The URL can be used to link to this page

Home My WebLink About14-6159 Supreme Court of Pennsylvania Cout €ifommu Pleas For Prothonotarr Use Onh'. ilCOt a Sheet Cuml beriand r / Count`- Docket No: The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace thefiling and service o leadin s or other papers as required by law or rules of court. Commencement of Action: X Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: C M&T BANK ELIZABETH A,YOUELLS T I Dollar Amount Requested within arbitration limits O Are money Damages requested?: ❑ Yes ® No (Check one) X outside arbitration limits 1 Is this a Class Action Suit? ❑ Yes ® NO' Is this an MDJ Appeal? ❑ Yes ® NO Name of Plaintifflappellant's Attorney:KML Law Group,P.C. ❑ Check here if you are a Self-Represented(Pro Se Litigant Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include ❑ Statutory Appeal: Other E mass tort) ❑ Employment dispute: C Slander/Libel Defamation Discrimination ❑ Other ❑ Employment Dispute:Other T ❑ Other: 0 MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration B ❑ Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus N Mortgage Foreclosure:Residential ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.R.C.P. 205.5 Updated 1/1/2011 KML LAW GROUP,P.C. - ` =1 SUITE 5000—BNY MELLON INDEPENDENCE CEN Eli 701 MARKET STREET PHILADELPHIA,PA 19106 ' r (866)413-2311 i;, ;=:%;, I�4 THE COURT OF COMMON PLEAS /A M&T BANK c. t t=_ z . . One Fountain Plaza OF Cumberland COUNTY Buffalo,NY 14203 Plaintiff CIVIL ACTION-LAW vs. ELIZABETH A.YOUELLS ACTION OF MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) CIVIL ACTION: MORT'GA& 1705 Cornell Road Camp Hill,PA 17011 V l Defendant(s) q` NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served,by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other.rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes,usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos important es para usted.ex S' 4llS. 7Sz) � L` 77 -)O�) 1 LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. S1 NO TIENE ABOGADO SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO VAYA N PERSONA O POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you,you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney.For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default.Please See the PHFA website http://www.,Vhfa.org/consumers/homeowners/real.asp—x. 5). Call the Plaintiff(your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionga kmllawgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.Please reference our Attorney File Number of 13665517C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M&T BANK, One Fountain Plaza,Buffalo,NY 14203. 2. The name(s) and address(es) of the Defendant(s) is/are ELIZABETH A. YOUELLS, 1705 Cornell Road, Camp Hill, PA 17011,who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On July 03, 2013 mortgagor(s)made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,ACTING SOLELY AS NOMINEE FOR MERIDIAN BANK,which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on July 10, 2013 as Instrument#201322781. An Assignment of Mortgage was executed September 4, 2014. A true and correct copy of the executed Assignment of Mortgage is attached hereto as Exhibit"C". The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g);which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property") 5. The mortgage is in default because the monthly payments are due and unpaid for May 01, 2014 and each month thereafter and by the terms of the Mortgage,upon default in such payments for a period of one month or more,the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: PrincipalBalance..................................................................................$130,858.55 Interest from 04/01/2014 through 11/01/2014 at 3.5000%................... ..$2,671.69 Monthly interest rate at$381.67 Late Charges $234.18 .............................................................................................. Escrow/Impound Overdraft ......................................................................$1,358.05 ProRata MIP................................................................................................$428.88 Property Inspections............................. .$56.00 Reasonable Attorney's Fee .................................................................................................... .......$1,650.00 $137,257.35 7. If the Mortgage is reinstated prior to a Sheriff's Sale,the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further,Plaintiff will request recovery of all costs incurred in this action including,but not limited to, costs of suit,process serving and skip tracing,title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an"in personam"judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding,this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy,but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Plaintiff sent Defendants the notice as required by 35 P.S. Section 1680.401 et. seq. (Act 91 of 1983) or by 41 P.S. Section 403 (Act 6 of 1974) or as required by the Mortgage ("Notice"). A true and correct copy of the Notice is attached and incorporated as Exhibit`B". WHEREFORE,Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$137,257.35, together with interest at the rate of$381.67,per month and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. r By: AAAAWP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa. ID'26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa.ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa.ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff i VERIFICATION I I, Jason sittniewski , as the representativeof the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the it understand that false statements therein are made subject to the best of my information and belief.I penalties of 18 Pa. C.S. Sec.4904 relating to unsworn falsification to authorities. Date: L 4jasosittniewski, vice President i #136655FC-ELIZABETH A.YOUELLS 1705 Cornell Road Camp Hill,PA 17011 i i EythibitA ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by William .I B.Whittock, Professional Engineer, dated June 4, 1962, as follows: BEGINNING at a point on the southern side of Cornell Road, fifty-seven and forty-two hunraong (57.42) feet west of the southwest corner of Chs ornell Road and Seventeenth Street; ; Cornell Road, South eighty-four (84) degrees fifty-seven (57) minutes West, fifty-five (55) feet to a fter point; thence along a line parallel with the westernnutes East one hundred ne of Lot No. 33 as 1tn on t twenty (120) feet he to a mentioned Plan, South five (05) degrees three (03) point: thence along Lots Nos. 26 and 25 on said Plan, North eighty-four (84) degrees fifty-seven (57) minutes East, fifty-five (55) feet to a point; thence along a line parallel with the western line of Lot No. ; 34, North five (05) degrees three (03) minutes West, one hundred twenty (120) feet to the place of BEGINNING. BEING the major part of Lot No. 33 and the eastern two feet of Lot No. 32 as shown on a Plan of Lots laid out in the Recorder's Office of Cumberland County in Plan Book 7, Page 21, . I i . I Eyhibit (B *Exhibit has been redacted to remove all personally identifiable information or non- public information M&T Banik REPRES USPS CERTIFIED MAIL P.O.Box 840 Buffalo,NY 14240 9207 1969 0043 7100 0217 238102 5-750-81336-0000105-001-01-000-000-000-000 ELIZABETH A YOUELLS 1705 CORNELL RD CAMP HILL PA 17011 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT July 3, 2014 ELIZABETH A YOUELLS 1705 CORNELL RD CAMP HILL PA 17011 Re: Mortgage No.: _8834 Property Address: 1705 CORNELL ROAD CAMP HILL PA 17011 ACT 6 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear Mortgagor Customer(s): If you are in bankruptcy or received a bankruptcy discharge of this debt,this communication is not an attempt to collect the debt against you personally, but is notice of a possible enforcement of the lien against the collateral property. The mortgage held by M&T Bank on your property located at 1705 CORNELL ROAD CAMP HILL PA 17011 IS IN SERIOUS DEFAULT because you have not made the monthly payments for the months of 05/01/2014 through today. Late charges and other charges have also accrued to this date in the amount of$131.09. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is$3,058.49. You may cure this default within THIRTY(30) DAYS of the date of this letter, by paying to us the above amount of$3,058.49 plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at M&T Bank, One Fountain Plaza, 7th Floor, ATTN: Payment Processing, Buffalo, NY 14203. If you do not cure this default within THIRTY(30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY(30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees, actually incurred, up to$50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over$50.00.Any attorney's fees will be added to whatever you owe us,which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale.You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately 10 months from the date of this notice.A notice of the date of the Sheriff 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 will be by calling us at the following number: 1-800-724-1633. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU 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. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID FOR PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. If you have any questions regarding this letter, please feel free to contact our office at 1-800-724-1633. Sincerely, M&T Bank Homeowner Assistance Center 1-800-724-1633 XD537 M&T Bank is attempting to collect a debt and any information obtained will be used for that purpose. If you are in bankruptcy or received a bankruptcy discharge of this debt, this communication is not an attempt to collect the debt against you personally, but is notice of a possible enforcement of the lien against the collateral property. INTERNET REPRINT i Eyt h VVV\j *Exhibit has been redacted to remove all personally identifiable information or non-public information i When Recorded Return To: M&T BANK ATTN:ASSIGNMENT GROUP PO BOX 1288 BUFFALO, NY 14240 Parcel No.01-20-1854-229 I CORPORATE ASSIGNMENT OF MORTGAGE Cumberland, Pennsylvania SELLER'S SERVICING# 834 "YOUELLS" SELLER'S LENDER ID#: MIN#: SIS M Date of Assignment: September 4th, 2014 Assignor: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ("MERS")AS NOMINEE FOR MERIDIAN BANK,A PENNSYLVANIA CHARTERED BANK ITS SUCCESSORS AND ASSIGNS Assignee: M&T BANK I hereby certify the precise address of the within named Assignor is 1901 E VOORHEES STREET, j SUITE C, DANVILLE, IL 61834. I hereby certify the precise address of the within named Assignee is 1 FOUNTAIN PLAZA, BUFFALO, ! NY 14203. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC is at 1901 E Voorhees Street, Suite C, Danville, IL 61834, P.O. BOX 2026, FLINT, MI 48501-2026 i Executed By: ELIZABETH A YOUELLS,A SINGLE WOMAN To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ("MERS")AS NOMINEE FOR MERIDIAN BANK, A PENNSYLVANIA CHARTERED BANK ITS SUCCESSORS AND ASSIGNS Date of Mortgage: 07/03/2013 Recorded: 07/10/2013 in Book/Reel/Liber: N/A Page/Folio: N/A as Instrument/Document: 201322781 In the County of Cumberland, State of Pennsylvania. 1705 CORNELL ROAD, CAMP HILL, PA 17011 in the Borough of CAMP HILL I do certify that he precise address of M&T ANK is 1 FOUNTAIN PLAZA, BUFFALO, NY 14203 Attested By: qS KNOW ALL MEN BY THESE PRESENTS, that for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the said Assignor hereby assigns unto the above-named Assignee, the said Mortgage having an original principal sum of$133,055.00 with interest, secured thereby,and the full benefit of all the powers and of all the covenants and provisos therein contained, and the said assignor hereby grants and conveys unto the said assignee, the assignor's interest under the Security Instrument. CORPORATE ASSIGNMENT OF MORTGAGE Page 2 of 2 TO HAVE AND TO HOLD the said Security Instrument, and the said property unto the said assignee forever, subject to the terms contained in said Security Instrument. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ("MERS")AS NOMINEE FOR I MERIDIAN BANK, A PENNSYLVANIA CHARTERED BANK ITS SUCCESSORS AND ASSIGNS On September 4th. 2014 i By: j Jos4hiktman,Assistant Secretary STATE OF New York COUNTY OF Erie On the 4th day of September in the year 2014 before me, the undersigned Notary Public in and for said State, personally appeared Joshua Wikman,Assistant Secretary of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ("MERS")AS NOMINEE FOR MERIDIAN BANK,A PENNSYLVANIA CHARTERED BANK ITS SUCCESSORS AND ASSIGNS, personally known to me or proved to me on the basis of satisfactory evidence to be the individual(s)whose name(s) is(are) subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their capacity(ies), and that by his/her/their signature(s)on the instrument the individual(s), or the person upon behalf of which the individual(s)acted, executed the instrument. WITNESS my hand and official seal, Bess E.Katerinsky C r Notary Public State of New York C Qualified in Erie County BESS E. KATERINSKY 7 Reg f101KA8199215 j Notary Expires: 01/12/2017 My Commission Expires 1/12/2017 Qualified in Erie County (This area for notarial seal) i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson t; LLLFOF I C E Sheriff 'R O • n � i �� Jody S Smith Chief Deputy Richard W Stewart Solicitor r r ;; F Tkri. $h'gRIFs~ ZOltiNOV26 Ail11:22 CUMBERLAND COUNT`( PE NSYLYAHLA M&T Bank vs. Elizabeth A Youells Case Number 2014-6159 SHERIFF'S RETURN OF SERVICE 11/21/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Elizabeth A Youells, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Served" at 1705 Cornell Road, Camp Hill Borough, Camp Hill, PA 17011. Nine attempts at service were made but deupties were unable to make contact with anyone to effectuate service before the Complaint expired. SHERIFF COST: $78.85 SO ANSWERS, November 21, 2014 ROW/ R ANDERSON, SHERIFF (c) Countyi,uite hentr, re soft Inc. KML Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF M&T BANK One Fountain Plaza Buffalo, NY 14203 vs. ELIZABETH A YOUELLS 1705 Cornell Road Camp Hill, PA 17011 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter, Term No. 14-6159 By: (A 2b4d . . KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 ‘i ranci 1.-ynn Como( 318389 Attorneys for Plaintiff wk.\ s0--Ispid i .-2-4-3 I soaPi