HomeMy WebLinkAbout14-5680 Supreme Court of Pennsylvania
Court of Common Pleas ForProthonotan-UseOnkj%
Civil Cover Sheet Docket No: nn
Cumberland County I -5(o�D lavi�Terrh
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling and service ofpleadiW or other a vers 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 Taking
Lead Plaintiff's Name:FEDERAL NATIONAL Lead Defendant's Natne: PATRICK J.NEAL AND LISA M.
T MORTGAGE ASSOCIATION("FANNIE MAE") NEAL
I
O
N
Are money damages requested? : ❑Yes X No Dollar Amount Requested: within arbitration limits
A Check one) outside arbitration limits
Is this a ClassAction Suit? ❑❑ Yes ❑X No . Is this an MDJA eal? ❑ Yes ❑X No
Name of Plaintiff/Appellant's Attorney: Martha Von Rosenstiel,Esq.
o Check here if you are a Self-Represented Pro Se Litigant
Nature of the Case: Place an"X" to theleft of the ONE case category that most accurately describes vour
PRIAfARY CASE. If you are making snore than one type of claim.check the one that
you consider most important.
TORT(do no;includeMoss Tort) CONTRACT(do not include judgments) CIVIL APPEALS
El Intentional 0 Buyer Plaintiff Administrative Agencies
0 Malicious Prosecution 0 Debt.Collection:Credit Card 0 Board of Assessment
Q Motor Vehicle 0 Debt Collection:Other Q Board of Elections
Nuisance 0 Dept.of Transportation
0 Premises Liability 0 Statutory Appeal:Other
5 Q Product Liability(does not incluale 0 Employuuent Dispute:
ass t077)E »m
0 Employment Discrimination
C El Other: � ent Dispute:Other 0 Zoning Board
o other:
T
I ❑Other:
O AIASS TORT
0 Asbestos
N 0 Tobacco
0 Toric Tort-DES
(] Toxic Tort-Implant REAL.PROPERTY N'IISCELLANEOUS
Q
Toxic Waste
Q Other: [:1EJecnnent (]Connnon Lauv,'Statuton Arbitration
B 0 Eminent Domain'Coudernnntion 0 Declaratory Judgment
0 Ground Rent. Mandamus
0 Landlord/Tenant.Dispute B Non-Domestic Relations
Q Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial 0 Quo Warranto
0 Dental 0 Partition 0 Replevin
0 Legal 0 Quiet Title 0 other
Q Medical 0 Other:
Other Professional:
L'pdntrd 1/11'011
FORM 1
FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF
•A,SOCIATION ("FANNIE MAE") CUMBERLAND COUNTY,
3900 Wisconsin Avenue, NW PENNSYLVANIA
Washington, DC 20016-2892
Plaintiff n
vs. No.
PATRICK J. NEAL AND LISA M. NEAL
82 Keefer Way
Mechanicsburg, PA 17055
Defendants
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer you must take the following steps to be eligible for a
conciliation conference. First,within twenty(20) days of your receipt of this notice, you must contact MidPenn legal
Services at(717)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 attempt to work out
reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
September 11, 2014 Ckxs� Q
Date Signature of Counsel or 1 intiff
• 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:
CUSTOMERIPRIMARY
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?
CO-BORROWER
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people in household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount:$ Included Taxes 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 payin&)
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/Tuit. 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 F-] No ❑
If yes,please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
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
1/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. 1/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.
PATRICK J. NEAL AND LISA M. NEAL
82 Keefer Way
Mechanicsburg, PA 17055
Defendants
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.
PATRICK J. NEAL AND LISA M. NEAL
82 Keefer Way
Mechanicsburg, PA 17055
Defendants
CASE MANAGEMENT ORDER
AND NOW,this day of , 20 the defendant/borrower in
the above-captioned residential mortgage foreclosure action having filed a Request for
Conciliation Conference verifying that the defendant/borrower has complied with the
Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby
ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on at M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made maybe 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.
S. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
J.
MARTHA E. VON ROSENSTIEL, P.C. ;;`i!; ", ;� €air 1 f; 4 4 35346CFC-AB
Martha E. Von Rosenstiel, Esquire/No. 52634
Heather Riloff, Esquire/No. 309906 S'UM ERL/k1I'D C'vfuN'T Y
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. 51080 3\o-Te-rm
PATRICK J. NEAL AND LISA M. NEAL
82 Keefer Way
Mechanicsburg, PA 17055
Defendants
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 la cone. 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 youpersona o con un abogado y entregar a la torte 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 cone 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,]a torte 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
S
CARLISLE, PA 17013
717-249-3166 115,r7-6 Pn AATIH
800-990-9108 e406P5(aU
R,*31151®
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. 35346CFC-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.
PATRICK J. NEAL AND LISA M. NEAL
82 Keefer Way
Mechanicsburg, PA 17055
Defendants
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. Defendants, Patrick J. Neal and Lisa M. Neal are the mortgagors and real owners of
premises 82 Keefer Way, Mechanicsburg, PA 17055, hereinafter described, whose last known
address is listed in the caption.
3. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and
real owners, to foreclose a certain indenture of mortgage made, executed and delivered by the
above named defendants, mortgagors and real owners to Mortgage Electronic Registration, Inc.
as nominee for Countrywide Home Loans, Inc. on July 28, 2004, which mortgage was recorded
on July 30, 2004 in the Office of the Recorder of Deeds of Cumberland County in Mortgage .
Book No. 1875, Page 2585, secured on premises 82 Keefer Way, Mechanicsburg, PA 17055 a
true and correct description of which is attached hereto as Exhibit I.
4. The mortgage was then assigned to BAC Home Loans Servicing, LP, flea, Countrywide
Home Loans Servicing, LP by written assignment dated September 1, 2010 and recorded on
September 20, 2010 in the Office of the Recorder of Deeds of Cumberland County in Mortgage
Instrument No. 201026172.
5. . The mortgage has since been assigned to Federal National Mortgage Association by
written assignment dated December 5, 2012 and recorded on December 31, 2012 in the Office of
the Recorder of Deeds of Cumberland County in Mortgage Instrument No. 201240742.
6. Plaintiff alleges each and every term, condition and covenant in the aforesaid
mortgage, and hereby incorporates them herein by reference thereto.
7. 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.
8. 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.
9. The following is an itemized statement of the amount due plaintiff under the terms of
the aforesaid mortgage:
Principal Balance $ 102,887.24
Interest from 2/1/2014 to 8/29/2014
at $7.75 per diem $ 1,402.75
Accrued Escrow deficit $ 3,508.96
Attorney's Fee $ 2,350.00
Property Inspections $ 165.00
Suspense $ ( 40.02 ) .
Total $ 110,273.93
10. Plaintiff sent to obligated defendants, mortgagors and real owners 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 Il).
WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged
premises in the amount of$110,273.93,plus per diem interest at $7.75 from August 30, 2014 to
the date of judgment plus costs thereon.
MARTHA E. VON ROSENSTIEL, P.C.
BY: 0
Martha E. Von o nos, Esquire
Heather Riloff, Esquire
Attorneys for Plaintiff
VERIFICATION
Jeannette',. Cao hereby states that he/she is the
Fereclosur�pecialist 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. Patrick J. Neal and Lisa M.Neal relating to the property located at 82 Keefer
Way, Mechanicsburg, PA 17055 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: Jeannette L. Cao
Title: Foreclosure 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 PIECE OR PARCEL of ground situate in Upper Allen Township,
Cumberland'County, Pennsylvania, being Lot No. 86 as shown on a Plan entitled 'Phase II,'
Bowman's Village, more properly known as Bowman's Village, Upper Allen Township,
Cumberland County, Pennsylvania' recorded December 14, 2000 in Plan Book 82, Page 63 and
re-recorded on January 3, 2001 in Plan Book 82, Page 85,prepared by Dawood Engineering, Inc.
more particularly bounded and described as follows:
BEGINNING at a 5/8 inch rebar to be set, said rebar being on the dividing line between
Lot No. 86 and Lot No. 87 where said line intersects with the southern right-of-way line of
Keefer Way (50 feet right-of-way); thence along Lot No. 87 South 46 degrees 27 minutes 15
seconds East, a distance of 110.00 feet to an 5/8 inch rebar to be set at the common corner of Lot
No. 54, Lot No. 55,Lot No. 86 and Lot No. 87; thence along Lot No. 55, South 43 degrees 32
minutes 45 seconds West, a distance of 37.00 feet to an 5/8 inch rebar to be set at the common
corner of Lot No. 55, Lot No. 56, Lot No. 85 and Lot No. 86; thence along Lot No. 85,North 46
degrees 27 minutes 15 seconds West, a distance of 110.00 feet to an 5/8 inch rebar to be set on
the southern right-of-way line of Keefer Way; thence along the southern right-of-way of Keefer
Way, North 43 degrees 32 minutes 45 seconds East, a distance of 37.00 feet to an 5/8 inch rebar
to be set on the lot line of Lot No. 85 and Lot No. 86, THE POINT OF BEGINNING.
CONTAINING 4,070 square feet, more or less.
UNDER AND SUBJECT to a 10 feet access easement along the western side of the lot
and to all covenants and agreements of record.
ALSO UNDER AND SUBJECT to Declaration of Protective Covenants, Restrictions and
Conditions as set forth in Miscellaneous Book 664, Page 882.
HAVING THEREON erected a two-story townhouse known as 82 Keefer Way,
Mechanicsburg, Pennsylvania 17055.
PARCEL IDENTIFICATION NO: 42-29-2456-202, CONTROL#: 00502544
EXHIBIT II
Seterus TM 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
NEAL,-PATRICK J 866.578.5277
82 KEEFER WAY Website
MECHANICSBURG,PA 17055 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. l,at^e I 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 IlVIPORTANCIA,PLIES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA.(PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.PUEDE SER
ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO"HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDEMM SU HIPOTECA.
Pa<(e?of 6
HOMEOWNER'S NAME(S): NEAL,PATRICK 3
NEAL,LISA M
PROPERTY ADDRESS: 82 KEEFER WAY
LOAN ACCT.NO.: MECHANICSBURG,PA 17055-9256
ORIGINAL LENDER: COUNTRYWIDE HOME LOANS,
INC.
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 agencies
for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one
face-to-face meeting. Advise your lender/servicer immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this
Notice(see following pages for specific information about the nature of your default). You have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so,you must fill out, sign,
and file a completed Homeowner's Emergency 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 (Brine it up-to-date)
NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender/servicer on your property located at:
82 KEEFER WAY
MECHANICSBURG, PA 17055-9256
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$913.22 each
Total: $2,739.66
Past Due Installments: $2,739.66
Other Open Charges: Prior Servicer Charges Seterus,Inc. Charges
Late Charges 0.00 27.70 27.70
Property Inspections 0.00 45.00 45.00
Speedpay Charges 0.00 5.00 5.00
Total Past Due Installments& Charges $2,817.36
Less Suspense(Balance) 20.00
TOTAL AMOUNT PAST DUE $2,797.36
Paye 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 $2,797.36, 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 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 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 paving 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 Sheriff s 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 Person(s): Shannon Stock or Nathan Wetzel
E-Mail Address: ExternalCommunications@seterus.com
EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff s Sale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongings could be started by the lender/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
setePhysical rus
Address
14523 SW Millikan Way;Suite 200;Beaverton,OR 97005
na
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
L178R
NEAL,LISA M Fax
82 KEEFER WAY 866.578.5277
MECHANICSBURG,PA 17055 Website
www.seterus.com
Loan number:mm, 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 offices 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.
Page l 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 NOTIFICACI6N EN ADJUNTO ES DE SUMA I PORTANCIA,PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION
OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.PUEDE SER
ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM"EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIIVIIR SU HIPOTECA.
Page 2 of 6
HOMEOWNER'S NAME(S): NEAL,LISA M
PROPERTY ADDRESS: 82 KEEFER WAY
MECHANICSBURG,PA 17055-9256
LOAN ACCT.NO.:
ORIGINAL LENDER: COUNTRYWIDE HOME LOANS,
INC.
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_agencies
for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one
face-to-face meeting. Advise your lender/servicer immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE --Your mortgage is in default for the reasons set forth later in this
Notice(see following pages for specific information about the nature of your default). You have the right to apply for
financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so,you must fill out, sign,
and file a completed Homeowner's Emergency 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."
Pa-,e 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:
82 KEEFER WAY
MECHANICSBURG, PA 17055-9256
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$913.22 each
Total: $2,739.66
Past Due Installments: $2,739.66
Other Open Charges: Prior Servicer Charges Seterus,Inc. Charges
Late Charges 0.00 27.70 27.70
Property Inspections 0.00 45.00 45.00
Speedpay Charges 0.00 5.00 5.00
Total Past Due Installments&Charges $2,817.36
Less Suspense(Balance) 20.00
TOTAL AMOUNT PAST DUE $2,797.36
Pa(-Ye 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 $2,797.36, 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 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 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 reguirements 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 Person(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 Sheriffs 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
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
RonnyRAnderson FILED -OFFICE
Sheriff THE PRO H JNO A
L�If819[-
Jody S Smith
Chief Deputy . 21114 OCT 13 . AM 10: 08
Richard W Stewart �+ " CUMBERLAND COUNTY
Solicitor THF. $r=RIFF PENNSYLVANIA
Federal National Mortgage Association
vs.
Patrick J. Neal (et al.)
Case Number
2014-5680
SHERIFF'S RETURN OF SERVICE
10/07/2014 07:23 PM - Deputy Noah Cline, 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: Lisa M.
Neal at 82 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055.
NOAH CLINE, DEPUTY
10/07/2014 07:23 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Lisa M. Neal, wife, who accepted as "Adult Person
in Charge" for Patrick J. Neal at 82 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055.
NOAH CLINE, DEPUTY
SHERIFF COST: $55.30 SO ANSWERS,
October 08, 2014
(c) CcuntySuite Sheriff, Teleosoft, Inc.
RONNY R ANDERSON, SHERIFF