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HomeMy WebLinkAbout14-6658 Supreme Court of Pennsylvania Court of Common Pleas FarProtlrorrotary Use Onlj. i; Civil Cover Sheet Docket No: Cumberland County , ` The information collected on this form is used solely for court administration purposes. This form does not sup lement or replace thefiling and service ofpleadings or other a ers 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 Name: KELLY LYNN NOON,IN HER T MORTGAGE ASSOCIATION("FANNIE MAE") CAPACITY AS EXECUTRIX OF THE ESTATE OF I CLARENCE L.CHUBB A/K/A CLARENCE LAMAR O CHUBB,DECEASED AND IN HER CAPACITY AS N DEVISEE 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 OX No Is this an MDJA eal? ❑ Yes ❑X No Name of Plaintiff/Appellant's Attorney: Martha Von Rosenstiel,Esq. ❑ Check here if you are a Self-Represented(Pro Se Litigant Nature of the Case: Place an"X"to the left oftlie ONE case category tltat mast accurntel3'describes your PRL1I4RY C45SE. If you are making snore than one type of claim:check the one that you consider most important. TORT(do no;include Mass Tort) CONTRACT(donor htctude Judgments) CIVIL APPEALS El Intentional ❑Buyer Plaintiff Administrative Agencies El Malicious Prosecution ❑Debt Collection:Credit Card ❑ Board of Assessment Motor%,ehicle ❑Debt Collection:Other Board of Elections Nuisance El Dept.of Transportation Prernises.Liability ❑ Statutory Appeal:Other S ❑ Product Liability{sloes not inchido E mass tot;) ❑Employment Dispute: Slander/LibeliDefamation Discr•itnination C ❑Other.: ❑Employment Dispute:Other ❑ Zoning Board -I- ❑Other: I — ❑Other: 0 MASS'TORT ❑ Asbestos N ❑ Tobacco Toxic Tort-DES To.ic Tort-Irrrplant REAL PROPERTY MISCELLANEOUS Toxic Waste Other: ❑Ejectment ❑Conrrnon Law/Statutory Arbitration B ❑Eminent Domaim'Coudetruiation ❑Declaratory Judgment ❑Ground Rent. Mandamus LandlordtTenant Dispute 8 Non-Domestic Relations ❑Mortgage Foreclosure:Residential Restraining Order x PROFESSIONAL LIABLITY ❑Mortgage Foreclosure.:Commercial ❑Quo Rtarranto Dental ❑Partition ❑Replevin Legal ❑Quiet.Title ❑Other: Medical ❑Other: ❑ Other Professional: Updated 1/1/22011 , s MARTHA E. VON ROSEN r r '` r 5 0 01 t"0 ri" 7 STIEL, P.C. (fit r f.f {� t�, y 35505CFC-AB Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 649 SouJeniece th Avenue, Suite 7 Davis, Esquire/No. 208967 E;,f,�t S�j�V to ll r, 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 ltF elve V. NO. ���- ��J KELLY LYNN NOON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF CLARENCE L. CHUBB A/K/A CLARENCE LAMAR CHUBB, DECEASED AND IN HER CAPACITY AS DEVISEE 632 Davis Drive New Cumberland, PA 17070 Defendants CIVIL ACTION—MORTGAGE FORECLOSURE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims Le han demandado a usted en la cone.Si usted quiere defenderse de set forth in the following pages,you must take action within twenty estas demandas expuestas en las pagmas siguientes,usted tiene (20)days after this complaint and notice are served,by entering a veinte(20)dias de plazo al partir de la fecha de la demanda y la written appearance personally or by attorney and filing in writing with notificacion. Hace falta a sentar una comparencia escrita o en the court your defenses or objections to the claims set forth against you. persona o con un abogado y entregar a la 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,]a 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,la 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 CARLISLE, PA 17013 717-249-3166 , 800-990-19108 � S� Ck- � 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. 35505 CFC-AB Martha E. Von Rosenstiel, Esquire/No. 52634 Heather Riloff, Esquire/No. 309906 Jeniece D. Davis, Esquire/No. 208967 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff FEDERAL NATIONAL MORTGAGE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY 3900 Wisconsin Avenue, NW Washington, DC 20016-2892 Plaintiff V. NO. KELLY LYNN HOON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF CLARENCE L. CHUBB A/K/A CLARENCE LAMAR CHUBB, DECEASED AND IN HER CAPACITY AS DEVISEE 632 Davis Drive New Cumberland, PA 17070 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. Defendant is Kelly Lynn Hoon, in her capacity as Executrix of the Estate of Clarence L. Chubb a/k/a Clarence Lamar Chubb, Deceased and in her capacity as Devisee, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant to foreclose a certain indenture of mortgage made, executed and delivered by Clarence L. Chubb a/k/a Clarence Lamar Chubb to Countrywide Home Loans, Inc. on March 16, 2007, which mortgage was recorded on March 27, 2007 in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1986, Page 1751, secured on premises 4601 Chestnut Avenue, Camp Hill, PA 17011 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to Federal National Mortgage Association by written assignment dated February 7, 2013 and recorded on February 19, 2013 in the Office of the Recorder of Deeds of Cumberland County as Mortgage Instrument No. 201305477. 5. On October 29, 2012, Clarence L. Chubb a/k/a Clarence Lamar Chubb departed this life, leaving a Last Will and Testament, in which he specifically devised the mortgaged premises to Kelly Lynn Hoon. 6. Letters Testamentary were granted to Kelly Lynn Hoon, as Executor of the Estate of Clarence L. Chubb a/k/a Clarence Lamar Chubb, Deceased, on November 8, 2012 by the Register of Wills of Cumberland County under Will No. 21-12-1177. 7. Kelly Lynn Hoon, Executrix of the Estate of Clarence L. Chubb a/k/a Clarence Lamar Chubb, conveyed premises to Kelly Lynn Hoon by way of Deed dated May 5, 2013 and recorded May 16, 2013 as Cumberland County Instrument No. 201316133. 8. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 9. 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 May 2014 and each month thereafter, up to and including the present time. 10. 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. 11. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 119,281.76 Interest from 4/1/2014 to 10/3/2014 at $20.83 per diem $ 3,854.19 Accrued Escrow deficit $ 36.04 Attorney's Fee $ 2,350.00 Property Inspections $ 90.00 Suspense $ ( 13.92 ) Total $ 125,598.07 12. The defendant involved in this action is not a mortgagor and therefore is not eligible for assistance under Act 91 of 1983. 13. As there are no successor record owners, notice under Act 6 of 1974 is not required. WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of$125,598.07, plus per diem interest at $20.83 from October 4, 2014 to the date of judgment plus costs thereon. MARTHA E. VON ROSENSTI , P.C. BY:. Martha E.,Von Rosenstiel, Esquire Heather Riloff, Esquire Jeniece D. Davis, Esquire -' Attorneys for Plaintiff VERIFICATION William Randolph hereby states that he/she is the Foreclosure Specialist of Seterus, Inc., as authorized subservicer for Federal National Mortgage Association("Fannie Mae"), a corporation organized and existing under the laws of the United States of America,plaintiff herein; that he/she is duly authorized to make this Verification on behalf of Federal National Mortgage Association ("Fannie Mae") and verifies that the statements made in the foregoing Complaint in Federal National Mortgage Association ("Fannie Mae") v. Kelly Lynn Hoon, in her capacity as Executrix of the Estate of Clarence Lamar Chubb, Deceased and in her capacity as Devisee relating to the property located at 4601 Chestnut Avenue, Camp Hill, PA 17011 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: i am andolph Title: Forecinsure Specialist Seterus, Inc., as authorized subservicer for Federal National Mortgage Association ("Fannie Mae"), a corporation organized and existing under the laws Dated: _ 3 D_ of the United States of America `'� EXHIBIT I LEGAL DESCRIPTION All that certain piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: Beginning at point at the Northwest corner of Clearview Drive and Chestnut Avenue on the Plan of Lots of Clearview Farms; thence South 51 degrees 26 minutes West along the northerly line of Chestnut Avenue a distance of 108.41 feet to a point; thence North 38 degrees 16 minutes West a distance of 57.24 feet to a point; thence North 3 degrees 5 minutes West a distance of 57.6 feet to a point on the southerly side of Clearview Drive;thence a North 86 degrees 55 minutes East along the southerly side of Clearview Drive a distance of 19 feet to a point;thence continuing along Clearview Drive in an arc curving to the right having a radius of 145 feet for a distance of 112.97 feet to a point,the place of beginning. PARCEL IDENTIFICATION NO: 10-21-0279-134, CONTROL#: 10007863 FORM 1 FEDERAL NATIONAL MORTGAGE IN THE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY, 3900 Wisconsin Avenue, NW PENNSYLVANIA Washington, DC 20016-2892 Plaintiff vs. NO. y KELLY LYNN HOON, IN HER CAPACITY AS (v I EXECUTRIX OF THE ESTATE OF CLARENCE L. CHUBB A/K/A CLARENCE LAMAR CHUBB, DECEASED AND IN HER CAPACITY AS DEVISEE = 632 Davis Drive New Cumberland, PA 17070 l , 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 oft he 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. Respe, Ily submitted: November 6, 2014 Date Signatutle4f Counsel for Pfal tiff 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? 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: s Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: _ Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Other transportation(automobiles boats motorcycles)• Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description(not wages): 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses:(Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2° Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med.(not covered) Auto fuel/repairs Other Prop.Payment Install. Loan Payment Cable TV Child Support/Alim, Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes❑ No If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes[] No [] If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company(Name): Contact: Phone: AUTHORIZATION I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender and fender 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 FEDERAL NATIONAL MORTGAGE FORM 3 IN THE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") CUMBERLAND COUNTY, 3900 Wisconsin Avenue, NW PENNSYLVANIA Washington, DC 20016-2892 . Plaintiff vs. NO. KELLY LYNN HOON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF CLARENCE L. CHUBB A/K/A CLARENCE LAMAR CHUBB, DECEASED AND IN HER CAPACITY AS DEVISEE 632 Davis Drive New Cumberland, PA 17070 Defendants REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 ng the Cumbern County Residential Mortgage foreclosure Diversion Program, the undersigned hereby certi es as follows: I. 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 Legal Representative Date Signature of Defendant Date Signature of Defendant Date FEDERAL NATIONAL MORTGAGE FORM 4 INTHE COURT OF COMMON PLEAS OF ASSOCIATION ("FANNIE MAE") 3900 Wisconsin Avenue, NW CUMBERLAND COUNTY, PENNSYLVANIA Washington, DC 20016-2892 Plaintiff vs. NO. KELLY LYNN HOON, IN HER CAPACITY AS EXECUTRIX OF THE ESTATE OF CLARENCE L. CHUBB A/K/A CLARENCE LAMAR CHUBB, DECEASED AND IN HER CAPACITY AS DEVISEE 632 Davis Drive New Cumberland, PA 17070 Defendants CASE MANAGEMENTORDER 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: I. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at __.____. M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or-the date upon which service of the completed Form 2 is to be made may be extended. upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. S. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTYt., _( irr. t it_,.f�� iJi !� tart;. THE } O iONOiW 2tTi DEC —14 11H 9: 57 CUMBERLAND COON ► Y PENNSYLVANIA OFPCZ Or THE !$i,,E,R1 P Federal National Mortgage Association vs. Kelly Hoon in her Capacity as Executrix of the Estate of Clarence L. Chubb Case Number 2014-6658 SHERIFF'S RETURN OF SERVICE 11/19/2014 06:03 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mo• age Fo -t losure by "personally" handing a true copy to a person representing themselves t• •- D -'en ant, to wit: Laurie Putman, Occupant at 4601 Chestnut Avenue, Hampden Township, Ca ' • , 7011. WN HARD`' IN, DEPUTY 11/20/2014 04:50 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: Kelly Hoon in her Capacity as Executrix of the Estate of Clarence L. Chubb at 632 Davis Drive, New Cumberland Borough, New Cumberland, PA 17070. GUTSHALL, DEPUTY SHERIFF COST: $74.16 SO ANSWERS, November 21, 2014 RONNN1Y R ANDERSON, SHERIFF {c) CountySuile Shoriff, ,!eosoft. Inc.