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HomeMy WebLinkAbout15-0022 S Supreme. Court of Pea n.sylvania Couiy�f(omamon Pleas , Far,PRothonorafT Use 0111r: �i Gover,Sheet t -} Js.�i r �45 "ire•. Cumberland- _ County >,oclne� �: �'Iv,lTm 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: R Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: PNC BANK,NATIONAL ASSOCIATION,SUCCESSOR SUSAN B.MCGLONE C IN INTEREST TO NATIONAL CITY REAL ESTATE DONALD L.MCGLONE T SERVICES LLC SUCCESSOR BY MERGER TO I Dollar Amount Requested within arbitration limits Q Are money Damages requested?: ❑ Yes ® No (Check one) X outside arbitration limits 1 Is this a Class Action Suit? ❑ Yes R NO Is this an MDJ Appeal? ❑ Yes R NO A Name of Plaintiff/appellant's Attorney:KML Law Grout),P.C. ❑ Check here if you are a Self-Rep resented(Pro Se Litigant Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection:Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation S ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include ❑ Statutory Appeal:Other E mass tort) ❑ Employment dispute: ❑ Slander/Libel.Defamation Discrimination ❑ Other ❑ Employment Dispute:Other T ❑ Other: 1 0 MASS TORT ❑ Other ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory ❑ Toxic Waste $ 13 Other ❑ Eminent Domain/Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus N Mortgage Foreclosure:Residential ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.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 NVW W.KDILLA W GRO1 TP.COM PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN THE COURT OF COMMON PLEAS IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES,LLC,SUCCESSOR BY MERGER TO OF Cumberland COUNTY NATIONAL CITY MORTGAGE,INC.,FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO. CIVIL ACTION-LAW 3232 Newmark Drive Miamisburg,OH 45342 ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. SUSAN B.MCGLONE No. J5-0600U bvil DONALD L.MCGLONE — � Mortgagor(s)and Record Owner(s) 1413 Silver Creek Drive :aV1L ACTIUN: MORTGAGI Mechanicsburg,PA 17050 FORECLOSURE 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 c � 2 Liberty Avenue `v i Carlisle,PA 17013 - c�nr"- -r 1 C:)r � C7 .. LEGAL SERVICES INC C-) o— 8 Irvine Row o 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 defenses 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 Q de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. 115.175 Pl��ATN C 784 658 0316io 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.org/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: hqp://Nvww.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@kmllawgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 139441FC. Para informacion en espanol puede communicarse con Loretta al 21.5-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is PNC BANK,NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST TO NATIONAL CITY REAL ESTATE SERVICES, LLC, SUCCESSOR BY MERGER TO NATIONAL CITY MORTGAGE, INC., FORMERLY KNOWN AS NATIONAL CITY MORTGAGE CO., 3232 Newmark Drive, Miamisburg, OH 45342. 2. The name(s)and address(es) of the Defendant(s) is/are SUSAN B. MCGLONE, 1413 Silver Creek Drive,Mechanicsburg, PA 17050 and DONALD L. MCGLONE, 1413 Silver Creek Drive, Mechanicsburg,PA 17050,who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On May 23, 2003 mortgagor(s)made, executed and delivered a mortgage upon the Property hereinafter described to NATIONAL CITY MORTGAGE CO, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on May 29, 2003 as BK: 1813, PG: 4618. 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"). S. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for July 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 as of 01/02/2015: PrincipalBalance..................................................................................$230,11.4.52 Interest from 06/01/2014 to 01/02/2015 at 5.0000%................................$6,743.19 Per Diem interest rate at$31.52 LateCharges ................................................................................................$282.90 Escrow/Impound Overdraft........................................................................$202.03 ProRata PMI..................................................................................................$96.72 UnpaidOther Fees.........................................................................................$68.00 InspectionCosts.............................................................................................$12.00 Appraisal........................................................................................................$85.00 $237,604.36 7. 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. 8. 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$237,604.36, together with interest at the rate of$31.52,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, including but not limited to attorney fees and costs, until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: AW GROUP,P.C. ichael McKeever Pa. ID 56129 ay 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, �I T JkA A S16rw , as a Authorized Signer , of PNC BANK, NATIONAL ASSOCIATION do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff, 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: D f r,1 011 PNC BANK,NATIONALASSOCIATION NAME: 00an�,� J r OW TITLE: '"`I Authorized Signer #139441FC-SUSAN B.MCGLONE and DONALD L.MCGLONE 141.3 Silver Creek Drive,Mechanicsburg,PA 17050 Eyh i i t A Ey,hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information i Y EMUBIT "A" _ 1 AM �MT CMTUV tract or parcel of land -situate in "ArApden Township, Cumbarland County, Pennsylvania, more particularly bounded and described as followa, to wit., a>laXomina at a point on the southern right-of-way line of Banseman Road, a 5d foot wide street:, said point also being the northeastern property car +ar of Lot /33 as shown on the final Phase 3 subdivision plan of Tur arty; Thence along the aoutheft rigbtwof-bray Tina of Sens;eman Road, NarC 82 dagroas 45 minutes 15 seconds East, a distance of 100.Do feet to a paint on the southern right-of-fray line of Sensanan Road, said paint also; bsinq the northwustern Carrier of Lot 0381 Thence along the wevtern propRrty line of Lot 4130, South 67 degrees 24 minutes 45 seconds Vast, a di.athnce of 96.00 fast to a pint on the northwestern progeny cornitr of Lot f3l, said point also being the southwedterh property corner oZ Lot 138;'Tttence along the western property line of Lot 037, South 57 degrees 44 n utei's 14 seconds West, a dista000 of 82.76 feet: to a point on the port eastern property corner or Lot 1<36, said point. also beiang the i Bout: waatern property corner of Lot #37; Thance along the northern property line of Lot 036, South 92 degrees 45 minutes 15 seconder West, a 41at4nca of 25.00 feet to a point on the northarn property line of Lot 136,i said point also being the southeastern corner of Lot 13,1; Thence along the eastern property line of Lot 1E33, North 07 degrees 14 minutes 45 slaaohdg West, a distance of 125.00 feet to a point on the southern righrr-of-way line of Sonsetaan Road, said point being the point and place of ginning. . I . 1 -- i _ REPRESENTATION OF PRINTED DOCUMENT 10/20/2014 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 foreclosei Specific information about the nature of the default is: provided in 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 WITHA CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you 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) 780-1869.) 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 NOTIFICAC16N 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. INTERNET REPRINT REPRE ED PN C USPS CERTIFIED MAIL MORTGAGE' 9207 1969 0043 7100 0260 9325 52 9-749-07573-0000002-001-01-000-000-000-000 SUSAN B MCGLONE 1413 SILVER CREEK DR MECHANICSBURG, PA 17050 Please find enclosed the ACT 91 NOTICE for Loan Number=472 This is an attempt to collect a debt and/or enforce our lien.Any information obtained will be used for that purpose unless prohibited by applicable law. However, if this debt has been discharged or if you are protected by the automatic stay in bankruptcy,we are not attempting to collect the debt from you personally,and if we have obtained relief from the automatic stay,we will only exercise our rights against the property itself.By providing this notice we do not waive any applicable exemptions from state or federal collection laws. If you are requesting loss mitigation, please note that normal collection and/or foreclosure activity will continue on your loan to the extent allowed by law while your request is being reviewed.Any information requested may be necessary to determine your eligibility for loss mitigation options. DR671/10/20/2014/0002202472 To request information or notify us of an error regarding your account,please send a written request/notice to: PNC Mortgage; PO Box 8807;Dayton,OH 45401-8807 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT HOMEOWNER'S NAME(S): DONALD L MCGLONE SUSAN B MCGLONE PROPERTY ADDRESS: 1413 SILVER CREEK DR MECHANICSBURG,PA 17050 LOAN ACCT.NO.: =472 ORIGINAL LENDER: NATIONAL CITY MORTGAGE CO CURRENT LENDER/SERVICER:PNC Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FIN N LAL 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- HREE a3LDAYS 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 NOTI EAi D "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 telgphope numbers QLdesi ng ated consumer credit counseling_agencies �r the coun1y inwhich the property iLlocated are set forth at the end QL 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 APPLICATION ALSOON ASPOSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE �i)_ FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY,AS EXPLAINED ABOVE,IN THE SECTION CALLED"TEMPORARY STAY OF FORECLOSURE". INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT XQL—JHAVE THE RJQ T MFILE A- EMAPP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,BUT IF YOUR APPLICATION 1S EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S 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 AIN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT li T--The MORTGAGE debt held by the above lender on your property located at: 1413 SILVER CREEK DR' MECHANICSBURG,PA 17050 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $1,533.84 for 7/1/2014- 10/1/2014. Monthly Payments Accrued: $6,135.36 Late Charges Accrued: $226.32 Non-Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $12.00 Speedpay Fees: $32.00 TOTAL AMOUNT PAST DUE: $6,405.68 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 $6,405.68, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES W141CH 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: PNC Mortgage,A Division of PNC Bank,NA Attention:Collections Center 3232 Newmark Drive Miamisburg,OH 45342 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 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 property. 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 attorney's 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 you cure the default within the THIRTY(30)DAY period,you will not be required to pay attorney's fees OTHER LENDER REMEDIE --The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. LIGHT TO CURE THE DEFAULT PRIOR TO SHERIFFS SALE--If you have not cured the default within the THIRTY(30) DAY period and foreclosure proceedings have begun,y_ou still have the right to cure the default and prevent the sale at any time un to one hour before the Sheriff s Sale, You may do so by paying 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 mortgaee. 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 9 to 10 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 THF LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg, OH 45342 Phone Number: (800)523-8654 Fax Number: (855)201-6325 Contact Person: Collections Center E-Mail Address: LossMitigation@pncmortgage.com EFFECT OF SHERIFF' ALE--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 Sheriffs 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 X may not(CHECK ONE)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. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 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 1F 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 Advantage Credit Counseling Scrvice/CCCS of Western PA 2000 Linglestown Road Harrisburg,PA 17102 888-51.1-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg,PA 17104 717-232-9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York,PA 17401. 717-855-2752 Maranatha 43 Philadelphia Avenue Waynesboro,PA 17268 717-762-3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg,PA 17325 717-334-1518 PHFA 211 North Front Street Harrisburg,PA 17110 717-780-3940 800-342-2397 INTERNET REPRINT REPRE ejPNC USPS CERTIFIED MAIL MORTGAGE- 9207 1969 0043 7100 0260 9325 45 2-749-07573-0000001-001-01-000-000-000-000 DONALD L MCGLONE 1413 SILVER CREEK DR MECHANICSBURG, PA 17050 Please find enclosed the ACT 91 NOTICE for Loan Number=472 This is an attempt to collect a debt and/or enforce our lien.Any information obtained will be used for that purpose unless prohibited by applicable law.However, if this debt has been discharged or if you are protected by the automatic stay in bankruptcy,we are not attempting to collect the debt from you personally,and if we have obtained relief from the automatic stay,we will only exercise our rights against the property itself.By providing this notice we do not waive any applicable exemptions from state or federal collection laws. If you are requesting loss mitigation,please note that normal collection and/or foreclosure activity will continue on your loan to the extent allowed by law while your request is being reviewed.Any information requested may be necessary to determine your eligibility for loss mitigation options. DR670110120/2014/0002202472 To request information or notify us of an error regarding your account,please send a written request/notice to: PNC Mortgage; PO Box 8807;Dayton,OH,45401-8807 INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 10/20/2014 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 is provided in 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 you 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 1-860-342-2397. (Persons with impaired hearing can call (717)-780-1869). 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 NOTIFICAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA,PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA.SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIAN OBTENGA UNA TRADUCCION 1NMEDIATAMENTE 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. INTERNET REPRINT • REPRESENTATION OF PRINTED DOCUMENT HOMEOWNER'S NAME(S): DONALD L MCGLONE SUSAN B MCGLONE PROPERTY ADDRESS: 1413 SILVER CREEK DR MECHANICSBURG,PA 17050 LOAN ACCT.NO.: =472 ORIGINAL LENDER: NATIONAL CITY MORTGAGE CO CURRENT LENDEPUSERVICER:PNC Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE-FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR ROME 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 tMI DAYS OF THE RATE OF THIS NOTICE. ILYOU U IQ NOT APPLY' FOR_ EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE yOU MORTGAGE DE AJU T",EXPLAINS now To uuING yoUg Mo TGAGE 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 e COUDly in whichthe property �LQcated 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 APPLICATION AS_SOON POSSIBLE, IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING,THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE,IN THE SECTION CALLED"TEMPORARY STAY OF FORECLOSURE". INTERNET REPRINT m REPRESENTATION OF PRINTED DOCUMENT YOU HAVE THE RIGHTTFILE &HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS_ A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION,BUT IF YOUR APPLICATION 1S EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S 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 (Bring it up to date). NATURE OF THE D WA Ii T -The MORTGAGE debt held by the above lender on your property located at: 1413 SILVER.CREEK DR MECHANICSBURG,PA 17050 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following' amounts are now past due: $1,533.84 for 7/1/2014- 10/1/2014. Monthly Payments Accrued: $6,135.36 Late Charges Accrued: $226.32 Non-Sufficient Funds: $0.00 Fax Fees: $0.00 Property Inspections: $12.00 Speedpay Fees: $32.00 TOTAL AMOUNT PAST DUE: $6,405.68 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 $6,405.68, 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 money9rder made payable and sent to PNC Mortgage,A Division of PNC Bank,NA Attention: Collections Center 3232 Newmark Drive Miamisburg,OH 45342 INTERNET REPRINT 0 REPRESENTATION OF PRINTED DOCUMENT IF YOU DO NOT CURE THE D FAU T--If you do not cure the default within THIRTY(30)DAYS of the date of this Notice, the lender jut—emds 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 roperty W THE ORTGAGE.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 attorney's 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 you cure the default within the THIRTY(30)DAY period,you will not be required to pay attorney's fee s. 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 un to one hour before the Sheriffs Sale You may d_.o soby paying"the total amount then a t due,plus any late or other charges then due,reasonable attome 's fees and costs connected with the eclosure sale and any other costs connected with the Sheriffs Sale a ecified in writin by Der o p gay the lender and any other requirements under the mortgage 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. EARL IFST POSSI LE HERIFF' ALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 to 10 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 TOC TACT TUE LENDER: Name of Lender: PNC Mortgage Address: 3232 Newmark Drive Miamisburg, OH 45342 Phone Number: (800)523-8654 Fax Number: (855)201-6325 Contact Person: Collections Center E-Mail Address: LossMitigation@pncmortgage.com EFFECT OF HERIFF'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 X may not(CHECK ONE)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. INTERNET REPRINT • REPRESENTATION OF PRINTED DOCUMENT YOU MAY ALSO HAVE T E 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 1F 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 COUNSEL LN AGENCIES SERVING YOUR COUNTY Advantage Credit Counseling Service/CCCS of Western PA 2000 Linglestown Road Harrisburg,PA 17102 888-51.1-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg,PA 17104 717-232-9757 Housing Alliance of York/Y Housing Resources 290 West Market Street York,PA 17401 717-855-2752 Maranatha 43 Philadelphia Avenue Waynesboro,PA 17268 717-762-3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg,PA 17325 717-334-1518 PHFA 211 North Front Street Harrisburg,PA 17110 717-780-3940 800-342-2397 INTERNET REPRINT Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF ICE F;rr w�:.FW' =1 'n I5 j;:rr j' P f 6' i •-,,i.1M BFRL[ dD C;C,i.1tK FENHSYLVANIA PNC Bank, National Association, Successor in Interest to National City vs. Susan B. McGlone (et al.) Case Number 2015-22 SHERIFF'S RETURN OF SERVICE 01/06/2015 05:50 PM - Deputy Jamie DiMartile, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Donald L. McGlone at 1413 Silver Creek Drive, Hampden Township, Mechanicsburg, PA 17050. cUk A IE DIMARTILE, DEPUTY 01/06/2015 05:50 PM - Deputy Jamie DiMartile, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Donald McGlone, Husband , who accepted as "Adult Person in Charge" for Susan B. McGlone at 1413 Silver Creek Drive, Hampden Township, Mechanicsburg, PA 17050. auk kao marr±oL AIE DIMARTILE, DEPUTY SHERIFF COST: $55.50 SO ANSWERS, January 07, 2015 RON-3 R ANDERSON, SHERIFF (c) CcuntySuite Sheriff, Teleosott, Inc.