HomeMy WebLinkAbout15-0133 Supreme Court, of Pennsylvania
Court.ofCorn.m.on Pleas For Prothonotary Use Only:
Ci.vil C -y-er*.Sh6e
Docket No:
County
b(S-&
The information collected on this form is used sole1j,for court administration purposes. This form does not
—supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S E Complaint El Writ of Summons El Petition
E E] Transfer from Another Jurisdiction [:] Declaration of Taking
C Lead Plaintiff's Name: Ve S- BANK NATIONAL Lead Defendant's Name:
vNk�
ASSOCIATION, AS TRUSTEE FOR THE PENNSYLVANIA L
T HOUSIN6 FINMCE AaENeY
Dollar Amount Requested: Owithin arbitration limits
Are money damages requested? El Yes El No (check one) Eloutside arbitration limits
0
Yes
N Is this a Class Action Suit? E] ED No Is this an MDJAppeal? I Yes 0 No
A Name of Plaintiff/Appellant's Attorney: Leon P. Haller/Jill M.Wineka
El Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant)
-Natu re-of the Case-:--Place-an-'-'.X"-to-the-left-of-the-O.N.E-case-categor-y-that-most-accurately-describes your---
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
El Intentional [I Buyer Plaintiff Administrative Agencies
E] Malicious Prosecution El Debt Collection: Credit Card El Board of Assessment
0 Motor Vehicle E] Debt Collection: Other E] Board of Elections
E] Nuisance El Dept.of Transportation
E] Premises Liability El Statutory Appeal:Other
S EJ Product Liability(does not include
mass tort El Employment Dispute;
IF, El Slander/Libel/Defamation Discrimination
C El Other: n Employment Dispute:Other 0 Zoning Board
T El Other:
I E] Other:
O MASS TORT
0 Asbestos
N n Tobacco
E] Toxic Tort-DES
E] Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
E] Toxic Waste El Ejectment 0 Common Law/Statutory Arbitration
B Other: Ej Eminent Domain/Condemnation E]Declaratory Judgment
El Ground Rent Ej Mandamus
El Landlord/Tenant Dispute El Non-Domestic Relations
El Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY El Mortgage Foreclosure:Commercial Quo Warranto
[-I Dental Partition 0 Replevin
E] Legal Quiet Title El Other:
E] Medical Other:
0 Other Professional:
Updated 11112011
F. _ ..
Leon P. Haller,Esquire
J1 J 1,�, - . 19
Purcell,Krug&Haller
1719 North Front Street 1 U;s.F Y
'
Harrisburg, PA 17102 r 'i'. r =_g i s i t
717.234.4178
mtg@pkh.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 FORECLOSURE
DARLENE L. ANDERSON, 4—
Defendant
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 IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO,LLAME AL"LAWYER REFERENCE SERVICE"(SERVICIO DE REFERENCIA
DE ABOGADOS),(215)238-6300.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
J
CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET
CARLISLE,PA 17013 �s 7j?d
717-249-3166 0—
CI� �� 3
T1) �, III 9-%
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
DARLENE L. ANDERSON,
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, DARLENE L. ANDERSON, is an adult individual whose last known address is 325
JUNIPER STREET, CARLISLE, PA 17013.
3. On or about, May 18, 2007, the said Defendant executed and delivered a Mortgage Note in the sum of
$98,455.00 payable to PHILADELPHIA FINANCIAL MORTGAGE a division of LEESPORT 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 May 30, 2007 in Mortgage Book 1993, Page 4322 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 May 30, 2007 in Mortgage Book
0737 Page 1566. The Mortgage was further assigned to U.S. BANK,NATIONAL ASSOCIATION,
TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid
County on March 8, 2013 instrument number 201315006. The said Mortgage and Assignments are
incorporated herein by reference.
5. The land subject to the Mortgage is: 325 JUNIPER STREET, CARLISLE, PA 17013 and is more
particularly described in Exhibit`B"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
April 01, 2014 and all subsequent installments thereon, and the following amounts are due on the
Mortgage:
UNPAID PRINCIPAL BALANCE $85,215.51
Interest at$13.02 per day $4,348.68
From 03/01/2014 To 02/01/2015
(based on contract rate of-5.5000%)
Accumulated Late Charges $664.92
Late Charges $21.67 $219.70
From 04/01/2014 to 01/01/2015
Escrow Deficit $184.07
Attorney's Fee at 5% of Principal Balance $4,260.78
TOTAL $94,893.66
"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 July 29, 2014, as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the July 29,
2014, Act 6 Notices is attached hereto and marked Exhibit"C".
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"D".
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned
total amount due together with interest at the rate of 5.5000% ($13.02 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:
PURC L,KRUG & 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
DARLENE L. ANDERSON,
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
portionthereof owirigao 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
Boom
01
Number; 124007043
NOTE
-'7 FHA CASE NO.
441-7940407 '
i
MAY 18, 2007 t
ED-)
325 JUNIPER STREET, CARLISLE, PENNSYLVANIA 17013
M.Pc d Address]
L PARTIES
'Borrowa'mant each person signing at the end of this Note,and the person's successors and assigns.'Lcndu"mean
PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK, A
PENNSYLVANIA BANKING CORPORATION
and its succcsmrs and assign',
2. BORROWER'S PROMISE TO PAYi Dri'EREST
In return for a loan received from(soder,Borrower promises to y the principal sum of NINETY-EIGHT
THOUSAND FOUR HUNDRED FIFTY-FIVE AND 0000 Dollars
(U.S.S 9 B,455.00 ),plias interest,to the order of Lender. Interest will be charged on unpaid principal,
from the date of dubursomem of the loan proceeds by lander,at the rate of FIVE AND 500/1000
pareem( 5.500 %)Per yar
until the full amount of principal has been paid.
3. PROMISETO PAY SECURED
Borrower's promise to pay is secured by a mortgage,decd of trust or similar security Instrument that is dated the same
date at this Note and called the'Sccority lastnaman0 The Security lrubument promets the Lender from louts which might
result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lander on the first day of each month beginning
on JULY 1, 2007 .Any principal and Interest remaining on the ftrstdsy of
JUNE 1, 2037 ,will be due on that&is,which is called the"Maturity Dam.'
(B) Place
Payment shall be made at 1757 SENTRY PARKWAY WEST, SUITE 220, BLUE BELL,
PENNSYLVANIA 19422
or at such other 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.S 559.02
This amount will be part of a larger monthly payment required by the Security bamareent,thu shall be applied to principal,
Interest art other items la she order deseno d in the Security Inshumem.
(D) Mlonge to this Note for Payment Adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note,the eoveaatxs of the
anongt shall be Incorporated into and shall amend and supplement the covenants of this Note as If the alloage were a part
of this Nate. (Check applicable box.)
❑Growing Equity Allonge ❑Graduated Payment AEonge
❑Other(apeeify)
S. BORROWER'S RIGHT TO PREPAY
Borrowm has the right to pay the debt evidenced by this Nae,In whole or In part,without charge or penalty,on the fust
day of any month. Leader shall accept prepayment on other 4ayaprovided diet Borrower pays interest on the amount prepaid
for the remainder of the month to the extent required by leader and permitted by regulations of the Socretary,if Borrower -
makes a partial pnpaymem,there will be no changes in the due date or In the amount of at monthly payment unless Lender
agrees in writing to those'changes,s1MTLSrArSFM Fnrrp PATE Nora(4tsa)
w w synw,u..mm«s.uu Age I of 2
(I Et
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6. BORROWER'S FAILURE TO PAY i
(A) Late Charge for Overdue Payments
If Leoda has not received the full monthly payment required by the Secur(ly Instrument,as described in Paragraph 4(Q
of this Now,by the cod of fifteen calendar days after me payment Is due,Lender may collect a lam charge m the amount of l
FOUR AND 0OD/1000 perocbt( 4.000 %) '
of time overdue amount of each payment,
(B) Default
If Borrower defanits by failing to pay is full any monthly payment,tbm Lender may,except as limited by regulations of
the Secretary in the case of payment defaults,requite immediate payment in fail of the principal balance remaining due and
all accrued interest. Lender.maychoose not to txtmiae this option without waiving its rights in the event of any subsequent
default. In many circnmsunces regulation.;issued by the Secretary will limit Isnder's rights to require immediate payment
in full in the case of payment defaults. This Note does not aumhorixe acceleration when not permitted by HUD regtda6les.
As used in this Nom,'Secretary'meant the Sccrcury of Housing and Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in fun,as described above,Lender may require Borrower to pay cons and
expenses including reasonable and customary atmmmys'fees for enforcing this Note to the extent not prohibited by applicable
law.Such fees and costs shall bear interest from the dale of disbursement at the same me 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. 'Prenecrocnt'means the right to require Leader to demand payment of amounts due. 'Notice of dishonor'means
the right to require Leader W give notice to other persons that amounts due have of been paid,
g. GiVO4G0FNOTICPS
Unless applicable law requires a different method,any notice that must be given to Borrower under this Note witlbe given
by delivering it or by mailing it by first class matt to Borrower at the property address above or at a different address if ,
Borrower oar given Lender a amlm of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated
in Paragraph 4(B)or at a 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 ml of the promises made
In this Note,including the promise to pay,the full amount owed. Any person who is a guarantor,surety or eodorser of this
Note is elm obligated to do these things. Any person who ukes over these obligations, including rhe obligations of a
m
guattor, =rely or endorser of this Nota,is also obligated to keep all of the prom@eg made in this Now. Lender may
enforce Its rights under this Note against each person individuallyor against all signatories together. Any one person signing
this Note may be required to pay all of the amounts owed under this Note.
.-_BY SIONINO BELOW,Borrowev accepts
Ann'dJd agrees to the terms and covenants contained in pages I and 2 of this Note.
_,�si2LIsNE L WOODAI L Bor war. Borrower
(Seal) (Sea])
-Borrower -Borrower
(Seat) (Sam)
-Borterwer -Borrower
WMT=AT8-FHA FDCM RA'r'E NUDE(Wid) -
mxa�.a a»s,s.w.tura us.uat Page 2 of 2
I
ALLONGE
Loan Number. 124007043 1
Loan Dace:MAY. 18, 2007
Borrower(s): DARLENE L WOODALL
I
Property Address:325 JUNIPER STREET, CARLISLE, PENNSYLVANIA 17013 1
I
I
Principal Balance$98,455.00
PAY TO THE ORDER OF
- pgRNSYLVARIA ROUSING FINANCE AGENCY
Without Recourse
Company Name: PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK
1
>�C/f J HDRTGAGE UNDERWOTING HAH M
BY` (Tido)
(Nafie)
DENISE DIGIDVARNI
N.OLTISTATE NOTE ALLONGEN+e��'S` d
03/08/07 NMw
� �,.. �sema�aeaavava
LEGAL DESCRIPTION
ALL that certain tract of land with the improvements thereon erected,situate in the Second Ward of the Borough of
Carlisle,Cumberland County, Pennsylvania,bounded and described as follows: /
BEGINNING at a point on the southern side of Juniper Street at the Northeast corner of Lot No 1 i A in the hereinafter
mentioned plan of Lots which point is located 120 feet from a concrete marker on the southerly side of Juniper Street;
thence North 20 degrees 40 minutes East along Juniper Street a distance of 30 feet to a point at the northwestern
comer of Lot 12A as shown said plan of lots;thence South 69 degrees 13 minutes East along Lot No. 12A a distance
of 125.30 feet to a point at lands now or formerly of Lightner; thence South 20 degrees 54 minutes West along land
now or formerly of Lightner,a distance of 30 feet to a point at the southeastern corner of Lot No 11 A as shown on
said Plan of Lots; thence North 69 degrees 13 minutes West along Lot No I 1 A a distance of 125.24 feet to a point on
the southerly side of Juniper Street being the point and place of BEGINNING.
BEING all of Lot No. 12 on a Subdivision Plan for Section No. 1 of Willow Crossing as recorded in Cumberland
County in Plan Book 25, Page 90.
PARCEL 403-22-0485-105
I
8
19 9:3 PG 4 3 3 2
i
Pennsylvania
Housing Finance Ageri .counting&Loan Servicing
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
7/29/2014
RE: Account No. 1579754
DARLENE L. ANDERSON
PO BOX 694
CARLISLE, PA 17013-0694
RE: 325 JUNIPER ST
CARLISLE, PA 17013-2525
Dear Occupant(s):
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by U.S. Bank National Association (hereinafter We, Us or Ours) on your
property located at 325 JUNIPER ST, CARLISLE, PA 17013-2525, IS IN SERIOUS DEFAULT because
you have not made the monthly payments of $1,040.00. for 4/2014 through 7/2014 for a total of
$4,160.00. Late charges and NSF charges that have accrued to this date in the amounts of $735.66
and $.00 respectively, are also due. The total listed below includes all fees (including inspections and
securing that needed to be completed) less any funds we are holding in suspense. 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 $7,814.69.
You may cure this default within THIRTY(30) DAYS of the date of this letter, by paying to us the
total amount of$7,814.69, plus any additional monthly payments, expenses and late charges which may
fall due during this period. Such payment must be made either by cash in our office, cashier's check,
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
mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY
(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.
`ti► v� v FHAACT/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 sheriff Ps 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,
Mr.Thomas L. Gouker
Manager of Collections
PENNSYLVANIA HOUSING FINANCE AGENCY
211 North Front Street/P.O. Box 15057
Harrisburg, PA 17105-5057
TLG/
FH AACT/dtmdocs/ALSW
Pennsylvania
Housing Finance Agen _ _:ounting & Loan Servicing
211 North Front Street, P.O.Box 15057
Harrisburg,PA 17105-5057
(800)346-3597 FAX(717) 780-3853
TTY(717) 780-1869
NOTICE
7/29/2014
DARLENE L. ANDERSON
PO BOX 694
CARLISLE, PA 17013-0694
RE: Account #1579754
TO: DARLENE L. ANDERSON
325 JUNIPER ST
CARLISLE, PA 17013-2525
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
*** 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:800-864-4909 Phone:800-930-4663
TABOR COMMUNITY SERVICES
208 E King St.
Lancaster,PA 17608-1676
Phone:717-397-5182
FH AACT/dtmdocs/A LSV/
I; 2. Article Number
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REFERENCE: 1579754 i 1579754
i PS Form 3800 January 2005
PS Form 3800 January 2005
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SERVICE Return Receipt Fee
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Department of Defense Manpower Data Center Results as of:Jan-05.201512:52:21 PM
SCRA 3.0
°}zE Status Report
{E Pursuant to Servicemembers Civil Relief Act
Last Name: ANDERSON
First Name: DARLENE
Middle Name: L
Active Duty Status As Of: Jan-05-2015
On Active Duty On Active Duty Status Date
Active Duty Start 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
i
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Dale 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 hislher 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.
�' 11111(01414— r
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
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
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
ANDERSON
1579754
P01455/42278-14
[tai �r°�}! —7 P ; 2= i
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA" 't'EN'iSYLVt1� IA
Plaintiff(s)
VS. ao�s 3
Defendants)
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action,you may be able to
participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer you must take the following steps to be eligible for a
conciliation conference. First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal
Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative,
at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal
representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal
representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If
you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will
prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days
of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled,you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender
before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to
be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that
a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format
attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed
with the Court within sixty(60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation
conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out
reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
Date Leon P. H:aller / Jill M. Wineka
Attorney.. for Plaintiff
Purcell, Krug and Haller
1719 North Front Street
Harrisburg PA 17101
PA ID 157 0a / 58802
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
v
Plaintiff(s)
VS.
Defendant(s) ``lb 0—
S�Civil
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as
follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion
Program: and has taken all of the steps required in that Notice to be eligible to participate in a
court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I understand that
statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket#
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance,your lender must consider your circumstances to determine
possible options while working with your
Please provide the following information to the best of your knowledge:
CUSTOMERIPRIMARY APPLICATION
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes❑ No❑ Listing date: Price:$
Realtor Name: Realtor Phone:
Borrower Occupied: Yes❑ No❑
Mailing Address(if different)
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people in household: How long?
Mailing Address:
City: State:. Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
#of people in household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage 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: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile#1:Model: Year:
Amount owed: Value:
Automobile#2: Model: Year:
Amount owed: Value:
Other transportation(automobiles,boats,motorcycles): Model:
Year: Amount owed: Value:
Monthly Income
Name of Employers:
1. Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3. Monthly Gross Monthly Net
Additional Income Description(not wages):
1. Monthly Amount:
2. Monthly Amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses:(Please only include expenses you are currently paving)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2" Mortgage Utilities
Car Payment(s) Condo/Neigh.Fees
Auto Insurance Med.(not covered)
Auto fuel/repairs Other Prop.Payment
Install.Loan Payment Cable TV
Child Support/Alim. Spending Money
Day/Child Care/Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income and Expenses:
Have you been working with a Housing Counseling Agency?
Yes❑ No❑
If yes,please provide the following information:
Counseling Agency:
Counselor:
Phone(Office): Fax:
Email:
f , A
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes❑ No ❑
If yes,please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company(Name):
Contact: Phone:
AUTHORIZATION
1/We, authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/we
understand that I/we am/are under no obligation to use the services provided by the above
named
Borrower Signature Date.
Borrower Signature Date
Please forward this document along with the following information to lender and
lender counsel:
V Proof on income
V Past 2 bank statements
V Proof of any expected income for the last 45 days
V Copy of a current utility bill
V Letter explaining reason for delinquency and any supporting documentation
V (hardship letter)
Listing agreement(if property is currently on the market)
V Copy of 2 years of federal income tax returns
V Copy of deed