HomeMy WebLinkAbout14-6355 A
Supreme Court-of Pennsylvania
��,�
Couft,! Com tiEn Pleas
r f `` V: t' ForProthonotart'Use 0n,11%
Gi�� Cot°er,S'heet
Cu#iberland County Docker No- 5�
The information collected'on thisform is used solei or
f f solelyfor court administration purposes. This form does not
Supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
® Complaint ❑ Writ of Summons ❑ Petition
S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiff Name: Lead
Defendant's
I fe NGUYName:
N e:
C PENNYMAC LOAN SERVICES,LLC
THUNAM NGUYEN
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
A Name of Plaintiff/appellant'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
5 ❑ Premises Liability ❑ Zoning Board
❑ Product Liability(does not include ❑ Statutory Appeal: Other
� mass tort) ❑ Employment dispute:
❑ Slander/Libel Defamation Discrimination
❑ Other ❑ Employment Dispute:Other
T ❑ Other:
I
0 MASS TORT ❑ Other
N ❑ Asbestos
❑ Tobacco
❑ Toxic Tort-DES REALTROPERTY MISCELLANEOUS
❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory
❑ Toxic Waste
❑ Other ❑ Eminent Domain/Condemnation Arbitration
❑ Ground Rent ❑ Declaratory Judgment
❑ Landlord/Tenant Dispute ❑ Mandamus
® 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.RC.P. 205.5 Updated 1/1/2011
KML LAW GROUP,P.C.
SUITE 5000—BNY MELLON INDEPENDENCE CENTEItt,_ !f�'.t'.?-�'c_:;-7-�j�'4__
701 MARKET STREET
PHILADELPHIA,PA 19106 +' `
(866)413-2311 L ,
'f r 1: 39
1yWW.KMLLA WGROITP.COM
PENNYMAC LOAN SERVICES,LLC �.•';� z ,�; ��; r f it THE COURT OF COMMON PLEAS
6101 Condor Drive �, tt )
� 9_6' h`e i• 1a�„
Suite 200 OF Cumberland COUNTY
Moorpark, CA 93021
Plaintiff CIVIL ACTION-LAW
vs.
JESSICA NGUYEN ACTION OF MORTGAGE FORECLOSURE
THUNAM NGUYEN 1
Mortgagor(s)and Record Owner(s) 1 �3ss v
4312 Park Street CIVIL ANON: MORTGAGI
Camp Hill,PA 17011 •
Defendant(s) FMECLOSM
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 importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O
SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME
POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA X11
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.phfa.org/consumers/homeowners/real.gVx.
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 homeretention@.. llawgroup.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 13272517C.
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 PENNYMAC LOAN SERVICES, LLC, 6101 Condor Drive, Suite 200 Moorpark, CA
93021.
2. The name(s)and address(es) of the Defendant(s) is/are JESSICA NGUYEN, 4312 Park Street, Camp
Hill, PA 17011 and THUNAM NGUYEN, 4312 Park Street, Camp Hill, PA 17011,who is/are the
mortgagor(s) and record owner(s)of the mortgaged premises hereinafter described.
3. On May 30, 2012 mortgagor(s)made,executed and delivered a mortgage upon the Property hereinafter
described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR
VANGUARD FUNDING,LLC,which mortgage is recorded in the Office of the Recorder of Deeds of
Cumberland County on June 07,2012 as Instrument#: 201216920. The mortgage has been assigned to:
PENNYMAC LOAN SERVICES, LLC by assignment of Mortgage recorded on August 27, 2014 as
Instrument#201419196. The Mortgage and Assignment(s) (if any) are matters of public record and are
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 of principal and interest are due and unpaid
for April 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:
Principal Balance..................................................................................$155,510.22
Interest from 03/01/2014 through 09/01/2014 at 3.7500%.......................$2,915.82
Per Diem interest rate at$16.20
LateCharges................................................................................................$115.35
Escrow........................................................................................................$1,954.25
NSFCharges..................................................................................................$50.00
Fees. ...............__. .....$52.00
..................
Recoverable Balance.....................................................................................$368.50
Reasonable Attorney's Fee.......................................................................$1,650.00
$162,616.14
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$162,616.14,
together with interest at the rate of$16.20,per day 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.
By:
KML LAW GROU1,
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 1. 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
VERMICA.TION
I, Paul Romero , as the representative of PennyMac Loan Services,
LLC. the,Plaintiff corporation within named do hereby verify that I'ann authorized to and do make
this verification on behalf of PennyMac Loan Services,LLC. tbe.Plaintiff corporation and the facts
set forth in the foregoing Coni.plaint;are true and correct to the lest of my information and belief: I
understandthat false statements therein arc made subject to the penalties of IS Pa. C.S. Sec. 4904
relating to unsworn falsification to authorities.
Date' 1Q NA / IL/
PENNYMAC LOAN SERVICES,LLC
By: PennyMac Loan Services,LLC, the Plaintiff
Name: Paul Romero
Title: Default Specialist
#1.32725FC-JESSICA NGUYEN and THUNAM NGUYEN
4312 Park.Street Camp Hill,`PA.1,7011
EO,Xhisbit
A
I;
i
I
I
ael of fiend �tuats ib'A+ � Taw��Pa• -
NitcbR'Ff1li trot of Pu mws p rtAmAarly ceded wad dtegdbed
S�Zeimd Ormtr*
follows* 'to wily
eIDGIJ m nt n po�lstt Im 'CbM �t'1 of St. mitt Plot
NA
4o4.43 lest rAct at Im Nvr&�� 7 hor
Stt*et� sad at di.idim line betwewa T� N9a. 6 end T SA ,� -
Qok.aod Psdrj VOM
almS Ndd dive b%lino 13a� 21 deg #6 int
y25 feet to n pb3af l 77ff2 Nortk 90 dW&" let '"Utee acct 69 t*" Ps
13. of said ORkNOd F�1
Ft ditidiri6 lint ba wmn.lets 1109. 1 ead 8 AMtim ad � Nss.r!L'ES xat
tnu= hien 19sid diTidira Mm. god*21 dew
x poi7St as tb•gor6arly U" 0t AAt`k tltrtst�.«£ereeafdge PIRO#o!8> •
swath 64 awfas i+t ndenr4s Sart 6N i 't0 a 1 •
i
i
Eifift
*Exhibit has been redacted to remove all personally identifiable information or non-public information
w�Lz FORM iiFwr O.5xitk t�,s
THE FROM us�rNc�.ssgt,ses 7196 9008 9112 2607 9521
watt
CERTIFIED Jessica Nguyen i TO:
Thunam Nguyen f
4312 Park Street Jessica Nguyen
=
Camp Hill PA 17011 Thunam Nguyen
� 4312 Park Street
Labels Camp Hill PA 17011
i
i
F7,0039033949,02-25-14, , - ,JYH '
i
_
Jessica Nguyen a? SENDER:
Thunam Nguyen
4312 Park Street REFERENCE:
Camp Hill PA 17011 F7,0039033949,02-25-14, , - - JYH
Label#2 a;
PS Form 3800.Jars, Zoos
F7,0039033949,02-25-14, , - - JYH ~ RETURN Postage
j? RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Jessica Nguyen Restricted Delivery
Thunam Nguyen Total Postage&Fees
4312 Park Street
Label#3 Camp Hill PA 17011 USPS' POSTMARK OR DATE
Receipt for
F7,0039033949,02-25-14, , - - ,JYH Certified Mail"'
No Inwranoe Coverage Provided
A FOLD AND TEAR THIS WAY--� OPTIONAL Do Not Use for International Mail
B ...-- — — -
Label#5 .--------------- --- »_.»»». _....»..............
a
Labat 18
,_; Jessica Nguyen
171 Thunam Nguyen
4312 Park Street
0 Camp Hill PA 17011
ru
a .
a
tr �
. m
o ch"e
n- Amount:
.A
A Charge
TO:
FOLD AM TM IMS WAY �
WALZ
WALZ Form No:356G3 ' Since 1983,Walz has been a pioneer and the nationwide leader in
Posr�saur�oN�"" Version:10/13 providing Certified Mail-solutions.We offer significant domain expertise in
Certified Mail'and the leading solutions in the industry.
To reorder forms,contact us at: 0 Walz currently services 34 of the Fortune 100 companies and 86 of
the AmLaw 200
salesOwalzgroup corn r..
a 80%of the top mortgage companies are our clients along with over
(800)882-3811 3,500 organizations such as government,legal,healthcare,and insurance =
wwwwalzgroup mm0 Over the past thirty years,Walz has created unique Certified Mail'"
solutions for over 300 million mailings
WALZ SOLUTIONS:
0 WALZ CERTIFIED MAILERS':Patented forms and i
software to automate your in-house process WALZ REFERRALPROGRAM
ho could benefit from
Do you know someone w
O WALZ OUTSOURCING SERVICES:
using our forms?
Comprehensive Outsourcing Solutions for
compliant type mailings,utilizing Certified I- Mention our forms to a friend and tell them to
Mail—and First-Class servicesmention your naiiie when they call.Both you
-)ur next
and yourfriend will receive 10%off of yc
A`;WIR-ACKRIGHT° :Tracks USPS®Delivery events,images.
i ordersoff per. .
and updated status
Promotional ..-
q fit'.TORERIGHTD:Return Receipt and Unclaimed.Mail
storage and records management system ±;'p ' `tl "'" "`'
.. ------------ .................•--.........----- .---- ----......... ---- -. -.-.. _--_ .. _: _. --- ----------------------
1"1:
- .. ----• ------1"1:Addressee label
�•.-
Lall 2,'Addi6vnal addressee label ar optional return address'
label when using the Walz Certified Macro .011111F
tLalyd t,.Heturn address labelir
Labat#:'Seridet'` temtd of the Certified Article Number -
u.i.,nadr..wuk..n
,t
A&WoW labelforcustonwfites
s t N 6ef'S,1;i= 300 Certified sticker(affix.at the top of rite
..;e.hvelope with the.perforation mark on'the edge)
`Ret nn Retiept:Proof of tlel very that provides-reciplent FRONT BACK
signature.det'`rwery date and forwarded
address o'degvery,if applicable
f � - -_---= - ---- ------ ----- - --=- ----
0039033949 F7
Franklin American
MORTGAGE COMPANY
February 25,2014
Hours of operation:
00386 Customer Se wice:Monday-Friday.8:30 AM to 8:00 PM Er
Jessica Nguyen Collections Dept:Monday-Friday.8:30 AM to 10:00 PM Er
Thunam Nguyen
4312 Park Street
Camp Hill PA 17011
Loan Number:M3949
Property Address: 4312 Park Street
Camp Hill PA 17011
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear Jessica Nguyen and Thunam Nguyen:
The MORTGAGE held by FRANKLIN AMERICAN MORTGAGE COMPANY(hereinafter we,as or ours)on
your property located at:
4312 Park Street
Camp Hill PA 17011
IS IN SERIOUS DEFAULT because you have not made the monthly payment (s) and other charges for the
months of January 01,2014 through February 25,2014 as follows: .J
Next Payment Due Date: January 01,2014
Current Monthly Payment: $1,126.60
Total Monthly Payments Due: $2,253.20
Late Charges: $45.06
Other Charges: Uncollected NSF Fees: $.00
Other Fees: $16.25
Corporate Advance Balance: $.00
Suspense Funds: $1,116.43
TOTAL YOU MUST PAY TO CURE DEFAULT: $1,198.08
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:
TOTAL YOU MUST PAY TO CURE DEFAULT: $11198.08-
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above
amount of $1,198.08, plus any additional monthly payments and late charge which may fall due during this
period. Such payment must be made either by cash,cashier's check,certified check or money order. Please remit
the total amount due immediately to: Franklin American Mortgage Company, P.O. Box 986, Newark, NJ
07184-0986.
Toll Free: 877-883-1073 • Website: www.famchomeloan.com
If you do not cure the 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 still 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'sfees.
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 still
have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's 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 Sheriff's sale could be held would be approximately May 26,
2014.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: 877-883-1073. This payment must be in cash, cashier's
check,certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriff's 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 Sheriff's 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 ATTORNEYOS FEES AND COSTS ARE PAID 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 ARE UNABLE TO BRING YOUR ACCOUNT CURRENT,Franklin American Mortgage Company
offers consumer assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. You
may be eligible for a loan workout plan or other option. If you would like to learn more about these programs,
you may contact us at the number listed. WE ARE VERY INTERESTED IN ASSISTING YOU.
Attention Servicemembers and dependents: The Federal Servicemembers' Civil Relief Act ("SCRA"). and
certain state laws provide important protections for you, including prohibiting foreclosure under most
circumstances. If you are currently in the military service, or have been within the last nine (9) months, AND
joined after signing the Note and Security Instrument now in default,please notify Franklin American Mortgage
Company immediately. When contacting Franklin American Mortgage Company as to your military service,
you must provide positive proof as to your military status. If you do not provide this information, it will be
assumed that you are not entitled to protection under the above-mentioned Act.
For your benefit and assistance, there are government approved homeownership counseling agencies designed
to help homeowners avoid losing their homes. To obtain a list of approved counseling agencies, please call
(800) 569-4287 or visit http://www.hud.gov/offices/hsgtsfh/hcc/hes.chn. You may also contact the
Homeownership Preservation Foundation's Hope hotline at(888)995-HOPE(4673).
This matter is very important. Please give it your immediate attention.
Sincerely,
Franklin American Mortgage Company
425 Phillips Blvd.
Ewing,NJ 08618
XCO19 010 JYH F7
FEDERAL LAW REQUIRES US TO ADVISE YOU THAT THIS IS AN ATTEMPT TO COLLECT A
DEBT. ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. TO THE EXTENT
YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A
BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND
DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT AN
INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE REPRESENTED BY AN
ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE
NUMBER.
Cumberland County
*CCCS of Western PA-York
55 Clover Hill Road
Dallastown PA 17313
888.511.2227/888.511.2227
www.cccspa.org
Community Action Commission -Capital Region
1514 Derry St
Harrisburg PA 17104
717.232.9757
www.cactdcounty.org
Harrisburg Fair Housing Council
2100 N 6th St
Harrisburg PA 17110
717.238.9540
Housing&Redevelopment Authority-Cumberland Cnty
114 N Hanover St; STE 104
Carlisle PA 17013
866.683.5907/717.249.0789
www.cchra.com
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234.6616
www.ruralisc.org/pathstone—pa.htm
Pennsylvania Interfaith Community Programs, Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
www.adamscha.org-
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFFiC
THE PRUfHOi OiAi;
OFFCa' F TI4 ?HE' FF
2014 NOV 17 Fti 3: CCS
CUMBERLAND COUNTY
PENNSYLVANIA
Pennymac Loan Services, LLC
vs.
Jessica Nguyen (et al.)
Case Number
2014-6355
SHERIFF'S RETURN OF SERVICE
11/04/2014 07:53 PM - Deputy Shawn Gutshall, 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:
Jessica Nguyen at 4312 Park Street, Hampden Township, Camp Hill, PA 17011.
GUTSHALL, DEPUTY
11/04/2014 07:53 PM - Deputy Shawn Gutshall, 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 Jessica Nguyen, Daughter, who accepted as
"Adult Person in Charge" for Thunam Nguyen at 4312 Park Street, Hampden Township, Camp Hill, PA
17011.
"OP
4417 N GU SHALL, DEPUTY
SHERIFF COST: $60.95 SO ANSWERS,
November 05, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuite Sherif, Teleosoft, Inc.