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Home My WebLink About15-0040 o s Y VDor-ket1\To=: Use CUMBERLAN �•: �=�' yI -.f��<=fir•;= � The ir�ornuttion collected on this form fs used solely for court administration purposes: This fornz does not supplement or replace the151ing and service of pteadings or other papers as r equir ed by lm.v or rules of court Com�nencemeut of Ammon- a Petition. M1 Complain:`. 03 WritofSummons D�Iaration of.Taking Transfer ff om Another Jurisdiction . I,eadPlaintiff'sName- U S, BANK, NATIONAL izarlDeiFxidant'sName: (C SSOCIATION TRUSTEE FOR THE TINA M. LAFORCE T Dollar AmountR.eques within arbitration limits L Are maneg dmages;requested? M Yes M No (check one) 10outside arbitration limifs 0 a 'lass�4ci ore�' `? EjYes NO 19 this a�MDf�ipea j? El Yes• No Name of PIaintifstApp eilant'sAttomey: Leon P. Haller Cltee£sltere ifyou haveno:attotiley(area SeI€Repr'esented tFro Eel Dant) Na{> re of e€te base: Plaee an"Xy to the left of the ONE case category that most accurately describes your 'PRUfqR y CASH If you are making more than one type of claim,check the orle that you consider most important. CONTRACT(do not f Wude.ludgmsau's) CW1 APPEAES TORT(do not wdude Nass T oM [i Buyer Plaintiff Administrative Agmeies 13 Intentional 0 Debi Collecii4n:CreditCard - Board ofAssessment Malicious Prosecution Board of Elections Q Motor Vehicle DebtCoIIection:Other ri DepL ofTran*ortaflon. Nuisance R-3Statutory Appeal:Offer 13 premises Liability . --: ,�►` Fj ProductLiability(does not include Ej EmploymentDispuW- mass tort) Discrimination Ej SlandedLibel/Defamafion EmploymmtDisputa:Outer ZoningBoard C E-3 Other: E3 Other_ T El Cnher. MA-SS ORT Ej Asbestos N E3 Tobacco Q ToidcTort-DES IYffSCE EOUS e JeTort-Implant RE&LFROPERTY �Common Law/Statutory Afbit ation 0 T- 9 Ejectment O EminentDomainlCondeumation ®Declaratory Judgment -GioundReat . F1 Mandamus Q Landlord/TenautDisputa [3Non-DomesficReIatzons MMortgageForeclosure:Residential Res't�in�Order PROF�SIQ�NAL�T� L�, ' n MortgageForeclosure:Commercial �Quo Warranto Partition Replevin 0 Dental 0 Quiet Title ®Other: Legal Ej Otber: Medical Other Professionsl: 'Updated L1112011 Ir Leon P. Haller,Esquire,�. {,`► Purcell,Krug&Haller ; 8 1719 North Front Street Harrisburg,PA 17102 717.234.4178 mtg@pkla.com U.S. BANK NATIONAL ASSOCIATION,AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING OF CUMBERLAND COUNTY,PENNSYLVANIA FINANCE AGENCY, Plaintiff CIVIL ACTION -LAW vs. ACTION OF MORTGAGE FORECLOSUR E Defendant TINA M. LAFORCE, �O '1)ol s— a00g6) THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS,ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED,O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES,LA COUTE PUEDE, SIN NOTIFICARIO,DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO 1MMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL"LAWYER REFERENCE SERVICE"(SERVICIO DE REFERENCIA DE ABOGADOS), (215)238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET 1-dllJ ys�QI CARLISLE,PA ]7013 717-249-3166 UUU""""""''��, U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE TINA M. LAFORCE, Defendant COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust Indenture dated as of April 1, 1982 and as amended by Supplemental Indenture of Trust dated March 1, 2007, is acting through the Pennsylvania Housing Finance Agency ("Agency"), its appointed Limited Power of Attorney, with an address of 211 North Front Street, Harrisburg, Pennsylvania 17101. The Limited Power of Attorney executed October 4, 2006 between the Plaintiff and the Agency is recorded in the Recorder of Deeds Office of the within County and Commonwealth on October 11, 2006 in Book 0731 Page 0421. The Limited Power of Attorney is incorporated herein by reference pursuant to Pa.R.C.P. 1019(g). 2. Defendant, TINA M. LAFORCE, is an adult individual whose last known address is 232 W. DAUPHIN STREET, ENOLA, PA 17025. 3. On or about, September 30, 2004, the said Defendant executed and delivered a Mortgage Note in the sum of$84,333.00 payable to WAYPOINT BANK, which Note is attached hereto and marked Exhibit «A„ 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on October 6, 2004 in Mortgage Book 1883, Page 1894 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid County on October 6, 2004 in Mortgage Book 712, Page 410. The Mortgage was further assigned to U.S. BANK,NATIONAL ASSOCIATION, TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording, which Assignment is attached hereto and marked Exhibit`B". The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 232 W. DAUPHIN STREET, ENOLA, PA 17025 and is more particularly described in Exhibit"C" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that the Mortgagor has failed to pay the installment due on October 01, 2013 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $70,383.19 Interest at $9.53 per day $4,936.54 From 09/01/2013 To 02/01/2015 (based on contract rate of 4.8750%) Accumulated Late Charges $285.60 Late Charges $17.85 From 10/01/2013 to 02/01/2015 Escrow Deficit $2,029.53 Attorney's Fee at 5% of Principal Balance $3,519.16 TOTAL $81,154.02 "Together with interest at the per diem rate noted above after February 01, 2015 and other charges and costs to date of Sheriff's Sale. 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 the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendant by letters dated February 11, 2014, as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the February 11, 2014, Act 6 Notices is attached hereto and marked Exhibit"D". 9. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 10. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Service Members Civil Relief Act, as amended. A copy of the website report from the Department of Defense Manpower Data Center, confirming non-active military duty is attached as Exhibit"E". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 4.8750% ($9.53 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By: PU ELL, KR G & HALLER Leon P. Haller, Esquire I.D. # 15700 Jill M. Wineka I.D. #58802 Attorneys for Plaintiff 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) U.S. BANK NATIONAL ASSOCIATION, AS IN THE COURT OF COMMON PLEAS TRUSTEE FOR THE PENNSYLVANIA HOUSING CUMBERLAND COUNTY, PENNSYLVANIA FINANCE AGENCY, Plaintiff CIVIL ACTION LAW VS. ACTION OF MORTGAGE FORECLOSURE TINA M. LAFORCE, Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period,the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff �L1 Multistate NOTE FHA Case No. 441-7567849 September 30th, 2004 [Date] ; . .. _ MIN. 232 W Dauphin Street, Enola, PA 17025 [Property Address] /104 1.PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender"�means WAYPOINT BANK and its successors and assigns. 2. BORROWER'S.p1tOSE TO PAY;INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of Eighty Four. Thousand Three'Hundred Thirty Three and no/100. Dollars(U.S. $ 84,333.00 ), plus interest,to the order of Lender. Interest will be charged on unpaid principal; from the date of disbursement of'the loan proceeds by Lender, at the rate of Pour and seven eighths percent( 4.875 %)per year until the,full amount of principal has been paid. 3.PRONIISE TO PAY b"ECURED Borrower's promise to pay is secured by a mortgage, deed of trust or.similar security instnunent that is dated`tfie same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which mi&Umsult if Borrower defaults under this Note. .MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on November 1st 2004 Any principaland interest.remaining on the first day of. October 2034 , will be due on that date, which is called the "Maturity Date." ' (B) Place Payment shall be made at P. O. Box 1711, Harrisburg, PA 17105 or at such place as Lender may designate in writing . by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of.U.S. $ 446.30 . . This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower.together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the all were a part of this Note. [Check applicable box] ❑Graduated Payment Allonge ❑Growing Equity Allonge ❑other [specify] 5.BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If.Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the writing to those changes. monthly payment unless Lender agrees in �o -1R 10210) FHA Multistate Fixed Rate Note-10195 VMP MORTGAGE FORMS-(800)521.7291. ' Page 1 of 2 Initials: 1 ' '" N 6. BORROWER'S FAILURE TO PAY (A)' Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent( 4.00' %)of the overdue amount of each payment: (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued.iriierest. Lender may-choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in ihis'Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable. law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7.WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to.demand payment of amounts due. "Notice of dishonor" means the: right to require Lender to give notice to other-persons that..amounts due have not been paid. 8. GIVING OF NOTICES Unless'applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering:it or by mailing it by first class mail to Borrower at the property address above or at a different address.if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this.Note will he given by first class mail to Lender at the address stated in Paragraph 4(B)or ata different address if Borrower is given a notice.of that different address. 9..OBLIGATIONS OF PERSONS UNDER THIS NOTE ' If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this.Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note maybe required to pay all of the amounts owed under this Note: BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. (Seal) (Seal) C Tina.M LaFoorceY ' -Borrower -Borrower (Seal) (Seal) . . -Borrower -Borrower ' N(sSIANCr r_cnirw (Seal)' PA -Borrower -Borrower AXRr� BANK Name: ��``''�� O -GH y��G (Seal) (Seal) Tit e' -Borrower -Borrower -IR (02101 Page 2 of 2 Prepared by&Return to: U.S.Bank National Association c/o PHFA-Loan Servicing Division 211 North Front Street,P.O. Box 15057 Harrisburg,Pennsylvania 17105-5057 717-780-3800 or 1-800-346-3597 PIN/ID Number: 09140832202 1232842 Above space is intentionally left blank for recording data. ASSIGNMENT OF MORTGAGE For value received,PENNSYLVANIA HOUSING FINANCE AGENCY("PHFA"),hereby grant,sell,convey, assign and deliver unto the U.S.BANK NATIONAL ASSOCIATION,(Trustee for the Pennsylvania Housing Finance Agency,pursuant to a Trust Indenture dated as of April 1, 1982),its successors and assigns,the following described Mortgage,together with the Note secured thereby Name of Original Mortgagor(s): TINA M.LAFORCE Secured by the real property located at: 232 WEST DAUPHIN STREET,ENOLA,PA 17025 Municipality of: TOWNSHIP OF EAST PENNSBORO Original Mortgagee: WAYPOINT BANK(NOW KNOWN AS SOVEREIGN BANK FSB) Original Principal Amount:$84,333.00 County Recorded in: CUMBERLAND Mortgage Recorded: October 6,2004. Book 1883 Page 1894 Instrument#: 40752 Last Assignment to: PA Housing Finance Agency Book 712 Page 410 Instrument#: 40753 IN WITNESS WHEREOF,the said Pennsylvania Housing Finance Agency,has caused this Assignment of Mortgage to be executed by its duly authorized officer. (Series: 085) MiNEO DATED: October 20,2014 By: PENNSYLVANIA HOUSING FINANCE AGENCY Thomas F.Brzana,Jr. Director of Loan Servicing Division COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this,the e.D ay of� 14,before me,'the undersigned officer,personally appeared Thomas F.Brzana,Jr.,Director of Loan Servicing Division.,an authorized officer of the Pennsylvania Housing Finance Agency,and acknowledged that he,being authorized to do so,executed the foregoing instrument for the purposes therein contained. In witness whereof,I have hereunto set my hand and official sea]. tt VMN4 L Notary Public IMFt �!ttv ..^ 60 r04N.VLVAN1A Notarial Seal Kimberley F.Ayala,(Votary Public Clty wE HaMsburg,Dauphin County My Commisslon expires Jan.15,2015 CERTIFICATE OF RESIDENCE OF ASSIGNEE MEMBER,PEf4NSYLVANIA AS50QATXON OF NOTARIES I certify that the principal business and mailing address for this assignment and assignee is: U.S.Bank National Association,c/o PHFA-Loan Servicing Division 211 North Front Street,P.O. Box 15057,Harrisburg, Pennsylvania 17105-5057 Authorized Officer k L ALL THAT CERTAIN tract or,parcel Of lead and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point in the southerly line of Dauphin Street at the distance of 183.381 (erroneously referred to in Deed Hook R-33, Page 221 as 183.31) feet measured eastwardly, .along said line of Dauphin Street from its intersection with ,the easterly line of Brick "Church Road; extending thence along the said southerly ling of Dauphin Street, North 79 degrees 40 minutes East, 46 feet; thence South 10 degrees 20 minutes East, passing through the middle line of the party wail between the house on this lot and the house Of the lot adjoining on the East, 117.505 feet; thence South 79 degrees 40 minutes West, 46 feet; thence North 10 degrees 20 minutes West, 117.505 feet to the place of BEGINNING. HAVING THEREON ERECTED the western half of a double dwelling house known as 232 Dauphin Street, Enola, •Pennsylvania, 17025. UNDER AND SUBJECT to all applicable restrictions, reservations, easements and rights of way of record. T Certify this to be recon d-d Tn Cumberland COU-311 V PA. `? I..,' .. _ . i , Pennsylvania Accounting & Loan Serviciin Housing Finance Agency 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17105-5057 (800) 346-3597 FAX(717) 780-3853 TTY(717) 780-1869 CERTIFIED MAIL- RETURN RECEIPT REQUESTED 2/11/2014 RE: Account No. 1232842 TINA M. LAFORCE 232 W DAUPHIN ST ENOLA, PA 17025-2209 RE: 232 W DAUPHIN ST ENOLA, PA 17025-2209 Dear Occupant(s): NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by PENNSYLVANIA HOST N ENOLA,A NPA AGENCY GEN Y( he einafINtS R OUS We, Us or Ours) on your property located at 232 W DAUPHIN DEFAULT because you have not made the monthly payments of $597.00 for 10/2013 through 2/2014 for a total of $2,994.00. Late charges and NSF charges that have accrued to this date in the amounts of $71.40 and $.00 respectively, are due. Completed) lesstotal any funds we are holding in suspense(including The inspections and securing that needed to beas of total amount now required to cure this default, or in other words, get caught up 'in your payments, the date of this letter is$3,105.40. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the total amount of $3,105.40, plusnyadditional monthly made ether byexpenses cash naoarloffice,acashier'srges tccheck, h may fall due during this period. Such p Yme t must be certified check or money order and made at: PENNSYLVANIA HOUSING FINANCE AGENCY 211 NORTH FRONT STREET/P.O. BOX 15057 HARRISBURG, PA 17105-5057 1-800-822-7375 or TTY (800) 346-3597 If you do not cure the default within THIRTY (30) DAYS, We intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original unt of default is not made within THIRTY mortgage in monthly installments. If full payment of the amo (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgageed property. If the mortgage is foreclosed, your mortgage property will be sold by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees, even if they are over$50.00. Any attorney's fee will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty-day period, you will not be required to pay attorney fees. Lv�) Emg ji-*-j FH AACT/dtmdocs/ALSV/ We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty-day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the sheriffps foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments and any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately five months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-822-7375. This payment must be made payable in cash in our office, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. You have the right to assert in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents, the nonexistence of a default or any other defense you believe you may have to any such action. If you maintain credit, life or disability insurance in connection with your mortgage loan, your failure to pay premiums with your payments may have already resulted or may result in the future in the lapse or a cancellation of that insurance by the insurance company. If the insurance lapses or is cancelled, reinstatement of the loan will not reinstate the insurance, and you will have to apply to the insurance company and qualify for replacement insurance if you wish to retain it. If you make partial payments on account of the delinquencies, we may accept them and apply them to the delinquencies. However, such partial payments will not cure your default or reinstate your loan. The loan will not be reinstated unless we receive the entire amount required to cure the default. Sincerely, -le", L. ce_'-, Mr. Thomas L. Gouker Manager of Collections PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street/P.O. Box 15057 Harrisburg, PA 17105-5057 TLG/ • FHAACT/dtmdocs/ALSV/ Pennsylvania Housing Finance Agency Accounting & Loan Servicing 1 211 North Front Street, P.O. Box 15057 Harrisburg, PA 17105-5057 (800) 346-3597 FAX(717) 780-3853 TTY(717) 780-1869 NOTICE 2/11/2014 TINA M. LAFORCE 232 W DAUPHIN ST ENOLA, PA 17025-2209 RE: Account #1232842 TO: TINA M. LAFORCE 232 W DAUPHIN ST ENOLA, PA 17025-2209 FROM: PENNSYLVANIA HOUSING FINANCE AGENCY The Federal Housing and Development Act of 1987 (as amended) directs creditors to notify homeowners who are delinquent in their mortgage obligation of the availability of homeownership counseling provided by nonprofit organizations approved by the Secretary of the Department of Housing and Urban Development ("HUD") and experienced in the provision of homeownership counseling. Attached is a current list of HUD-approved counseling agencies for Pennsylvania. If these agencies are not near you, you can call HUD's toll free number (800) 569-4287 for financially distressed mortgagors for information concerning HUD-approved housing counseling agencies. Attachment: Housing Counseling List FHAACT/dtmdocs/ALSW r *** PLEASE BE SURE THE AGENCY OF YOUR CHOICE SERVICES YOUR COUNTY *** CCCS OF WESTERN PA-HARRISBURG NACA 2000 LINGLESTOWN RD. 1341 N DELAWARE AVE;SUITE 312 HARRISBURG,PA.17110 PHILADELPHIA,PA.19125 Phone:888-599-2227 Phone:888-297-5568 HOUSING ALLIANCE OF YORK PHILADELPHIA COUNCIL OF COMMINITY DEVELOPMENT 34 S.Duke St. ONE PENN CENTER;1617 JFK BLVD;SUITE 1550 York, PA 17401-1106 PHILADELPHIA,PA.19103-1828 Phone:$00-864-4909 Phone:800-930-4663 TABOR COMMUNITY SERVICES 208 E King St. Lancaster,PA 17608-1676 Phone:717-397-5182 FHAACT/dtmdocs/ALSW ----------------•..---------- - --------------------------------------------------------------------------- --------------------- C j 2. Article Number COMPLETE THIS SECTIONON m � C A. Received by(Please Print Clearly) B. Date of Delivery t V S G : C. Signature ❑ ++ O W O i Agent fi fl. x ❑Addressee. O W , a jj 7196 9008 9111 1453 3998 D. Is delivery address different from item 1? ❑Yes D t Uj . II If YES,enter delivery address below: ❑No W �- LL O 3. Service Type CERTIFIED MAIL" i tQ V a j 4. Restricted Delivery?(Extra Fee) ❑Yes (3 i! 1. Article Addressed to: CD W prn ¢ TINA M LAFORCE c 3 y a 232 W DAUPHIN. ST m ZNia = r ENOLA, PA 17 025 ° L i0C I c) " m v Cl) Q :. :.. 1232842 KLIMEK �c 2tv 0 F- PS Form 3811,January 2005 Domestic Return Receipt I :JPPV — dQ M Z£Z :T?eW t t�= rod . VlON3 :JPpd glfjy y tr, VQ M Z£Z :doJd 76ttL : ew3 :T � drt3 :Z JJOe 3eTeuTZ :TrVRI,-- PannjddV _.OV m .Tdu3 £� E- �QVNIl :I JJ08 MLn .. 21" W to 0 )13WI1)I :d0 £T. -q P4H Cq O � � G �£ZI000 #ueo-1 8h fsi W Y N m Z m ,� _ )13WI1)1 S( f�t(J� x. i hr1 � ',� rh ups u > ,o d ZO-098AHS CI�rIV(,�� G7� tee..., � � �, � � N $ m 'm "N m Joo oe'(0 1L!/I G7ep Q a, H rl N ti N v y O '. Jas(1 ! y--- a rn C3 ca (D AeAeTdSt Cr N v, • MLA TSSOLLS L. V $ 9 ci cc ¢ N Q. Q- H N W W � M �• p W € �aU �? Z LL: ti EU¢ cz Q W W 1-� N Q a. cc cc cwn V z°S t-------------------------------------------------------------------- -------------•--•---- ------------ w- - Department of Defense Manpower Data Center Results asoi:Nov-24.201407:SCR AM SCRA 3.0 a �S taruL� Cpott r Pursuant.fo -Smice tiers Ci �1 e Last Name: LAFORCE First Name: TINA Middle Name: M. Active Duty Status As Of: Nov-24-2014 On Active Duty On Active Duty Status Date Active Duty Stan Date Active Duty End Date. Status Service Component NA NA No. NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA 'No NA This response reflects whether the individual or his/her unit.has received early.notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data.Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force, NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. A01 A Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 v U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct upon my personal knowledge and upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. PENNSYLVANIA HOUSING FINANCE AGENCY, Attorney-in-Fact for U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA HOUSING FINANCE AGENCY Dated Z �' By Thomas F. Brzana, Jr., Director of Loan Servicing for the Pennsylvania Housing Finance Agency, Attorney-in- Fact for U.S. Bank National Association, as Trustee for the Pennsylvania Housing Finance Agency LAFORCE 1232842 P01455/42546-14 FORM 1 ' �1 U.S. BANK, NATIONAL ASSOCIATION TRUSTEE FOR THE PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF HOUSING FINANCE AGENCY1- CUMBERLAND COUNTY, PENNSYLVANIA j Plaintiff(s) VS. TINA M. LAFORCE 7 A CP „r. Defendants) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First,within twenty(20) days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you 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. *HIS PROGRAM IS FREE. Respectful) bnnitte : s, 1 � S �li Date Signature of Counsel for Plaintiff 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: Is the property for sale? Yes No Zip: ❑ ❑ Listing date: Realtor Name: Price:$ Realtor Phone: Borrower Occupied: Yes❑ No❑ Mailing Address(if different) City: State: Phone Numbers: Home: Zip: Office: Email: Cell: Other: #of people in household: How long? Mailing Address: City: State: Zip: c Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How.long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes and Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy?Yes❑ No❑ If yes,provide names,location of court,case number&attorney: Assets Amount Owed: Home: $ Value: Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1:Model: Amount owed: Year: Value: 'Automobile_ #2:Model: Amount owed: Year: Value: Other transportation(automobiles boats motorcycles) Model: Year:- Amount owed: Value: Monthly Income. Name of Employers: 1• Monthly Gross 2. Monthly Net Monthly Gross 3 Monthly Net Monthly Gross - Additional Income Description(not wages): Monthly Net 1. Monthly Amount: 2. Monthly Amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses•1Please only include expenses you are currently pavan ' EXPENSE AMOUNT Mortgage EXPENSE AMOUNT 2" Mortgage Food Car Payment(s) Utilities Condo/Neigh.Fees Auto Insurance Med.(not covered) Auto fuel/repairs Install.Loan Payment Other Prop.Payment,Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuii- Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes❑ No❑ If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Email: Fax: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes[ No F] If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company(Name): Contact: Phone: [/We, ` named authorize the above to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Borrower Signature Date Please forward this document along with the following information to lender an lender counsel: d V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter.explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement(if property is currently on the market) V COPY of 2 years of federal income tax returns V Copy of deed