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Home My WebLink About14-7193 l For Prothonotary Use Only: S u ftfe.rri a Go,w rtof P'e n n sy Iva n i a. �C�o�u rt o �Co rui n Plea s ,C-4 i1 ver Sh*oet. m`r,!and 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 of leadin s or other papers as required by law or rules of court. Commencement of Action: S ®Complaint ❑ Writ of Summons ❑ Petition E ❑Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name:LSF8 Master Participation Trust Lead Defendant's Name:Bradley P.Robinson T I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑within arbitration limits O (check one) ❑outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No I Is this an MDJAppeal? [] Yes ® No A Name of Plaintiff/Appellant's Attorney:McCabe, Weisberg&Conway,P.C. ❑ Check here if you have no attorney(a Self-Represented 1.Pro Sel 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 APPEALS ❑intentional ❑Buyer Plaintiff Administrative Agencies ❑Malicious Prosecution ❑Debt Collection: Credit Card ❑Board of Assessment ❑Motor vehicle ❑Debt Collection: Other ❑ Board of Elections ❑Nuisance 1 ❑ Department of Transportation ❑Premises Liability(does not include ❑ Statutory Appeal: Other S mass tort) E ❑ Slander/Libel/Defamation ❑Employment Dispute: ❑Other: Discrimination C ❑Employment Dispute: Other ❑Zoning Board T ❑Other I O ❑Other N MASS TORT ❑Asbestos ❑Tobacco 11 11 ❑Toxic Tort-DES ❑Toxic Tort-Implant B REAL PROPERTY MISCELLANEOUS ❑Toxic Waste ❑Ejectment ❑Common Law/Statutory Arbitration ❑Other. ❑ Eminent Domain/Condemnation ❑Declaratory Judgment ❑Ground Rent ❑Mandamus ❑ Landlord/Tenant Dispute ❑Non-Domestic Relations ®Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY Mortgage❑ Mort a e Foreclosure:Commercial ❑Quo Warranto ❑Dental ❑ Partition ❑Replevin ❑Legal ❑Quiet Title ❑Other: ❑Medical ❑Other: ❑Other Professional: Updated 1/1/2011 FORM 1 I LSFB Master Participation Trust IN THE COURT OF COMMON PLEAS OF t Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA vs. Bradley P. Robinson and Brenda J. Keller, a/k/a Civil Brenda J. Robinson 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 that 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 submitt, O� D Date [Signature of Counsel for Plaintiff] 14-104333 Page 1 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: 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 on household: How long? CO-BORROWER Mailing Address(if different): City: State: Zip: Phone Numbers:. Home: Office: Cell: Other: Email: #of people on 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 Payment Amount$ Included Taxes&Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes 0 No 0 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: "i Monthly Income Name of Employers: 1. 2. 3. 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"a 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 Da /Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&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: 2 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 deliquency? Yes❑No❑ If yes,please indicate the status of those negotiations: Please provide the following information,if known,regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: 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 obiligation to use the services provided by the above named 'Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation(hardship letter) Listing agreement(if property is currently on the market) 3 E 12 FIA, 2• E ^�1tIE?ERi_AND Ci;U Y YLVI N- McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE,ESQUIRE-ID# 1.6496 MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE-ID# 34687 MARGARET GAIRO,ESQUIRE-ID#34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID# 74770 MARISA J. COHEN,ESQUIRE-ID# 87830 CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA,ESQUIRE-ID# 57716 JOSEPH L FOLEY,ESQUIRE-ID# 314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID# 313673 LENA KRAVETS,ESQUIRE-ID#316421 CAROL A.DiPRINZIO,ESQUIRE-ID# 316094 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215) 790-1010 LSF8 Master Participation Trust Cumberland County c/o Caliber Home Loans,Inc. Court of Common Pleas 13801 Wireless Way Oklahoma City, OK 73134-2500 Number - T93 IV�1TP.C� V. Bradley P.Robinson 2 Ian Drive Mt. Holly Springs,PA 17065 and Brenda J. Keller, a/k/a Brenda J.Robinson 2 Ian Drive Mt. Holly Springs,PA 17065 COMPLAINT IN MORTGAGE FORECLOSURE �i l�.'75 pt�FiTl'`f aZD1 ba 31 Lk 5'71 File# 14-104333 • ou have been sued in court. If you wish to Le han demandado a usted en la corte. Si Y defend against the,claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex-puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notificacion. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisiones de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO TIENE BELOW. THIS OFFICE CAN PROVIDE A UN ABOGADO, VA A O TELEFONEA YOU WITH INFORMATION ABOUT LA OFICINA EXPUS"O ABAJO. ESTA HIRING A LAWYER. OFICINA LO PUEDE PROPORCIONAR IF YOU CANNOT AFFORD TO CON INFORMATION ACERCA DE HIRE A LAWYER, THIS OFFICE MAY BE EMPLEAR A UN ABOGADO. ABLE TO PROVIDE YOU WITH SI USTED N O PUEDE INFORMATION ABOUT AGENCIES THAT PROPORCIONAR PARA EMPLEAR UN MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. INFORMACIONACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS , 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990-9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 File# 14-104333 D....e 7 COMPLAINT.IN MORTGAGE FORECLOSURE 1. Plaintiff is LSF8 Master Participation Trust. 2. Caliber Home Loans, Inc. is acting solely in the capacity as servicer for LSF8 Master Participation Trust,Plaintiff herein. 3. The Defendant is Bradley P.Robinson,who is a mortgagor and real owner of the mortgaged property hereinafter described,and his/her last-known address is 2 Ian Drive,Mt.Holly Springs,PA 17065. 4. The Defendant is Brenda J. Keller, a/k/a Brenda J.Robinson,who is a mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 2 Ian Drive, Mt. Holly Springs,PA 17065. 5. On January 25;2007,Bradley P.Robinson and Brenda J.Keller,a/k/a Brenda J.Robinson, mortgagors,made,executed and delivered a Mortgage upon the premises hereinafter described to Beneficial . Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania which Mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1980,Page 3892(the "Mortgage"), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa.R. C. P. 6. On January 25, 2007,Defendant,Bradley P.Robinson and Brenda J. Keller,a/k/a Brenda J. Robinson, also executed an Adjustable Rate Note secured by the aforementioned Mortgage. Plaintiff, directly or through an agent,is in possession of the note and is the holder of the note with the right to enforce it;the note is either made payable to plaintiff or has been duly endorsed. 7. On July 24, 2014,the Mortgage was assigned by Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania, by Caliber Home Loans, Inc., as attorney in fact to LSF8 Master Participation Trust, by Assignment of Mortgage, recorded in,the Office of the Recorder of Cumberland County as Instrument Number 201419035, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa.R. C.P.. 8. The premises subject to said Mortgage is described in the legal description attached as Exhibit "A" and is known as 141 Farm Road,Newville,Pennsylvania 17241. File# 14-104333 Page 3 9. The Mortgage is in default because monthly=payments of principal and interest upon said Mortgage due February 1, 2012 and each month thereafter are due and unpaid, and by the terms of said Mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 10. The following amounts are due on the Mortgage: Principal Balance $ 173,142.96 Interest through November 14,2014 $ 55,691.41 (Interest due and owing at a variable rate, currently$45.78 per diem) Late Charges $ 389.43 . Attorney's Fee $ 2,350.00 Escrow Advance $ 1,536.00 Tax Balance $ 11,698.40 Less Unapplied Funds $ (47.44) Appraisal or Broker's Priced Opinion(BPO)Fee $ 200.00 Property Inspections $ 255.50 Property Preservation Costs $ 2,051.64 GRAND TOTAL $ 247,267.90 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's sale. If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 11. Plaintiff complied with,all notice requirements as prescribed by 41 P.S. §101,et seq. (Act 6), and 35 P.S. 1680.401c,et seq. (Act 91),as applicable. File# 14-104333 Page 4 WIJEREFORE, Plaintiff demands in rem Judgment against the Defendants in the sum of $247,267.90,together with interest due and owing at a variable rate,currently$45.78 per diem, and other costs and charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged property. McCABE,WEISBERG C. �r BY: F [ ]Terrence J.McCabe,Esquire [ ]Marc S eisberg,Esquire [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire [ ]Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F . a,Esquire [ ]Joseph I.Foley,Esquire [ ] CO DerKrikorian,Esquire [ ]Lena Kravets,Esquire arol A.DiPrinzio,Esquire Attorneys for Plaintiff File# 14-104333 Page 5 VERIFICATION The undersigned, , does hereby certify that he/she is �k SO-0 V CaNrof Caliber Home Loans,Inc. and that Caliber Home Loans,Inc.has been duly nominated and appointed by LSF8 Master Participation Trust, plaintiff herein, as its mortgage servicing agent in regard to the mortgage loan which is the subject of this action(the"Mortgage"). LS178 Master Participation Trust lacks sufficient information to make this verification because Plaintiffs is not the entity that maintains the business records for the Mortgage. Caliber Home Loans,Inc., in its capacity as mortgage servicing agent for LSF8 Master Participation Trust,maintains the business records for the Mortgage, and therefore does have sufficient information to make this verification in accordance with Pa.R.C.P. 1024(c)(1). I am authorized to make this Verification on Plaintiff's behalf and do hereby verify that the facts as set forth in the foregoing Complaint are true and correct to the best of my information and belief. I have access to and have reviewed the business records of Caliber Home Loans,Inc. for and relating to the Mortgage,_and I make this Verification based on my review of those records,which are maintained by Caliber Home Loans, Inc. in the course of its regularly conducted business activities and are made at or near the time of the event,by or from information transmitted by a person with knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C-S. §4904 relating to unsworn falsification to authorities. Dated: By: Name'IF-4, �(` Title: Z \-, LSF8 Master Participation Trust,by Caliber Home Loans,Inc., solely in its capacity as servicer Name: LSF8 Master Participation Trust v.Bradley P.Robinson and Brenda J.Keller,a/k/a Brenda J.Robinson Loan Number ending with: 7640 Fite-4 14-104333 Page 6 '• Exhibit "A" EXHIBIT A (PAGE 1) ALL THAT CERTAIN PROPERTY SITUATED IN TMETpYr M I P OF PENN IN THE COUNTY OF qLWIEERLA D AND M& NMI!ALTH OF PENNSYLVANIA, BEING MORE FULLY DESCRIBED IN A DEED DATA 08/2811886 AND RECORDED 09/2911M.- AMOW THE LAND RECORDS OF THE CO=RM AND STATE SET FORTH ABOVE, IN GEED VOLUME 128 AND PAGE 1128. TAX MAP OR PARCEL tD No, ; 31-11-Q3pO-O47 TC ertl fy this Cu O be z'ecorded �xzbez-�and Co UntY-PA Recorder of beeds `R5$2C59C2R8WT0T000PA0013000-gftjN50ry K Og161PM3L 8K I 9-80PG390.1 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Initiate any Foreclosure Action in the Name of (in the following states: AK, AZ, CO, DE, ID, MT, ND, NE, NJ, NM, OK, PA, SD, WY): LSF8 Master Participation Trust, by Caliber Home Loans, Inc., solely in its capacity as servicer Initiate any Foreclosure Act Plaintiff v. Bradley P. Robinson and Brenda J. Keller, a/k/a Brenda J. Robinson Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number: 14-7193 Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure in the above -captioned matter. McCABE, WEISBERG�AND CONWAY, P.C. BY: i 2 L • 4i-, f [ ] Terrence J. McCabe, Esq. [ ] Marc S. Weisberg, Esq. [ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. )) [ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph F. Riga, Esq. [ ] Joseph 1. Foley, Esq. Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esquire 1 �Spd ] Carol A. DiPrinzio, Esquires 1 Attorneys for Plaintiff a CkJ a3rlgi 24 Sup Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY -OFF-v.;F. TKE PHGF.IFF PENNSYLVANIA, NIA, 0 LSF8 Master Participation Trust vs. Bradley P Robinson (et al.) Case Number 2014-7193 SHERIFF'S RETURN OF SERVICE 12/15/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Bradley P Robinson, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 141 Farm Road, Penn Township, Newville, PA 17241. Residence is vacant. A Post Office check was requested, the form was returned by the Newville Postmaster marked "Unable to Forward, Forwarding Order Expired". 12/15/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Brenda J Keller, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 141 Farm Road, Penn Township, Newville, PA 17241. Residence is vacant. A Post Office check was requested, the form was returned by the Newville Postmaster marked "Unable to Forward, Forwarding Order Expired". SHERIFF COST: $67.56 SO ANSWERS, January 06, 2015 (c) CountySu e Sheriff, TeleosoTt, BONN R ANDERSON, SHERIFF