HomeMy WebLinkAbout15-0021 Supreme Coutrt_of Pea-insylvania
Coin hof omen PIeas
G'i��I,Co��et- Sheet For Ptothouatatr Use Onit':
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The information collected on this form is used solely for 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:
R Complaint ❑ Writ of Summons ❑ Petition
S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiff Name: Lead Defendant's Name:
C QUICKEN LOANS INC DOUGLAS BLACK
T
I Dollar Amount Requested within arbitration limits
0 Are money Damages requested?: ❑ Yes R No (Check one) X outside arbitration limits
N
Is this a Class Action Suit? ❑ Yes ® NO Is this an MI)J Appeal? ❑ Yes R 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
❑ 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:
I
0 MASS TORT ❑ Other
N ❑ Asbestos
❑ Tobacco
❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory
❑ Toxic Waste
❑ Other ❑ Eminent Domain/Condemnation Arbitration
❑ Ground Rent ❑ Declaratory Judgment
❑ Landlord/Tenant Dispute ❑ Mandamus
RMortgage 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 CENTER
701 MARKET STREET
PHILADELPHIA,PA 19106
(866)413-2311
W W W.K&ILLA W GROUP.COM
QUICKEN LOANS INC IN THE COURT OF COMMON PLEAS
635 Woodward Avenue
Detroit,MI 48226 OF Cumberland COUNTY
Plaintiff
VS. CIVIL ACTION-LAW
DOUGLAS BLACK ACTION OF MORTGAGE FORECLOSURE
Mortgagor(s)and Record Owner(s)
915 Park Place v iL ACTIUN: MORTGAGE
Mechanicsburg,PA 17055 FMECLOSU"
Defendant(s)
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 r? ,
Carlisle,PA 17013
r
LEGAL SERVICES INC
8 Irvine Row n `
Carlisle,PA 17013 �c -
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 usteo------,
s
1
(5, '75 PD i�T7
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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
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.oria/consumers/homeowners/real.aspx.
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.Dhiladelphiafed.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@kmllawproup.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 13949117C.
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 QUICKEN LOANS INC, 635 Woodward Avenue, Detroit, MI 48226.
2. The name(s) and address(es)of the Defendant(s) is/are DOUGLAS BLACK, 915 Park Place,
Mechanicsburg,PA 17055, who is/are the mortgagor(s) and record owner(s)of the mortgaged premises
hereinafter described.
3. On February 19, 2014 mortgagor(s)made, executed and delivered a mortgage upon the Property
hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS ,INC.AS
NOMINEE FOR QUICKEN LOANS , INC., which mortgage is recorded in the Office of the Recorder
of Deeds of Cumberland County on February 26,2014 as Instrument#201404020. The mortgage has
been assigned to: QUICKEN LOANS INC. by assignment of Mortgage executed December 5, 2014.
Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as
Exhibit"C". 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 August 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....................................................................................$91,036.76
Interest from 07/01/2014 through 01/05/2015 at 4.7500%.......................$2,209.49
Per Diem interest rate at$11.85
LateCharges .................................................................................................$95.48
EscrowBalance..........................................................................................($339.33)
PropertyInspections.......................................................................................$45.00
Reasonable Attorney's Fee.......................................................................$2.350.00
$95,397.40
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$95,397.40,
together with interest at the rate of$11.85,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.
i
By:
KML LAW GROUP,P.C.
Michael McKeever Pa. ID 61 9
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
VERIFICATION
I, t�l)1.i 1�1� as the representative of 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
best of my information and belief. I understand that false statements therein are made subject to the
penalties of 18 Pa. C.S. Sec.4904 relating to unsworn falsification to authorities.
Date:
#139491FC -DOUGLAS BLACK
915 Park Place Mechanicsburg,PA 17055
E..x. hibit
A
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Tax Id Number(s).22-31-2156-015
Land Situated in the Township of Monroe in the County of Cumberland in the State of PA
BEGINNING AT AN IRON PIN M THE SOUTHERN DEDICATED RIGHT-0F-WAY LINE OF OLD WILLIAMS
GROVE ROAD,NOW KNOWN AS PARK PLACE,AT THE EASTERN LINE OF LAND CONVEYED BY
HENRIETTA P.BELKNAP,WIDOW,TO ROBERT L GROSS AND MARY L GROSS,HIS WIFE,BY DEED DATED
JANUARY 11,1977 AND RECORDED IN DEED BOOK 'T,VOL 26,PAGE 94;THENCE BY THE SOUTHERN
DEDICATED RIGHT-OF-WAY LINE OF SAID OLD WILLIAMS GROVE ROAD,NOW KNOWN AS PARK PLACE,
NORTH 80 DEGREES EAST 137.16 FEET TO A POINT;THENCE BY A CURVE TO THE RIGHT HAVING A
RADIUS OF 4200 FEET AN ARC DISTANCE OF 69.89 FEET TO A POINT ON THE WESTERN LEGAL RIGHT-
OF-WAY LINE OF WILLIAMS GROVE ROAD,L.R.21017;THENCE BY SAID LEGAL RIGHT OF-WAY LME
SOUTH 04 DEGREES 39 MINUTES 40 SECONDS EAST 2922 FEET TOA POINT,THENCE BY LANDS NOW
OR LATE OF KENNETH MILLER AND LANDS NOW OR LATE OF HARRY HALE SOUTH 03 DEGREES 10
MINUTES 50 SECONDS WEST 120.77 FEET TO AN IRON PIN;THENCE BY SAID LANDS CONVEYED TO
ROBERT L GROSS AND MARY L GROSS,HIS WIFE,NORTH 86 DEGREES 49 MINUTES 10 SECONDS WEST
175.00 FEET TO A PIN;THENCE FURTHER BY SAME NORTH 01 DEGREES 55 MINUTES 30 SECONDS WEST
15421 FEET TO AN IRON PIN AT THE POINTAND PLACE OF BEGINNING.
BEING LOT NO.I ON FINAL SUBDM90N PLAN FOR HENRIETTA P.BELKNAP,WHICH SAID PLAN IS
RECORDED IN THE RECORDER OF DEEDS OFFICE IN AND FOR SAID CUMBERLAND COUNTY IN PLAN
BOOK 29,PAGE 39.
BEING PART OF TRACT NO.4 WHICH JANET R.HALL,WIDOW,BY DEED DATEDJUNE 5,1962 AND
RECORDED IN THE RECORDER OF DEEDS OFFICE IN AND FOR CUMBERLAND COUNTY IN DEED BOOK
'N' VOL 20 PAGE 727 GRANTED AND CONVEYED UNTO ROBERT D.BELKNAP AND HENRE17 TA P.
BELKNAP,HIS WIFE ROBERT D.BELKNAP DIED FEBRUARY 6,1973 WHEREON TITLE VESTED SOLELY IN
THE SAID HENRIETTA P.BELKNAP WHOSE EXECUTRIX IS THE GRANTOR HEREIN.
Commonly known as: 915 Park Pl,Andersontown,PA 17055
T • •
( /L.� Z Z t (B
*Exhibit has been redacted to remove allpersonally identifiable information or non-public information
Date: September 29,2014
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default,-and the
lender intends to foreclose. Specific information about the nature of the
default isprovidedin the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM (HEMAP) may be able to help to save your home. This Notice
explains how the program works. To see if HEMAP can help,you must
MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN
33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with jou when
you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice. If you have any questions,
you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-
2397 (Persons with impaired hearing can call (717) 780-1$b91.
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to
help explain it. You may also want to contact an attorney in your area. The
local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO
COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA
UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN
PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A
REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): Douglas Black
PROPERTY ADDRESS: 915 Park Pl.
Mechanicsburg, PA 17055
MAILING ADDRESS: 915 Park Pl.
Mechanicsburg, PA 17055
LOAN ACCT. NO.: 581
ORIGINAL LENDER: Quicken Loans
CURRENT
LENDER/SERVICER: Quicken Loans
HOMEOWNER'S EMERGENCY MORTGAGE
ASSIS'T'ANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN
SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE
FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"),
YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES
BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO
PAY YOUR MORTGAGE PAYMENTS,AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS
ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled
to a temporary stay of foreclosure on your mortgage for thirty (30) days from the
date of this Notice (plus three (3) days for mailing). During that time you must
arrange and attend a "face-to-face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS
NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE
ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE
PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of
the consumer credit counseling agency listed at the end of this notice, the lender
may NOT take action against you for thirty (30) days after the date of this meeting.
The names, addresses and telephone numbers of designated consumer credit
counseling agencies for the county in which the property is located are set forth at
the end of this Notice. It is only necessary to schedule one face-to-face meeting.
Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in
default for the reasons set forth later in this Notice (see following pages for
specific information about the nature of your default.) You have the right to apply
for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Assistance Program Application with one of the designated consumer
credit counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency.
To temporarily stop the lender from filing a foreclosure action, your application
MUST be forwarded to PHFA and received within thirty (30) days of your face-to-
face meeting with the counseling agency
YOU SHOULD FILE A HEMAP APPLICATIONAS SOON AS POSSIBLE. IF
YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33
DAYS OF THE POSTAMRK DATE OF THIS NOTICE AND FILE AN
APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN
THE LENDER WILL BE TEMPORARIL Y PREVENTED FROM STARTING
A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE,
IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE'
YOU HAVE THE RIGHT TO FILE A HEAMP APPLICATION EVEN
BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT
PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,
BUT IF YOUR APPLICA770NIS EVENTUALLYAPPROVED ATANY TIME
BEFORE A SHERIFFS SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are
very limited. They will be disbursed by the Agency under the eligibility criteria
established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE
FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING
PART OF THIS NOTICE IS FOR INFORMATION PURPOSES
ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT
TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency
Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE
DEFAULT LBring_ itup to dat).
NATURE OF THE DEFAULT--The MORTGAGE debt held by Quicken Loans,
Inc. on your property located at 915 Park Pl., Mechanicsburg PA 17055 IS IN
SERIOUS DEFAULT because YOU HAVE NOT MADE MONTHLY
PAYMENTS for the following months August 1, 2014 through September 1, 2014
and the following amounts are now past due:
The last assessed late charge on this account was $23.87 at a late charge rate of
5.00% for each delinquent payment(s). As of today, late charges have accrued to
the total amount of$47.74. Other charges include NSF fees have accrued at the
total amount of$0.00, a recoverable cost of$15.00, other fees in the amount of
$0.00 and a suspense balance of$0.00. 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 $1,393.18.
HOW TO CURE THE DEFAULT --You may cure the.default within THIRTY
(30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT
PAST DUE TO THE LENDER, WHICH IS JLL93.18, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by
cash, cashier's check,certified check or money order made payable and sent to:
Quicken Loans Inc.
635 Woodward Ave.
Detroit, MI 48226
IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within
THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its
rights to accelerate the mortgage debt. This means that the entire outstanding
balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends
to instruct its attorneys to start legal action to foreclose upon your mortgaged
ro e
IF THE MORTGAGE IS FORECLOSED UPON — The mortgaged property
will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your
case to its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable attorney's
fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorneys' fees actually
incurred by the lender even if they exceed $50.00. Any attorney's fees will be
added to the amount you owe the lender, which may also include other reasonable
costs. If jou cure the default within the THIRTY (301 DAY period,you will
not be required to pay attorney's fees.
OTHER LENDER REMEDIES -- The lender may also sue you personally for
the unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you
have not cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default and prevent the
sale at any time up to one hour before the Sheriffs Sale. You may do so by payine
the total amount then past due, plus any late or other charges then due, reasonable
attorney's fees and costs connected with the foreclosure sale and any other costs
connected with the _Sheriffs Sale as specified in writing by the lender and by
performing any other requirements under the morta e. Curing your default in
the manner set forth in this notice will restore your mortgage to the same
position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the
earliest date that such a Sheriffs Sale of the mortgaged property could be held
would be approximately 4-5 months from the date of this Notice. A notice of
the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may
find out at any time exactly what the required payment or action will be by
contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Quicken Loans
Address: 635 Woodward Ave.
Detroit, MI 48226
Phone Number: 800-508-0944
Contact Person: Ryan Ellison
Email Address: RyanEllison@QuickenLoans.com
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will
end your ownership of the mortgaged property and your right to occupy it. If you
continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and
your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -- You may or may not sell or transfer your
home 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 prior to or
at the sale and that the other requirements of the mortgage are satisfied. Please
contact the lender to find out if this option is available to you under the mortgage
and note.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE
MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER
LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING
ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION
AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE
DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE
YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR
YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY
FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE
TO SUCH ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY
LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING
YOUR COUNTY: see attached page (s)
HEMA.P Consumer Credit Counseling Agencies _
CUMBERLAND County
Rcporl last updated 09.+1812014 04:56 PM
Advantage Credit Counseling Service/CCCS of Western PA Community Action Commission of Capital Region
2000 Linglestown Road 1514 Derry Street
Harrisburg,PA 17102 Harrisburg,PA 17104
888.511-2227 717-232-9757
Housing Alliance of York/V Housing Resources N11aranatba
290 West:Market Street 43 Philadelphia Avenue
York,PA 17401 Waynesboro,PA 17268
717-845-2601 717-762-3285
PathStone Corporation PatbStone Corporation
1625 North Front St 450 Cleveland Ave
Harrisburg,PA 17102 Chambersburg,PA 17201
717-234-6616 717-264-5913
PA interfaith Community Programs Inc PHFA
40 E High Street 211 North Front Street
Gettysburg,PA 17325 Harrisburg,PA 17110
7t7-334-1518 717-780-3940 800-342-2397
EY, hibit
*Exhibit has been redacted to remove all personally identifiable information or non-public information
e
WHEN RECORDED MAIL TO:
Servicing Team
Quicken Loans Inc.
635 Woodward Ave
Detroit,MI 48226
LOAN AMOUNT:$91,500.00
Parcel#22-31-2156-015
j Min#:
MERS Phone: .`
I hereby certify Assignee's precise address is:
§3A Woodw ve,Detroit,MI 48226
(Sig ature)
Assignment of Mortgage
FOR VALUE RECEIVED,the undersigned,Mortgage Electronic Registrations Systems,Inc.,as nominee for
Quicken Loans Inc.,its successors and assigns,as("ASSIGNOR/GRANTOR"),whose address is P.O. Box 2026,
Flint,MI 4$501-2026,hereby grants,conveys,assigns to
Quicken Loans Inc.
("Assignee/Grantee")all beneficial interest under that certain Mortgage in the amount of$91,500.00,dated February
19,2014,and executed by: Douglas Black,a single man,borrower(s)to Mortgage Electronic Registrations
Systems,Inc.,as nominee for Quicken Loans Inc.,Its successors and assigns,Original Lender,certain
I Mortgage recorded in instrument No.201404020,recorded on February 26,2014,in the Official Records of Monroe
Township in Cumberland County,State of PA,covering the following described property:
915 Park P1,Mechanicsburg,PA 17055
PIN:22-31-2156-015
Together with the note or notes therein described or referred to,the money due and to become due thereon with
interest,and all rights accrued or to accrue under said Document.
Dated: 20�.
itness: Mortgage Electronic Registrations
1-AVONNA Systems,Inc.,as nominee for Quicken
Loans Inc.,its sgccessors and assigns
By:
Title:Assistant Secretary
W
I
STATE OF Michigan )
COUNTY OF Wayne )
On this,DeCernht'r ,20 1�,before me _Arnanrla .1 ��.,,u ,the undersigned officer,
personally appeared vibe,d I'd_W_ ,�e�r.H-,who acknowledged him/herself to be Assistant Secretary of
Mortgage Electronic Registrations Systems,Inc.,as nominee for Quicken Loans Inc.,its successors and assigns,and
that he/she as such,being authorized to do so,executed,the foregoing instrument for the purposes therein contained
by signing the name of the company by him/herself as Assistant Secretary.
In witness whereof, I hereunto set my hand and official seal.
t
�i
By:
Notary Pu lic,
Expires: I
AMANDAJ.BRUNETII;
NOTARY PUBLIC,STATE OF MI j
COUNTY OF LIYINQSTON i
MY COMMISSION EXPIRES Apr 6,201f
ACTING IN COUNTY OF
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