. 'emen' m n S Commencement of Action: E x Complaint o Writ of Summons o Petition I Transfer o Trans:from Another Jurisdiction o Declaration of Taking C PI rL�e�ad Plaintiffs Name:NATIONWIDE ADVANTAGE Lead Defendant's Name: ANDI H. M ELOY MORTGAGE T MORTGAGE COMPANY I 0 N Are money damages requested? : D Yes X No Dollar Amount Requested: within arbitration limits A (Check one -outside arbitration limits Is this a Class Action Suit? Do Yes OX No Is this an MDJAppeal? o Yes OX No Name of Plaintiff/Appellant's Attorney:Martha Von Rosenstiel,Esq. o Check here if you are a Self-Represented(Pro Se)Litigant 1 at-ure of the Case: Place an'X" to the left of the ONE case categoly that most acc-urately describes your PRIA114RYCASE. If you me snaking inore than one type of claims-check the one that you consider most inil3ortant. TORT(do not hichideMass Tort) CONTRACT(do nor include judgments) CIVIL APPEALS 0 Intentional 0 1311-ver Plaintiff Achniuistrative Agencies 0 Malicious Prosecution []Debt Collection,Credit Card [3 Board ofAssessnaeut [:]Motor Vehicle 0 Debt Collection:Other rl Board of Elections 0 Nuisance El Dept.ofTransportation [] Premises Liability r-1 Statutory Appeal:Other S 0 Product Liability(does slot h2chide Mass 101-0 0 Employinent Dispute: E 0 SlanderiLibel:Defamation Discrimination C 0 Other: Employment Dispute:Other Q Zoning Board T 0 other 1 0 Other: o INIASS TORT El Asbestos N 0 Tobacco [:] Toxic Tort-DES El Toxic Tort-Implant REAL PROPERTY AlISCELLANEOUS [3 Toxic Waste [I Ejectment E]Cotinnon Law/Statutory,Arbitration B 0 Other: 0 Eminent Doinain/Coudeirnintion ❑Declaratory Judgment Ground Rent. Mandamus Landlord/Tenant Dispute Non-Domestic Relations Mortgage Foreclosure:Residential Restraiiiing Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure.Commercial 0 Quo,Warranto 0 Dental ❑Partition 1:1 Replevin 0 LegM ❑Quiet Title El Other: rl Medical Other: 0 Other Professional: T-)i do i ed 1/1/41 011 F' ?p ANG, O lr�,' Y 35007CFC-AB MARTHA E. VON ROSENSTIEL, P.C. i Martha E. Von Rosenstiel, Esquire/No. 52634 AUG 25 Heather Riloff, Esquire/No. 309906649 South w(1P3 L �Ef� Se ane PA 19018 Suite 7 PENN YLV COUNTY (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 Plaintiff V. NO. ANDI H. MELOY 68 Oliver Road Enola, PA 17025 Defendant CIVIL ACTION—MORTGAGE FORECLOSURE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims Le ban demandado a usted en]a 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)dial 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 provisioner 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 717-249-3166 I C 800-990-9108 ��- baa /q THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS,YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. MARTHA E. VON ROSENSTIEL, P.C. 35007CFC-AB Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 Plaintiff V. NO. ANDI H. MELOY 68 Oliver Road Enola, PA 17025 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 Nationwide Advantage Mortgage Company, a company organized and existing under state law, with offices for the conduct of business at 1100 Locust St., Dept. 2009, Des Moines, IA 50391-2009. 2. Defendant, Andi H. Meloy is the mortgagor and real owner of premises 68 Oliver Road, Enola, PA 17025, 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 Graystone Mortgage on October 15, 2009, which mortgage was recorded on October 22, 2009 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instrument No. 200936042, secured on premises 68 Oliver Road, Enola, PA 17025 a true and correct description of which is attached hereto as Exhibit 1. 4. The mortgage has since been assigned to Nationwide Advantage Mortgage Company by written assignment dated June 29, 2012 and recorded on July 25, 2012 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instrument No. 201222164. 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 March 2014 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 $ 114,618.84 Interest from 2/1/2014 to 7/17/2014 at $16.49 per diem $ 2,771.08 Attorney's Fee $ 1,650.00 Pre-Acceleration Late Charges $ 292.12 Property Inspection Fee $ 366.00 Total $ 119,698.04 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$119,698.04, plus per diem interest at $16.49 from July 18, 2014 to the date of judgment plus costs thereon. MARTHA E. VON ROSENSTIE , P.C. B Martha E. Von Rosenstiel, Esquire Heather Riloff, Esquire Attorneys for Plaintiff VERIFICATION kQ� /a <C/ hereby states that he/she is the AS36c Q 4 V.Cr /�r�°.S��o%..� of Nationwide Advantage Mortgage Company,as authorized subservicer for Nationwide Advantage Mortgage Company,a corporation organized and existing under the laws of the United States of America,plaintiff herein;that he/she is duly authorized to make this Verification on behalf of Nationwide Advantage Mortgage Company and verifies that the statements made in the foregoing Complaint in Nationwide Advantage Mortgage Company v.Andi H. Meloy relating to the property located at 68 Oliver Road,Enola,PA 17025 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. �B • ar eel T le:Assoicate Vice President Nationwide Advantage Mortgage Company as servicer for Nationwide Advantage Mortgage Company Dated: J EXHIBIT I LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the building and improvements thereon erected situate in East Pennsboro Township,Cumberland County,State of Pennsylvania, and described according to Plan of Lots,Louis Park,made by D.P.Raffensperger,registered surveyor,on December 21, 1951 and recorded in the Office of the Recorder of Deeds,Carlisle, Penna. in Plan Book No. 5 Page 50,as follows,to wit: BEGINNING at a point on the northeast side of Oliver Road(fifty feet wide)at the distance of six hundred eighty-two and ninety-six one-hundredths feet measured along same south forty-six degrees no minutes east from its point of intersection with the southeast side of Louis Lane (north)(sixty feet wide). CONTAINING in front or breadth on the said Oliver Road sixty-four feet measured south forty- six degrees no minutes east from said beginning point and extending of that width in length or depth north forty-four degrees no minutes east between parallel lines at right angles to the said Oliver Road one hundred ten feet;being Lot No.68 on said Plan. UNDER AND SUBJECT to any and all covenants,conditions,reservations,restrictions, limitations,rights-of-ways,objections,easements,agreements,etc.,as they appear of record. PARCEL IDENTIFICATION NO: 09-13-1002-020.,CONTROL#: 09001511 EXHIBIT II �fG 7 V A L Natiornwide Advantage Mortgage Company T! n d f PO Box 9100 TamecWa,CA 92589-9100 PRESORT First-Class Map U.S.Postage and Fees Paid Send Payments to: 9314 71Q0 1]+70 Q737 5229 18 WSO Nationwide Advantage Mortgage Company PO Bax 740850 Cincinnati,OH 45274.0850 20140425-166 Send Correspondence to: I�1'11'irhillldl�rlIII-TIII 1�11 '11111.11�111111 P III 1116 Nationwide Advantage Mortgage Company PO Box 91900o ANDI H MELOY Des Moines,IA50391-9000 68 OLIVER RD ENOLA,PA 17025-2144 PA ACT91 Nationwide Advantage Mortgage' Seat Via Certified Mail 9314 7100 1170 0737 5229 16 (}4!2512014 ANDI H MELOY 68 OLIVER RD ENOLA,PA 17025-2144 Loan Number. Property Address: 68 OLIVER RD ENOLA,PA 17025 ACT 91 NOTICE TA]K.E ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official Notice that the mortgage on your home Is in default. and the lender Intends to foreclose Specific inrormation about the nature of the default is provided in the attached Pages The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save Your home. This Notice ex Iai s bort• the ro ram work- To s i! Ml ca you must MEET WITH A CONSUMFR C p T COUNSELING AGENCY WITHIN 13 D YS QF HE DATE OF THIS NOTICE. 'fake this Notice with you Ithen you meet with the Counseling Agency The namc,addrcss.and phane nUMba gifg_ • mer Crcdit Counsclin g A cncics scrayingyour Countyc fisted at the cnd of the Notice. if you have any questionsyoa may call the Pennsylvania IlousinR Finance Agency toil free at(800) 342-2397.MersonsAith 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 ADJU.NTO ES DE SUMA [,MMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EBF SU CASA. SI NO COMPRENDE FL CONTENIDO DE ESTA NOTIFICACIf3N OBTENGA UNA TRADUCC16N 1NMEDIATAMENTE LLA.MiANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SLY CARGOS AL NUMERO MiENC[ONADU ARRLBA. PUEDE SER ELF.GIBLE PARA UN PRF,STAMO POR EL PROGAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDEMIR SU HIPOTECA. Pn ACI91 Pad:i«r6 1314 7100 1170 0737 5221 16 HOMEOWNER'S NAIVIE(S): ANDI H MELOY PROPERTY ADDRESS: 68 OLIVER RD ENOLA,PA 17025 LOAN ACCT.NO.: 41�1111 ORIGLNAL LENDER: GRAYSTONE MORTGAGE CURRENT LENDER/SERVICER: Natloawide Advantage Mortgage Company HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1483(THE"ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: ._•..,_..IF-YOURDEFAULTIIAS_BEEN_CAUSED-By_CIRCU31STANCESBEYOND-YOUR_CONTROL,,_ _ • 1F YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS,AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act,you are entitled to a temporary stay of foreclosure on your mortgage for thirty(30)days from the date of this Notice(plus three:(3)days for mailing). During that time you must arrange and attend a"face-to-face"meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (331 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 CA LED "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 Noticc, 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 decionniM 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 accessary to schedule one face-to-face meeting. Advise your Icnder immediately ofyour intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set forth later in this Notice(sce following pages for specific information about the nature ofyour default). You have the right to apply for financial assistance from the homeowner's Emergency Mortgage Assistance Program. To do so,you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice, Only consumer credit counseling agencies have applications for the program,and they will assist you in submitting a complete application to die Pennsylvania Housing Finance Agency.To temporarily stop the lender from filing a foreclosure action,your application MUST be forwarded to PHFA and received within thirty(30)days ofyour Ihce-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMI4P APPLIC4 TIONASSOONAS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE.4N APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING THEN THE LENDER iVILL BE TEMPOR4RILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, .4S F PLAINER ABOVE,IN THE SECTION CALLED"TEAIP0R4RY STAY OF FORECLOSURE" YOU HAKE THE RIGHT TO FILE A HE1fAP APPLICATION EVEN BEYOND THESE TIAIE PERIODS. A LATE APPLIC 4TION WILL NOT PREVENT THE LEYDER FROAf STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVEATUALL 1'APPROVED AT ANY TWE BEFORE A SHERIFF'S SALE THE FORECLOSURE WILL BE STOPPED. AGENCY ACT104N-Available funds for emergency mortgage assistance are very limited. They will be disbursed by PA_ACT91 Pese2of6 9314 7100 1170 0737 5221 18 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 OFA PETITION UN 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 Assis(ance.) HOW TO CURE YOUR MORTGAGE DEFAULT(Bring It up to date.) NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your properly located at: 68 OLIVER RD ENOLA,PA 17025 1S-SERIOUSLY IN-DEFAULT-because:- - YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Next Payment Due Date: 0310112014 Total Monthly Payments Due: 51.864.00 (2 @0$932.00) Late Charges: $217.56 Other Charges: Uncollected NSF Fees: $0.00 Other Fees: $0.00 Corporate Advance Balance: $00) Attorney Fees: $0.00 Inspection Fees: $312.00 Unapplied Balance: 0.00 TOTAL AMOUNT PAST DUE: S2,393-556 HOW TO CURE THE DEFAULT-You may cure the default within TI ARTY(30)DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,393.56 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either by cash,cashier's check certified check or monev order made payablc and sent to: Standard Mail: Overnicht: Nationwide Advantage Mortgage Cotttpany Nationwide Advantage Mortgage Company P.O. Box 740850 1100 Locust St.,Dept.2009 Cincinnati,OH 45274-0850 Des Moines,1A 50391-2009 1F 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_I_ntends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments, If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Shcriff to pay ofFthe i mortgage debt. if the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you. you will still be required to pay the reasonable attorney's fce-s dint wire actually PA_M-191 Page.or6 1314 7100 1170 0737 5229 1& incurred, up to 550.00. However, if legal proceeding., are started against you, you will have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed 550.00: Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY(30)DAY tseriod,you will not be required to pav attornev's fees OTHER LENDER RF,NIEDIES-The leader may also site you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEI:AULT PRIOR TO SHERIFF'S SALE-if you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the richt to cure the default and prevent the-,ale at any time up to one hour before the Sheriffs Sale. You may do so by paving the total amount then ast due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale,and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by formic any other requirements under the morttga tc. Curing your default in the manner set forth in Ibis notice will restore your mortgage to the same position as it you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,the amount needed to cure the default ivilrincrcasc thi longer you wait.Y6u may find out at any time exactly what the required payment or action%will be by contacting the lender. HOW TO CONTACT THE LENDER. Name of Lender: Nationwide Advantage Mortgage Company Address: 1100 Locust Street,Dept.2009 Des Moines,IA 50391-2009 Phone Number: 800-356-3442 Fax Number: 866-262-3202 EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it, if you continue to live in the property after the Sheriff's Sale,a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You____ may or X may not(CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs arc paid prior to or at the sale and that other requirement,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 TI{E SAME POSITION AS 1F NO DEFAULT HAD OCCURRED,IF YOU CURE THE DEFAULT. (HOWEVER,YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE(3)TIMES IN ANY CALENDAR YEAR) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH AL71ON BY THE LENDER. PA_ACT91 Pop 4or6 9314 7100 1170 0737 5221 16 • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BELO TED ON THE ATTACHED LIST OF COUNSELLNG AGENCIES LOCATED IN THE STATE OF PENNSYVANIA In accordance with the Fair Debt Collection Practices Act,Title 15,U,S.0 1692(8),you may dispute the validity of this debt,or any portion thereof,if you do so in writing within thirty(30)days after the'reccipt of this notice.If you dispute the validity of this debt, or any portion thereof,within this thirty(30) days period we will provide you with written verification thereof;otherwise the debt will be assumed to be valid. Sincerely, Nationwide Advantage Mortgage Company 1100 Locust Street,Dept.2009 Des,Moines,IA 50391-2009 800-356-3442 FEDERAL LAW REQUIRES US TO ADVISE YOU THAT NATIONWIDE ADVANTAGE MORTGAGE COMPANY IS A DEBT COLLECTOR AND THAT TIIIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISC14ARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, T141S NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT INDEBTEDNESS AS YOUR PERSONAL OBLIGATION_ IF YOU ARE REPRESENTED BY AN ATTORNEY,PLEASE PROVIDE US WITH THE ATTORNEY'S NAME,ADDRESS AND TELEPHONE NUMBER, PA_,1C7v! Pest 5 'r6 9314 7100 1170 0737 5229 A HEMA' Consumer Credit Counseling Agencies CUMBERLAND County Report lost upkumk 1011&7013 10:43 AM Advantage Credit Counseling ServWCCCS of Western PA Community Action Commission or Capital Region 20001-inglestown Road 1514 Derry Stmt Harrisburg,PA 17102 Harrisburg,PA 17104 888-511.2227 717.232.9757 Hotsing Alliance or Yorh1Y Housing Resources Maranatho 290 West Market Street 43 Philadelphia Avenue York,PA 17401 Waynesboro,PA 17268 717-855.2752 717-762-3285 PathStone Corporation PathStone Corporation 1625 North Fnmt St 450 Cleveland Ave Harrisburg.PA 17102 Chambersburg.PA 1711! 717-234-6616 717-264-5913 PA Interfaith Community Programs Inc FHFA 40 E High Sued 211 North Front Siren Gettysburg,PA 17325 Harrisburg.PA 17110 717-334.1518 717-7110-3940 8110.342-2397 HC Pagc6of6 9314 7100 1170 0737 5229 18 i FORM 1 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF.COMMON PLEAS OF COMPANY CUMBERLAND COUNTY, 1100 Locust St., Dept. 2009 PENNSYLVANIA Des Moines, IA 50391-2009 Plaintiff VS. NO. ANDI H. MELOY `-) 68 Oliver Road -rs �► �"�{~ Enola, PA 17025 y�' _) F Defendant NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE 'Gy r, c_C,1 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 Mid Penn 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 MiclPenn 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 ork 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 T KE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respec lly submitted: August 21, 2014 Date gnature of Counsel for Plaintiff 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 r ^� Mailing Address(if different) City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: . #of people in household: How long? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How tong? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: _ Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy?Yes❑ No❑ If yes,provide names,.location of court,case number&attorney: 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 B• Monthly Gross Monthly Net Additional Income Description(not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses:(Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2° Mortgage Utilities Car Payment(s) Condo/Neigh.Fees Auto Insurance Med.(not covered) Auto fuel/repairs Other Prop. Payment Install. loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes M No M 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 R 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: AUTHORIZATION I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named_ Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed FORM 3 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY, 1100 Locust St., Dept. 2009 PENNSYLVANIA Des Moines, IA 50391-2009 Plaintiff vs. NO. ANDI H. MELOY 68 Oliver Road Enola, PA 17025 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 NATIONWIDE ADVANTAGE MORTGAGE IN THE COURT OF COMMON PLEAS OF COMPANY CUMBERLAND COUNTY, 1100 Locust St., Dept. 2009 PENNSYLVANIA Des Moines, IA 50391-2009 Plaintiff vs. NO. ANDI H. MELOY 68 Oliver Road Enola, PA 17025 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 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 �evniO~' rp 44, qFF1OaOFTHE mERTF THE oR0THONOTi�\ 2.6 OCT -\ NI �: 3- ",.^",. ` - CUMBERLAND COUNTY - pFNNSYAVAN\A, Nationwide Advantage Mortgage Company vs. Andi Meloy Case Number 2014-4981 SHERIFF'S RETURN OF SERVICE 09/08/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligentsearch and inquiry for the within named Defendant to wit: Andi Meloy, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 68 Olivier Road, East Pennsboro, Eno|a. PA 17025. Residence is vacant. 09/22/2014 07:50 PM - Deputy Dawn Kell, 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: Andi Meloy at 323 8th Street, No. 1, New Cumberland Borough, New Cumberland, PA 17070. cuArn DAWN KELL, DEPUTY SHERIFF COST: $6416 SO ANSWERS, September 23, 2014 RONNYRANDERSON, SHERIFF CountySuile Sheriff, Teleasoft, inc. MARTHA E. VON ROSENSTIEL, P.C. Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COMPANY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 Plaintiff vs. ANDI H. MELOY 68 Oliver Road Enola, PA 17025 Defendant f. r 0_CF E OF THE P ROTHONO IARY 20111 DEC -1 PM 2: 27 CUMBERLAND COUNTY PENNSYLVANIA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No. 14-4981 Civil PLAINTIFF'S MOTION TO REMOVE CASE FROM THE CUMBERLAND COUNTY RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM Plaintiff, Nationwide Advantage Mortgage Company by and through its undersigned counsel, Martha E. Von Rosenstiel, P.C., Heather Riloff, Esquire, hereby respectfully requests that this Honorable Court enter an Order granting its Motion to Remove Case from the Cumberland County Residential Mortgage Foreclosure Diversion Program, and in support thereof, avers as follows: 1. This matter has been assigned to the Honorable Kevin A. Hess, P.J. for matters concerning the Residential Mortgage Conciliation Program. 2. • This is a residential mortgage foreclosure action. 3. On or about September 22, 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 November 25, 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. To date, 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, Nationwide Advantage Mortgage Company, respectfully requests this case be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program. MARTHA E. VON ROSENSTIEL, P.C. BY: Dated: November 25, 2014 Heather Riloff, qu r e PA Attorney ID Attorney for Plaintiff 09906} 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 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: Date: November 25, 2014 Heather Riloff, Esq Attorney for Plaintif MARTHA E. VON ROSENSTIEL, P.C. Heather Riloff, Esquire / I.D. No. 309906 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE MORTGAGE COMPANY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 Plaintiff vs. ANDI H. MELOY 68 Oliver Road Enola, PA 17025 Defendant : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No. 14-4981 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: ANDI H. MELOY 68 Oliver Road Enola, PA 17025 And ANDI H. MELOY 323 8th Street, #1 New Cumberland, PA 17070 by regular first class mail, postage prepaid, deposited with the United States Postal Service on November 25, 2014 This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. BY: Dated: November 25, 2014 Heather Riloff, Esquir Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA NATIONWIDE ADVANTAGE MORTGAGE COMPANY 1100 Locust St., Dept. 2009 Des Moines, IA 50391-2009 Plaintiff vs. ANDI H. MELOY 68 Oliver Road Enola, PA 17025 Defendant : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : No. 14-4981 Civil ORDER OF COURT r -n C") 712. AND NOW, this I. day of )-1. , 2014, the Defendant 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: i4 .tizA f 44 fizaai Itispy #35007CFJ-DN TNN tHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONWIDE ADVANTAGE MORTGAGE COMPANY ANDI H. MELOY Plaintiff V. : NO. 14-4981 Civil Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: (XX) Enter judgment in favor of Plaintiff and against: Andi H. Meloy for want of an answer. (X) Assess Damages as Follows Debt Interest from 07/18/2014 to 12/30/14 At $16.49 per diem $ 119,698.04 00 $ 2,736.73 Total $ 122,434.77 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 file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his. attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P. 237.1 This day of MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Rose sti s, Esque Heather Riloff, Esqui Jeniece D. Davis, Esquire Attorneys for Plaintiff , 20l. judgment is entered in favor of the Plaintiff and against Defendant(s), Andi H. Meloy by default for want of,.an answer and damages assesseat the sum of $122,434.77 as per the above certification. I Prothonotary, Cumb \ Ak3153-1Sr 14A THA E. VON ROSENSTIEL, P.C. 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 Plaintif NATIONWIDE ADVANTAGE MORTGAGE COMPANY v. ANDI H. MELOY Plaintiff Defendant TO: Andi H. Meloy 68 Oliver Road Enola, PA 17025 #35007CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14-4981 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: 12/10/14 Martha E. Von Ro Heather Riloff, Es Attorneys for Plaintiff et Esquire #35007CFJ-DN h MARTHA E. VON ROSENSTIEL, P.C. 1Vlartjha 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 NATIONWIDE ADVANTAGE MORTGAGE : COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff vs. No: 14-4981 Civil ANDI H. MELOY Defendant(S) 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. Appx. Section 501 et seq. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MARTHA E. VON ROSENSTIEL, P.C. BY: Martha E. Von Ros Heather Riloff, Esq Jeniece D. Davis, Esquir Attorneys for Plaintiff , Esquire Dated: December 30, 2014 MARTHA E: VON ROSENSTIEL, P.C. 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 Plaintif NATIONWIDE ADVANTAGE MORTGAGE COMPANY` Plaintiff v. ANDI H. MELOY Defendant i #35007CTD - MB COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 14-4981 Civil TO: Andi H. Meloy 323 8th Street, #1 New Cumberland, -PA 17070 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 WITI-IOUT 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. Dated: 12/10/14 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 1.7013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, P.C. Martha E. V • i7. sen Heather Riloft,. • • Attorneys for Plaintiff tiel, Esquire re Andi H. Meloy 68 Oliver Road. Enola, PA17025 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. ANDI H. MELOY DEFENDANT(S) : NO: 14-4981 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 $122,434.77 on December 30, 2014, David D. Buell Prothonotary Judgment by Default • Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings If you have any questions concerning this notice, please call: Martha E. Von Rosenstiel, P.C. at this -telephone number:610-328-2887. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 David D. Buell, Prothonotary Andi H. Meloy 323 8th Street, #1 New Cumberland, PA 17070 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY PLAINTIFF VS. ANDI H. MELOY DEFENDANT(S) : NO: 14-4981 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 $122,434.77 on December 30, 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 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 NATIONWIDE ADVANTAGE MORTGAGE COMPANY ANDI H. MELOY v. 35007CWE-DN COURT OF COMMON PLEAS r; DOCKET NO. 14-4981 `CGivil ATTORNEY: I.D. #52634 ATTORNEY I.D. #309906 ATTORNEY I.D. # 2089677 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 12/31/2014 to 6/3/2015 At6% TOTAL* *Plus costs to be endorsed PREM: 68 Oliver Road, Enola, PA 17025 OJAI ��bp(e. Cap 1‘5.--)s It it j1c.som " akA $ 122,434.77 $ 3,120.15 $ 125,554.92 MARTHA E. VON ROSENSTIEL, P.C. BY: artha E. Von Ros Heather Riloff, Esqu Jeniece D. Davis, Esquire Attorneys for Plaintiff t_a.Q0),A., so �L, Da* 6)27 P_# bi,e4,67 • 4r' 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 NATIONWIDE ADVANTAGE MORTGAGE: COURT OF COMMON PLEAS COMPANY : CUMBERLAND COUNTY Plaintiff VS. : NO: 14-4981 CIVIL ANDI H. MELOY Defendant(s) LEGAL DESCRIPTION #35007 -DN • ALL THAT CERTAIN lot or piece of ground with the building and improvements thereon erected situate in East Pennsboro Township, Cumberland County, State of Pennsylvania, and described according to Plan of Lots, Louis Park, made by D. P. Raffensperger, registered surveyor, on December 21, 1951 and recorded in the Office of the Recorder of Deeds, Carlisle, Penna. in Plan Book No. 5 Page 50, as follows, to wit: BEGINNING at a point on the northeast side of Oliver Road (fifty feet wide) at the distance of six hundred eighty-two and ninety-six one -hundredths feet measured along same south forty-six degrees no minutes east from its point of intersection with the southeast side of Louis Lane (north) (sixty feet wide). CONTAINING in front or breadth on the said Oliver Road sixty-four feet measured south forty-six degrees no minutes east from said beginning point and extending of that width in length or depth north forty-four degrees no minutes east between parallel lines at right angles to the said Oliver Road one hundred ten feet; being Lot No. 68 on said Plan. UNDER AND SUBJECT to any and all covenants, conditions, reservations, restrictions, limitations, rights -of - ways, objections, easements, agreements, etc., as they appear of record. PARCEL. IDENTIFICATION NO: 09-13-1002-020., CONTROL #: 09001511 IMPROVEMENTS: Residential dwelling Tax Parcel # 09-13-1002-020 TITLE TO SAID PREMISES IS VESTED IN Andi H. Meloy, adult individual, by Deed from Kathy Dreese, fka Kathy Milliken and Sidney Dreese, her husband, dated 10/05/2009, recorded 10/22/2009 in Instrument Number 200936041. MART A,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 NATIONWIDE ADVANTAGE MORTGAGE:' COMPANY : CUMBERLAND COUNTY ' Plaintiff #35007CAM - DN COURT OF COMMON PLEAS VS. : NO: 14-4981 CIVIL ANDI H. MELOY Defendant(s) AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 4�ef �j: f _• _ (� cr. ZL15,i-,°° -8 P i I: I9 f'f ,i,'i, S YC_VA IA Y 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 68 Oliver Road, Enola, PA 17025: 1. Name and address of owners(s) or reputed owner(s) Andi H. Meloy 68 Oliver Road En'ola, PA 17025 2. Name and address of defendant(s) in the judgment Andi H. Meloy 68 Oliver Road Enola, PA 17025 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: LVNV Funding, LLC. 15 South Main Street Greenville, SC 29601 4. lame 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 u interest may be affected by the sale: Brian Meloy 6516 Fairfax Dr Harrisburg, PA 17111-6819 Brian Meloy c/o William M. Shreve, Esq PO Box 5292 Harrisburg, PA 17110 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/0 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 68 Oliver Road Enola, PA 17025 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. C.S. Section 4904 relating to unsworn falsification to authorities. BY: Dated: December 29, 2014 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Roser st'; 1, Esquire Heather Riloff, Esqu Jeniece D. Davis, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 i . , , • Heather Riloff, Esquire / No. 309906 = • j , Jeniece D. Davis, Esquire / No. 208967 649 South Avenue, Suite 7 2E15 J. P., 1: 19 Secane, PA 19018 L;r,;,J (610) 328-2887 Attorneys for Plaintiff Nationwide Advantage Mortgage Company : COURT OF COMMON PLEAS 1100 Locust St., Dept. 2009 : CUMBERLANDCOUNTY Des Moines IA 50391-2009 Plaintiff vs. Andi H. Meloy : No: 14-4981 Civil 68 Oliver Road Enola, PA 17025 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: Andi H. Meloy 68 Oliver Road Enola, PA 17025 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. C.S. Section 4904 relating to unsworn falsification to authorities. BY: MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rose Heather Riloff, Esqui Jeniece D. Davis, Esquire Attorneys for Plaintiff {' {H MARTHA E. VON ROSENSTIEL, P:C. Martha E. Von Rosenstiel, Esquire / N'o M6348 Fe's I: 19 Heather Riloff, Esquire / No. 309906 0� lr_F4 A:z) C,JlTY Jeniece D. Davis, Esquire / No. 208967 ; E; 1 Y'LV[ IA 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff NATIONWIDE ADVANTAGE : COURT OF COMMON PLEAS MORTGAGE COMPANY : CUMBERLAND COUNTY Plaintiff vs. : No: 14-4981 Civil ANDI H. MELOY Defendant(s) 35007CAM-DN 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 68 Oliver Road Enola, PA 17025 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. 14-4981 Civil in the Court of Common Pleas of Cumberland County by Nationwide Advantage Mortgage Company, Plaintiff against Andi H. Meloy, Defendant(s). Judgment was entered on December 30, 2014 in the amount of $122,434.77. The property was seized and taken in execution as the property of Andi H. Meloy. The property to be sold at Sheriff's Sale is described as follows: ALL THAT CERTAIN lot or piece of ground with the building and improvements thereon erected situate in East Pennsboro Township, Cumberland County, State of Pennsylvania, and described according to Plan of Lots, Louis Park, made by D. P. Raffensperger,registered surveyor, on December 21, 1951 and recorded in the Office of the Recorder of Deeds, Carlisle, Penna. in Plan Book No. 5 Page 50, as follows, to wit: BEGINNING at a point on the northeast side of Oliver Road (fifty feet wide) at the distance of six hundred eighty-two and ninety-six one -hundredths feet measured along same south forty-six degrees no minutes east from its point of intersection with the southeast side of Louis Lane (north) (sixty feet wide). CONTAINING in front or breadth on the said Oliver Road sixty-four feet measured south forty- six degrees no minutes east from said beginning point and extending of that width in length or depth north forty-four degrees no minutes east between parallel lines at right angles to the said Oliver Road one hundred ten feet; being Lot No. 68 on said Plan. UNDER AND SUBJECT to any and all covenants, conditions, reservations, restrictions, limitations, rights -of -ways, objections, easements, agreements, etc., as they appear of record. PARCEL IDENTIFICATION NO: 09-13-1002-020., CONTROL #: 09001511 Tax ID #09-13-1002-020 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. 14-4981 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 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 NATIONWIDE ADVANTAGE MORTGAGE COMPANY Vs. ANDI H. MELOY WRIT OF EXECUTION NO 14-4981 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $122,434.77 L.L.: $.50 Interest FROM 12/31/2014 TO 6/3/2015 AT 6% - $3,120.15 Atty's Comm: Atty Paid: $224.91 Plaintiff Paid: Date: 1/8/15 (Seal) Due Prothy: $2.25 Other Costs: Davi 11, Prothonotary By: Deputy REQUESTING PARTY: Name: HEATHER RILOFF, ESQUIRE Address: MARTHA E. VON ROSENSTIEL, P.C. 649 SOUTH AVENUE, UNIT #6 SECANE, PA 19018 Attorney for: PLAINTIFF Telephone: 610-328-2887 Supreme Court ID No. 52634