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CIVIL COVER SHEET AND ENTRY OF APPEARANCE
DELAWARE COUNTY COURT OF COMMON PLEAS
1. Case Caption
PennyMac Loan Services, LLC. (Plaintiff)
v.
Manuel Rivera
2a. Plaintiff(s)
PennyMac Loan Services, LLC.
3043 Townsgate Road #200
Westlake Village, CA 91361
3a. Related Cases? Yes _X_No
4, Entry of Appearance
To the Office of Judicial Support:
Court Term & No.
2b. Defendant(s)
Manuel Rivera
726 Windermere Avenue
Drexel Hill, Pennsylvania 190261514
3b. Case Subject to Coordination Order? Yes _X_No
Ifyes, show Caption and Date of Order
Kindly enter my appearance on behalf of PennyMac Loan Services, LLC., (a)
plaintiff in this action. Papers may be served at the address sent forth below.
Margaret Gairo, Esq., Christine L. Graham, Esq., Esq., Nathalie Paul, Esq.,
Chelsea A. Nixon, Esq.
Attorney for party named above (Please Print)
MG #34419, MMC #87830, CLG #309480, JIF #314675, LMM #320589, CAN
#324130
Attorney ILD. Number
Is/ Chustine L Graham
Address: 123 South Broad Street, #1400
Philadelphia, PA 19109
Telephone: (215) 790-1010 Fax:(215) 790-1274
E-Mail:
11/10/2022
Attorney Signature
DateChoose only the one description which best reflects the principal type of case or relief sought from the list.
Case Description
APPEAL
Minor Court
Money Judgement
Landlord and Tenant
Code Enforcement
Personal Injury
Breach of Contract
Other
Local Agency
Civil Service
Motor Vehicle
Licenses and Inspections
Liquor Control Board
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Zoning Board
Other
Proceedings Commenced by Petition
Appointment of Arbitrators
Change of Name
Compel Medical Examination
Election Matters
Eminent Domain
Leave to Issue Subpoena
Mental Health Proceedings
Other
ACTIONS COMMENCED BY WRIT
OF SUMMONS OR COMPLAINT
Abuse of Process
Action for Wrongful Death
Class Action _
Confession of Judgement/Money
Confession of Judgement/
Real Property
Contract
Construction
Insurance/Bad Faith
Negotiable Instruments
Other
Intentional Tort
Assault and Battery
Libel and Slander
Defamation
Employment/Wrongful Discharge
False Imprisonment
Fraud _
Malicious Prosecution
Negligence
Motor Vehicle
Real Property
Premises Liability
Product Liability
Toxic Tort
Asbestos
DES
Implant
Toxic Waste
Other
Professional Malpractice
Dental
Legal
Medical
Other
Equity
Real Property
Stockholders Derivative Action
Waste Prevention
Other
Declaratory Judgement
Ground Rent
Mandamus
Real Property
Ejectment
Quiet Title
Mortgage Foreclosure
Mechanics Lien
Partition
Prevent Waste
Replevin
Saving Action Um/Uim
Quo Warranto
Other+ . Court OF COMMON PLEAS
DELAWARE COUNTY
THIRTY “SECOND JUDICIAL DISTRICT
‘COURTHOUSE.
NO:
Mevia, Det.AWARE COUNTY, PENNSYLVANIA
19063
Important Notice
Date of Service of this Notice:
(to be completed by the Sheriff's Deputy upon Service of Complaint)
Under a new Pilot Program sponsored by the Court of Common Pleas of Delaware County
and the Sheriff of Delaware County, you may be eligible to get help with your Mortgage.
Call the Save Your Home Hotline at 800-989-2227
To be eligible for any stay, you must be the owner or an heir to a deceased owner of the
property which is the subject of the Action of Mortgage Foreclosure and you must occupy the
property which is the subject of this Action of Mortgage Foreclosure as your principal residence.
You will discuss your mortgage foreclosure with an independent and professional Housing
Counselor who will work with you to review your finances and work with your lender to try and
resolve the mortgage foreclosure action. The Housing Counselor is available to you AT NO
CHARGE. Once you call this number, the Housing Counselor will contact the lender’s attorney
and the Court sanctioned thirty (30) day delay of the Action in Mortgage Foreclosure will go into
effect, all you have do is call.
You can have the Action of Mortgage Foreclosure delayed for up to thirty (30) days so that
you can participate in a conference with your Housing Counselor and submit a loan resolution
proposal to the lender and their attorney. This may assist you in saving your home from
foreclosure.
Call the Save Your Home Hotline at 800-989-2227
Make this call today to save your home. If you do not call within thirty (30) days from the
day this notice has been served on you or a member of your household by the Sheriff, you may
not be eligible for this program, but you may have other legal ways to delay the foreclosure
action.
22-101371IF YOU DECIDE TO USE THE SERVICES OF THE
HOUSING COUNSELOR MADE AVAILABLE BY THIS
PROGRAM, YOU SHOULD NOTE THAT THE SOLE
PURPOSE OF THIS PROGRAM IS TO PROVIDE
INFORMATION AND ASSISTANCE IN YOUR DESIRE
TO MAKE ARRANGEMENTS WITH YOUR LENDER
FOR THE MUTUAL RESOLUTION OF YOUR
INDEBTEDNESS. THIS IS A PUBLIC SERVICE
PROGRAM AND IS NOT IN ANY WAY A PROGRAM TO
PROVIDE YOU WITH LEGAL ADVICE OR LEGAL
SERVICES OF ANY KIND. NEITHER THE HOUSING
COUNSELOR NOR ANY PERSON OR ENTITY
ASSOCIATED WITH THE PROGRAM IS PROVIDING
OR WILL PROVIDE YOU WITH ANY INFORMATION
OR ADVICE CONCERNING ANY LEGAL REMEDIES,
LEGAL PROCEDURES, OBJECTIONS OR DEFENSES
TO THE CLAIM AGAINST YOU. THE PROGRAM AND
ANY PERSON OR ENTITY ASSOCIATED WITH IT
DOES NOT AND WILL NOT PROVIDE YOU WITH ANY
ATTORNEY OR LEGAL REPRESENTATION OF ANY
KIND.
22-101371NOTICE
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 this 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
claimed in the complaint or 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, 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.
Lawyers Reference Service
Delaware County Bar Association
335 West Front Street
Media, Pennsylvania 19063
(610) 566-6625
Rivera 22-101371
Complaint in Mortgage Foreclosure
AVISO
Le han demandado a usted en la corte. Si usted
quiere defenderse de estas demandas ex-puestas
en las paginas siguientes, usted tiene veinte (20)
dias de plazo al partir de la fecha de la demanda
y la notificacion. Hace falta asentar una
comparencia escrita 0 en persona o con un
abogado y entregar a la corte en forma escrita sus
defensas 0 sus objeciones a las demandas en
contra de su persona. Sea avisado que si usted
no se defiende, la corte tomaramedidas y puede
continuar la demanda en contra suya sin previo
aviso o notificacion.Ademas, la corte puede
decidir a favor del demandante y requiere que
usted cumpla con todas las provisiones de esta
demanda. Usted puede perder dinero o sus
propiedades u otros derechos importantes para
usted.
USTED LE DEBE TOMAR ESTE PAPEL
A SU ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE A UN ABOGADO, VA A
O TELEFONEA LA OFICINA EXPUSO
ABAJO. ESTA OFICINA LO PUEDE
PROPORCIONAR CON INFORMATION
ACERCA DE EMPLEAR A UN ABOGADO.
SI USTED NO PUEDE PROPORCIONAR
PARA EMPLEAR UN ABOGADO, ESTA
OFICINA PUEDE SER CAPAZ DE
PROPORCIONARLO CON INFORMACION
ACERCA DE LAS AGENCIAS QUE PUEDEN
OFRECER LOS SERVICIOS LEGALES A
PERSONAS ELEGIBLES EN UN
HONORARIO REDUCIDO NI NINGUN
HONORARIO.
Lawyers Reference Service
Delaware County Bar Association
335 West Front Street
Media, Pennsylvania 19063
(610) 566-6625
Page 1 of 6McCABE, WEISBERG & CONWAY, LLC
MARGARET GAIRO, ESQUIRE - ID # 34419
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
MARISA MYERS COHEN, ESQUIRE - ID #87830
ANDREW M. LUBIN, ESQUIRE - ID # 54297
CHELSEA A. NIXON, ESQUIRE - ID # 324130
NATHALIE PAUL, ESQUIRE — ID # 309118
123 South Broad Street, Suite 1400
Philadelphia, PA 19109
(215) 790-1010
Attorneys for Plaintiff
PennyMac Loan Services, LLC.,
3043 Townsgate Road #200
Westlake Village, CA 91361,
Plaintiff,
v.
Manuel Rivera
726 Windermere Avenue
Drexel Hill, PA 190261514,
Defendant.
Delaware County
Court of Common Pleas
Number:
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is PennyMac Loan Services, LLC., duly organized and doing business at
the above-captioned address.
2. The Defendant is Manuel Rivera, who is a mortgagor and real owner of the
mortgaged property hereinafter described, and his/her last-known address is 726 Windermere
Avenue, Drexel Hill, PA 190261514.
Rivera 22-101371 Complaint in Mortgage Foreclosure
Page 2 of 63. On July 20, 2018, Manuel Rivera, made, executed and delivered a Mortgage upon
the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as Nominee
for Mortgage Research Center, LLC dba Veterans United Home Loans which Mortgage is
recorded in the Office of the Recorder of Delaware County as Instrument Number 2018048027 in
Mortgage Book 06230, Page 0753 (“the Mortgage”), the Mortgage is incorporated herein by
reference pursuant to Pa.R.C.P. 1019(g).
4. On July 20, 2018, Manuel Rivera, also executed a promissory note secured by the
Mortgage (“the Note”). Plaintiff, directly or through an agent, is in possession of the Note and is
the holder of the Note with the right to enforce it; the Note is either made payable to plaintiff or
has been duly indorsed.
Bt On April 27, 2021, the Mortgage was assigned by Mortgage Electronic Registration
Systems, Inc., as Nominee for Mortgage Research Center, LLC dba Veterans United Home Loans
to PennyMac Loan Services, LLC., by assignment of mortgage, recorded in the Office of the
Recorder of Delaware County as Instrument Number 2021040947 in Mortgage Book 6694, Page
5365, said assignment of mortgage*is incorporated herein by reference pursuant to Pa.R.C.P.
1019(g).
6. The premises subject to the Mortgage is described in the legal description attached
as Exhibit “A” and is known as 726 Windermere Avenue, Drexel Hill, PA 190260000.
7. The Mortgage is in default because monthly payments of principal and interest
upon the Mortgage due January 1, 2021 and each month thereafter are due and unpaid, and by the
terms of the Mortgage, upon default in such payments for a period of one month, the entire
principal balance and all interest due thereon are collectible forthwith.
Rivera 22-101371 Complaint in Mortgage Foreclosure Page 3 of 68. The following amounts are due on the Mortgage:
Principal Balance $ 159,016.51
Interest through October 14, 2022 $ 14,829.89
(Plus $21.74 per diem thereafter)
Late Charges $ 495.32
Escrow Advance $ 10,198.79
Property Inspections $ 210.00
Title Search $ 290.00
GRAND TOTAL $ 185,040.51
plus additional interest and all other amounts authorized under the mortgage and applicable law
that are reasonable and have been incurred, including but not limited to costs, escrow advances,
and attorney's fees.
9. Pre-foreclosure notices were sent at least 33 days prior to the filing of this action.
A copy of said notice is attached hereto as Exhibit “B”.
WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of
$185,040.51, together with interest accruing thereafter; other costs and charges collectible under
the Mortgage and applicable law, including all reasonable and actually incurred attorney's fees and
costs; and the foreclosure and sale of the mortgaged property.
Date: 11/10/2022 McCABE, WEISBERG & CONWAY, LLC
py. /S! Chustone L. Grahame
{ ] Margaret Gairo, Esq. [ ] Marisa Myers Cohen, Esq.
[X] Christine L. Graham, Esq. [ ] Andrew M. Lubin, Esq.
{ ] Nathalie Paul, Esq.
[ ] Chelsea A. Nixon, Esq.
Rivera 22-101371 Complaint in Mortgage Foreclosure Page 4 of 6Attorneys for Plaintiff
Rivera 22-101371 Complaint in Mortgage Foreclosure Page 5 of 6VERIFICATION
Christine D'Angelo hereby states that he/she is__ Authorized Representative
of PennyMac Loan Services, LLC., Plaintiff in this matter, that he/she is authorized to make this
Verification, and verify that the statements of fact made in the foregoing Civil Action in
Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and
belief, The undersigned understands that this statement is made subject to the penalties of 18 Pa.
CS. Sec. 4904 relating to unsworn falsification to authorities.
ome jobelecs oat
Name: Christine D'Angelo
Title: Authorized Representative
File#; 22-101371
Name: PennyMac Loan Services, LLC. v. Manuel Rivera
Rivera 22-101371 Complaint in Mortgage Foreclosure Page 6 of 6Legal Description
‘File No: 11 7-0U4099
EXHIBIT A
ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon
erected, Situate in the Township of Upper Darby, County of Delaware and State of
Pennsylvania, bounded and described according to a Plan of Drexel Park Gardens, made for
Wamer West Corporation, by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania,
on December 16, 1941 and revised May 15, 1942, as follows, to wit:
BEGINNING at a point on the Southwesterly side of Windermere Avenue (40 feet wide) at
the distance of 169.8 feet measured Southeastwardly along the said side of Windermere
Avenue from a radius round corner whose radius is 25 feet the arc distance of 40.67 feet
from a point on the Southeasterly side of State Road (50 feet wide).
CONTAINING in front or breadth South 15 degrees, 53 minutes East along the
Southwesterly side of said Windermere Avenue 18 feet and extending of that width in length
or depth South 74 degrees, 07 minutes West between parallel lines at right angles 100 feet to
the middle of a 15 feet wide driveway {which extends Northwestwardly into State Road and
Southeastwardly into Highland Avenue). The Northwesterty and Southeasterly lines thereof
extending partly through party walls separating these premises from adjoining to the
Northwest and Southeast respectively.
TOGETHER with the free and common use, right, liberty and privilege of the aforesaid
driveways as and for a passageway in common with the owners, tenants and occupiers of the
adjoining lots of ground bounding thereon and entitled to the use thereof at all times hereafter
forever.
FOLIO NO. 16-09-01 509-00.
BEING the same premises which Theodore Sgro and Sandra Sgro, by Deed dated
06/16/2016 and recorded 06/22/2016 in the Office of the Recorder of Deeds in and for the
County of Delaware in Record Book 5829, Page 1213, granted and conveyed unto Keaton
Macut,
16-09-01509-00PennyMac Loan Services, LLC
PO Bax 9109
Temecula, CA 92589 9109
‘Send Payments to:
PennyMac Loan Services, LLC
PO Box 30597
Los Angeles, CA 90030 0597
‘Send Correspondence to:
PennyMac Loan Services, LLC
PO Bax 514387
Los Angeles, CA 90051 4387
EXHIBIT B
RETURN RECEIPT (ELECTRONIC)
MANUEL RIVERA
726 WINDERMERE AVE
DREXEL HILL, PA 19026
PRESORT
First Class Mail
US. Postage and
Fees Paid
wsoPennyM ac Notice Date: 02/25/2021
Sent Via Certified Mail
P.O. Box 514387 9314 8100 1170 10Sb 4571 79
LOS ANGELES, CA 90051 4387
MANUEL RIVERA Loan Number:
726 WINDERMERE AVE Property Address:
DREXEL HILL, PA 19026 726 WINDERMERE AVE
DREXEL HILL, PA 19026
NOTICE OF DEFAULT AND INTENT TO ACCELERATE
| ABOUT YOUR LOAN
This letter is formal notice by PennyMac Loan Services, LLC (herein as “PennyMac’”) that you are in default
under the terms of the documents creating and securing your Loan described above, including the Note and
Deed of Trust/Mortgage/Security Deed (“Security Instrument’), for failure to pay the amounts due.
[WHY YOU RECEIVED THIS NOTICE
The loan is due for 01/01/2021 and subsequent payments, plus late charges, and/or any escrow balance,
fees and costs. As of today, the total delinquency and reinstatement amount is $2,982.24, which consists of
the following:
Next Payment Due Date: 01/01/2021
Total Monthly Payments Due: $2,911.48
2 @ $1,455.74
Late Charges: $70.76
Other Charges: Uncollected NSF Fees: $0.00
Property Preservation Fees: $0.00
Property Inspection Fees: $0.00
Appraisals\Broker Price Opinion Fees: $0.00
Bankruptcy Fees: $0.00
Unapplied Balance: ($0.00)
TOTAL YOU MUST PAY TO CURE DEFAULT: $2,982.24
TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC
STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY
AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT AN
INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE REPRESENTED BY AN ATTORNEY,
PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE NUMBER.
Toll-Free: (866) 545-9070 Website: www.PennyMacUSA.com Payments: Correspondence:
MF 6:00AM 6:00 PM PT Secure Messaging Online: ‘Standard Address: Attn: Correspondence Unit
Sat 7:00AM 11:00 AMPT Create an account andior log in to P.O. Box 30597 P.O. Box 514387
Toll Free Fax: (866) 577 7205 hitp:/www.PennyMacUSA.com, Los Angeles, CA 90030 0597 Los Angeles, CA 90051 4387
then look for the Secured Message Overnight Address: (Please do not send payments)
Center to communicate with us securely. Attn: Lockbox Operations
20500 Belshaw Ave
Carson, CA 90746
(Please do not send correspondence)
GEN_NOL 52
Page 1 of 4 9314 8100 1170 1056 4571 79It is possible that after payment of the amounts detailed above there may be other fees still due and
owing, including but not limited to other fees, escrow advances or corporate advances that
PennyMac paid on your behalf or advanced to your account.
This letter is a formal demand to pay $2,982.24. If the default, together with additional payments that
subsequently become due, is not cured by 04/01/2021, the sums secured by the Security Instrument may be
accelerated, and PennyMac may invoke any remedies provided for in the Note and Security Instrument,
including but not limited to the foreclosure sale of the property.
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, PennyMac offers consumer assistance
programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are provided
without cost to our customers. You may be eligible for a loan workout plan or other similar alternatives. If you
would like to learn more about these programs, you may contact the Loss Mitigation Department at (866)
545-9070, 6:00 AM - 6:00 PM PT Monday through Friday and 7:00 AM - 11:00 AM PT Saturday. WE ARE
VERY INTERESTED IN ASSISTING YOU.
[ACTION REQUIRED
The default above can be cured by payment of the total delinquency and reinstatement amount plus any
additional payments and fees that become due by 04/01/2021. Note that in addition to the regular monthly
payments, additional charges, costs and fees may become due during the period between today’s date and
the date the aforementioned payments are due. You may contact our Collection Department at (866)
545-9070 to obtain updated payment information.
Please include your loan number and property address with your payment and send to:
PennyMac Loan Services, LLC
P.O. Box 30597
Los Angeles, CA 90030-0597
or Overnight:
PennyMac Loan Services, LLC
Attn: Lockbox Operations
20500 Belshaw Ave
Carson, CA 90746
If you wish to dispute the delinquency, or if you dispute the calculation of amount of the delinquency and
reinstatement amount, you may contact.us by calling (866) 545-9070, You may have the right to “cure” or
reinstate the loan after acceleration, and the right to assert in a foreclosure proceeding, or to bring a court
action to assert the non-existence of a default or any other defense to acceleration or foreclosure sale.
Failure to respond to this letter may result in the loss of your property. To the extent your obligation has been
discharged or is subject to the automatic stay in a bankruptcy case, this notice is for informational purposes
only and does not constitute a demand for payment or an attempt to collect a debt as your personal
obligation. If you are represented by an attorney, please provide us with the attorney's name, address and
telephone number.
|IMPORTANT INFORMATION
Attention Servicemembers and Dependents: Servicemembers on active duty, or a spouse or dependent
of such a servicemember, may be entitled to certain protections under the Servicemembers Civil Relief Act
(“SCRA”) regarding the servicemember's interest rate and the risk of foreclosure. SCRA and certain state
laws provide important protections for you, including prohibiting foreclosure under most circumstances. If
you are currently in the military service, or have been within the last (12) months, AND joined after signing
the Note and Security Instrument now in default, please contact PennyMac immediately. When contacting
PennyMac as to your military service, you must provide positive proof as to your military status.
Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate,
or their installation’s Legal Assistance Officer. Homeowner counseling is also available at agencies such as
Military OneSource (www.militaryonesource.mil; 1-800-342-9647) and Armed Forces Legal Assistance
http://legalassistance.law.af.mil), and through HUD-certified housing counselors
(http://www.hud.gov/offices/hsq/sfh/hcec/hes.cfm). You can also contact us toll-free at 1-866-545-9070 if you
have questions about your rights under SCRA.
GEN_NOI_52
Page 2 of 4 9314 8100 1170 1056 4571 79If you are experiencing financial difficulty, you should know that there are several options available to you
that may help you keep your home. You may contact a government approved housing counseling agency
which provides free or low-cost housing counseling. You should consider contacting one of these agencies
immediately. These agencies specialize in helping homeowners who are facing financial difficulty. Housing
counselors can help you assess your financial condition and work with us to explore the possibility of
modifying your loan, establishing an easier payment plan for you, or even working out a period of loan
forbearance. For your benefit and assistance, there are government approved homeownership counseling
agencies designed to help homeowners avoid losing their homes. To obtain a list of approved counseling
agencies, please call 1-800-569-4287 or visit http://www.hud.gov/offices/hsq/sfh/hec/hcs.cfm.
You may contact the Homeownership Preservation Foundation's Hope hotline at 1-888- 995-HOPE (4673). If
you wish, you may also contact us directly at (866) 545-9070 and ask to discuss possible options or visit our
website www.PennyMacUSA.com.
Pursuant to your loan documents, PennyMac may enter upon and conduct an inspection of your property.
The purposes of such an inspection are to (i) observe the physical condition of your property, and (ii) verify
that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default
prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not
limited to, winterization, securing the property, and valuation services) may be taken. The costs of the
above described inspections and property preservation efforts will be charged to your account as
provided in your security instrument.
PennyMac is attempting to collect a debt, and any information obtained will be used for that
purpose.
You are notified that this default and any other legal action that may occur as a result thereof may be
reported to one or more local and national credit reporting agencies by PennyMac.
| QUESTIONS? CONTACT US
If your loan is currently being evaluated for a loan modification, forbearance or other loan assistance
solution, this notice will not cancel or delay that evaluation process. However, it is important that you
promptly respond to all requests made in connection with your evaluation for a loan assistance solution,
including all requests for you to contact us and any documentation required. If you do not comply with these
requests in a timely manner, it may cause your loan to enter the foreclosure process as indicated in this
notice. If your loan is not eligible for a loan assistance program, please note this letter will continue to serve
as notice of our right to initiate foreclosure.
This matter is very important. Please give it your immediate attention.
Sincerely,
PennyMac Loan Services, LLC
3043 Townsgate Rd. Suite 200
Westlake Village, CA 91361
(866) 545-9070
GEN_NOL 52
Page 3 of 4 9314 8100 1170 LOSb 4S71 749In accordance with the Fair Debt Collection Practices Act, 15 U.S.C. section 1692 et seq., debt collectors are prohibited from engaging in
abusive, deceptive, and unfair debt collection efforts, including but not limited to: (j) the use or threat of violence; (ji) the use of obscene or
profane language; and (ii) repeated phone calls made with the intent to annoy, abuse, or harass.
NEW YORK Ifa creditor or debt collector receives a money judgment against you in court, state and federal laws prevent the following types
of income from being taken, to pay the debt: 1) Supplemental security income (SSI); 2) Social security; 3) Public assistance (welfare); 4)
Spousal support, maintenance (alimony) of child support; 5) Unemployment benefits; 6) Disability benefits; 7) Workers’ compensation benefits;
8) Public or private pensions; 9) Veterans’ benefits; 10) Federal student loans, federal student grants, and federal work study funds; and 11)
Ninety percent of your wages or salary earned in the last sixty days. PennyMac Loan Services, LLC is registered with the Superintendent of the
New York State Department of Financial Services (Department), You may obtain further information or file a complaint by calling the
Department's Consumer Assistance Unit at 1 800 342 3736 or by visiting www.dfs.ny.gov.
NORTH CAROLINA - Licensed by the North Carolina Department of Insurance. Permit No. 104753 6101 Condor Dr., Suite 200, Moorpark,
CA 93021. Permit No. 112228 14800 Trinity Blvd., Fort Worth, TX 76155. Permit No. 112874 3043 Townsgate Rd., Suite 200, Westlake
Village, CA 91361. Permit No. 112877 2201 West Plano Parkway, Suites 150 and 300, Plano, TX 75075. Permit No. 113746 10550 West
Charleston Blvd., Suite A, Las Vegas, NV 89135.
OREGON Residential mortgage loan servicers are regulated by the Oregon Division of Financial Regulation. To file a complaint, call (888)
877 4894 or visit http://dfr.oregon.gov.
This is an attempt by a debt collector to collect a debt and any information obtained will be used for that purpose. However, if your
account is subject to pending bankruptcy proceedings or if you have received a discharge in bankruptcy, this statement is for
informational purposes only and is not an attempt to collect a debt against you personally.
Licensing Information
@.... Housing Opportunity © 2008 2021 PennyMac Loan Services, LLC, 3043 Townsgate Rd, Suite 200, Westlake Village, CA 91361,
818 224 7442. NMLS ID # 35953 (www.nmisconsumeraccess.org). Trade/service marks are the property of PennyMac Loan Services, LLC
and/or its subsidiaries or affiliates. Arizona Mortgage Banker License # 0911088. Licensed by the Department of Financial Protection and
Innovation under the California Residential Mortgage Lending Act. Colorado: Colorado office: 700 17th St, Suite 200, Denver, CO 80202, (866)
436 4766. Georgia Residential Mortgage Licensee #33027. Massachusetts Mortgage Lender License # ML35953. Minnesota: This Is not an
offer to enter into an agreement and an offer may only be made pursuant to Minn. Stat. §47.206 (3) & (4). Licensed by the N.J. Department of
Banking and Insurance. Rhode Island Lender License # 20092600LL. Washington Consumer Loan License # CL 35953. For more
information, please visit www.pennymacusa.comV/state licenses. Loans not available in New York. Some products may not be available in all
states. Information, rates and pricing are subject to change without prior notice at the sole discretion of PennyMac Loan Services, LLC. All loan
programs subject to borrowers meeting appropriate underwriting conditions. This is not a commitment to lend. Other restrictions apply. All
rights reserved. (12 2020) FILED
11-10-2022 02:19 PM
GEN_NOL52 OFFICE OF sbiciaL suPPORT
DELAWARE COUNTY, PA
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CIVIL COVER SHEET AND ENTRY OF APPEARANCE DELAWARE COUNTY COURT OF COMMON PLEAS 1. Case Caption PennyMac Loan Services, LLC. (Plaintiff) v. Manuel Rivera 2a. Plaintiff(s) PennyMac Loan Services, LLC. 3043 Townsgate Road #200 Westlake Village, CA 91361 3a. Related Cases? Yes _X_No 4, Entry of Appearance To the Office of Judicial Support: Court Term & No. 2b. Defendant(s) Manuel Rivera 726 Windermere Avenue Drexel Hill, Pennsylvania 190261514 3b. Case Subject to Coordination Order? Yes _X_No Ifyes, show Caption and Date of Order Kindly enter my appearance on behalf of PennyMac Loan Services, LLC., (a) plaintiff in this action. Papers may be served at the address sent forth below. Margaret Gairo, Esq., Christine L. Graham, Esq., Esq., Nathalie Paul, Esq., Chelsea A. Nixon, Esq. Attorney for party named above (Please Print) MG #34419, MMC #87830, CLG #309480, JIF #314675, LMM #320589, CAN #324130 Attorney ILD. Number Is/ Chustine L Graham Address: 123 South Broad Street, #1400 Philadelphia, PA 19109 Telephone: (215) 790-1010 Fax:(215) 790-1274 E-Mail: 11/10/2022 Attorney Signature DateChoose only the one description which best reflects the principal type of case or relief sought from the list. Case Description APPEAL Minor Court Money Judgement Landlord and Tenant Code Enforcement Personal Injury Breach of Contract Other Local Agency Civil Service Motor Vehicle Licenses and Inspections Liquor Control Board Tax Assessment Boards Zoning Board Other Proceedings Commenced by Petition Appointment of Arbitrators Change of Name Compel Medical Examination Election Matters Eminent Domain Leave to Issue Subpoena Mental Health Proceedings Other ACTIONS COMMENCED BY WRIT OF SUMMONS OR COMPLAINT Abuse of Process Action for Wrongful Death Class Action _ Confession of Judgement/Money Confession of Judgement/ Real Property Contract Construction Insurance/Bad Faith Negotiable Instruments Other Intentional Tort Assault and Battery Libel and Slander Defamation Employment/Wrongful Discharge False Imprisonment Fraud _ Malicious Prosecution Negligence Motor Vehicle Real Property Premises Liability Product Liability Toxic Tort Asbestos DES Implant Toxic Waste Other Professional Malpractice Dental Legal Medical Other Equity Real Property Stockholders Derivative Action Waste Prevention Other Declaratory Judgement Ground Rent Mandamus Real Property Ejectment Quiet Title Mortgage Foreclosure Mechanics Lien Partition Prevent Waste Replevin Saving Action Um/Uim Quo Warranto Other+ . Court OF COMMON PLEAS DELAWARE COUNTY THIRTY “SECOND JUDICIAL DISTRICT ‘COURTHOUSE. NO: Mevia, Det.AWARE COUNTY, PENNSYLVANIA 19063 Important Notice Date of Service of this Notice: (to be completed by the Sheriff's Deputy upon Service of Complaint) Under a new Pilot Program sponsored by the Court of Common Pleas of Delaware County and the Sheriff of Delaware County, you may be eligible to get help with your Mortgage. Call the Save Your Home Hotline at 800-989-2227 To be eligible for any stay, you must be the owner or an heir to a deceased owner of the property which is the subject of the Action of Mortgage Foreclosure and you must occupy the property which is the subject of this Action of Mortgage Foreclosure as your principal residence. You will discuss your mortgage foreclosure with an independent and professional Housing Counselor who will work with you to review your finances and work with your lender to try and resolve the mortgage foreclosure action. The Housing Counselor is available to you AT NO CHARGE. Once you call this number, the Housing Counselor will contact the lender’s attorney and the Court sanctioned thirty (30) day delay of the Action in Mortgage Foreclosure will go into effect, all you have do is call. You can have the Action of Mortgage Foreclosure delayed for up to thirty (30) days so that you can participate in a conference with your Housing Counselor and submit a loan resolution proposal to the lender and their attorney. This may assist you in saving your home from foreclosure. Call the Save Your Home Hotline at 800-989-2227 Make this call today to save your home. If you do not call within thirty (30) days from the day this notice has been served on you or a member of your household by the Sheriff, you may not be eligible for this program, but you may have other legal ways to delay the foreclosure action. 22-101371IF YOU DECIDE TO USE THE SERVICES OF THE HOUSING COUNSELOR MADE AVAILABLE BY THIS PROGRAM, YOU SHOULD NOTE THAT THE SOLE PURPOSE OF THIS PROGRAM IS TO PROVIDE INFORMATION AND ASSISTANCE IN YOUR DESIRE TO MAKE ARRANGEMENTS WITH YOUR LENDER FOR THE MUTUAL RESOLUTION OF YOUR INDEBTEDNESS. THIS IS A PUBLIC SERVICE PROGRAM AND IS NOT IN ANY WAY A PROGRAM TO PROVIDE YOU WITH LEGAL ADVICE OR LEGAL SERVICES OF ANY KIND. NEITHER THE HOUSING COUNSELOR NOR ANY PERSON OR ENTITY ASSOCIATED WITH THE PROGRAM IS PROVIDING OR WILL PROVIDE YOU WITH ANY INFORMATION OR ADVICE CONCERNING ANY LEGAL REMEDIES, LEGAL PROCEDURES, OBJECTIONS OR DEFENSES TO THE CLAIM AGAINST YOU. THE PROGRAM AND ANY PERSON OR ENTITY ASSOCIATED WITH IT DOES NOT AND WILL NOT PROVIDE YOU WITH ANY ATTORNEY OR LEGAL REPRESENTATION OF ANY KIND. 22-101371NOTICE 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 this 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 claimed in the complaint or 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, 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. Lawyers Reference Service Delaware County Bar Association 335 West Front Street Media, Pennsylvania 19063 (610) 566-6625 Rivera 22-101371 Complaint in Mortgage Foreclosure AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita 0 en persona o con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaramedidas y puede continuar la demanda en contra suya sin previo aviso o notificacion.Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Lawyers Reference Service Delaware County Bar Association 335 West Front Street Media, Pennsylvania 19063 (610) 566-6625 Page 1 of 6McCABE, WEISBERG & CONWAY, LLC MARGARET GAIRO, ESQUIRE - ID # 34419 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 MARISA MYERS COHEN, ESQUIRE - ID #87830 ANDREW M. LUBIN, ESQUIRE - ID # 54297 CHELSEA A. NIXON, ESQUIRE - ID # 324130 NATHALIE PAUL, ESQUIRE — ID # 309118 123 South Broad Street, Suite 1400 Philadelphia, PA 19109 (215) 790-1010 Attorneys for Plaintiff PennyMac Loan Services, LLC., 3043 Townsgate Road #200 Westlake Village, CA 91361, Plaintiff, v. Manuel Rivera 726 Windermere Avenue Drexel Hill, PA 190261514, Defendant. Delaware County Court of Common Pleas Number: COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is PennyMac Loan Services, LLC., duly organized and doing business at the above-captioned address. 2. The Defendant is Manuel Rivera, who is a mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 726 Windermere Avenue, Drexel Hill, PA 190261514. Rivera 22-101371 Complaint in Mortgage Foreclosure Page 2 of 63. On July 20, 2018, Manuel Rivera, made, executed and delivered a Mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as Nominee for Mortgage Research Center, LLC dba Veterans United Home Loans which Mortgage is recorded in the Office of the Recorder of Delaware County as Instrument Number 2018048027 in Mortgage Book 06230, Page 0753 (“the Mortgage”), the Mortgage is incorporated herein by reference pursuant to Pa.R.C.P. 1019(g). 4. On July 20, 2018, Manuel Rivera, also executed a promissory note secured by the Mortgage (“the Note”). Plaintiff, directly or through an agent, is in possession of the Note and is the holder of the Note with the right to enforce it; the Note is either made payable to plaintiff or has been duly indorsed. Bt On April 27, 2021, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc., as Nominee for Mortgage Research Center, LLC dba Veterans United Home Loans to PennyMac Loan Services, LLC., by assignment of mortgage, recorded in the Office of the Recorder of Delaware County as Instrument Number 2021040947 in Mortgage Book 6694, Page 5365, said assignment of mortgage*is incorporated herein by reference pursuant to Pa.R.C.P. 1019(g). 6. The premises subject to the Mortgage is described in the legal description attached as Exhibit “A” and is known as 726 Windermere Avenue, Drexel Hill, PA 190260000. 7. The Mortgage is in default because monthly payments of principal and interest upon the Mortgage due January 1, 2021 and each month thereafter are due and unpaid, and by the terms of the Mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. Rivera 22-101371 Complaint in Mortgage Foreclosure Page 3 of 68. The following amounts are due on the Mortgage: Principal Balance $ 159,016.51 Interest through October 14, 2022 $ 14,829.89 (Plus $21.74 per diem thereafter) Late Charges $ 495.32 Escrow Advance $ 10,198.79 Property Inspections $ 210.00 Title Search $ 290.00 GRAND TOTAL $ 185,040.51 plus additional interest and all other amounts authorized under the mortgage and applicable law that are reasonable and have been incurred, including but not limited to costs, escrow advances, and attorney's fees. 9. Pre-foreclosure notices were sent at least 33 days prior to the filing of this action. A copy of said notice is attached hereto as Exhibit “B”. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $185,040.51, together with interest accruing thereafter; other costs and charges collectible under the Mortgage and applicable law, including all reasonable and actually incurred attorney's fees and costs; and the foreclosure and sale of the mortgaged property. Date: 11/10/2022 McCABE, WEISBERG & CONWAY, LLC py. /S! Chustone L. Grahame { ] Margaret Gairo, Esq. [ ] Marisa Myers Cohen, Esq. [X] Christine L. Graham, Esq. [ ] Andrew M. Lubin, Esq. { ] Nathalie Paul, Esq. [ ] Chelsea A. Nixon, Esq. Rivera 22-101371 Complaint in Mortgage Foreclosure Page 4 of 6Attorneys for Plaintiff Rivera 22-101371 Complaint in Mortgage Foreclosure Page 5 of 6VERIFICATION Christine D'Angelo hereby states that he/she is__ Authorized Representative of PennyMac Loan Services, LLC., Plaintiff in this matter, that he/she is authorized to make this Verification, and verify that the statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief, The undersigned understands that this statement is made subject to the penalties of 18 Pa. CS. Sec. 4904 relating to unsworn falsification to authorities. ome jobelecs oat Name: Christine D'Angelo Title: Authorized Representative File#; 22-101371 Name: PennyMac Loan Services, LLC. v. Manuel Rivera Rivera 22-101371 Complaint in Mortgage Foreclosure Page 6 of 6Legal Description ‘File No: 11 7-0U4099 EXHIBIT A ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, Situate in the Township of Upper Darby, County of Delaware and State of Pennsylvania, bounded and described according to a Plan of Drexel Park Gardens, made for Wamer West Corporation, by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania, on December 16, 1941 and revised May 15, 1942, as follows, to wit: BEGINNING at a point on the Southwesterly side of Windermere Avenue (40 feet wide) at the distance of 169.8 feet measured Southeastwardly along the said side of Windermere Avenue from a radius round corner whose radius is 25 feet the arc distance of 40.67 feet from a point on the Southeasterly side of State Road (50 feet wide). CONTAINING in front or breadth South 15 degrees, 53 minutes East along the Southwesterly side of said Windermere Avenue 18 feet and extending of that width in length or depth South 74 degrees, 07 minutes West between parallel lines at right angles 100 feet to the middle of a 15 feet wide driveway {which extends Northwestwardly into State Road and Southeastwardly into Highland Avenue). The Northwesterty and Southeasterly lines thereof extending partly through party walls separating these premises from adjoining to the Northwest and Southeast respectively. TOGETHER with the free and common use, right, liberty and privilege of the aforesaid driveways as and for a passageway in common with the owners, tenants and occupiers of the adjoining lots of ground bounding thereon and entitled to the use thereof at all times hereafter forever. FOLIO NO. 16-09-01 509-00. BEING the same premises which Theodore Sgro and Sandra Sgro, by Deed dated 06/16/2016 and recorded 06/22/2016 in the Office of the Recorder of Deeds in and for the County of Delaware in Record Book 5829, Page 1213, granted and conveyed unto Keaton Macut, 16-09-01509-00PennyMac Loan Services, LLC PO Bax 9109 Temecula, CA 92589 9109 ‘Send Payments to: PennyMac Loan Services, LLC PO Box 30597 Los Angeles, CA 90030 0597 ‘Send Correspondence to: PennyMac Loan Services, LLC PO Bax 514387 Los Angeles, CA 90051 4387 EXHIBIT B RETURN RECEIPT (ELECTRONIC) MANUEL RIVERA 726 WINDERMERE AVE DREXEL HILL, PA 19026 PRESORT First Class Mail US. Postage and Fees Paid wsoPennyM ac Notice Date: 02/25/2021 Sent Via Certified Mail P.O. Box 514387 9314 8100 1170 10Sb 4571 79 LOS ANGELES, CA 90051 4387 MANUEL RIVERA Loan Number: 726 WINDERMERE AVE Property Address: DREXEL HILL, PA 19026 726 WINDERMERE AVE DREXEL HILL, PA 19026 NOTICE OF DEFAULT AND INTENT TO ACCELERATE | ABOUT YOUR LOAN This letter is formal notice by PennyMac Loan Services, LLC (herein as “PennyMac’”) that you are in default under the terms of the documents creating and securing your Loan described above, including the Note and Deed of Trust/Mortgage/Security Deed (“Security Instrument’), for failure to pay the amounts due. [WHY YOU RECEIVED THIS NOTICE The loan is due for 01/01/2021 and subsequent payments, plus late charges, and/or any escrow balance, fees and costs. As of today, the total delinquency and reinstatement amount is $2,982.24, which consists of the following: Next Payment Due Date: 01/01/2021 Total Monthly Payments Due: $2,911.48 2 @ $1,455.74 Late Charges: $70.76 Other Charges: Uncollected NSF Fees: $0.00 Property Preservation Fees: $0.00 Property Inspection Fees: $0.00 Appraisals\Broker Price Opinion Fees: $0.00 Bankruptcy Fees: $0.00 Unapplied Balance: ($0.00) TOTAL YOU MUST PAY TO CURE DEFAULT: $2,982.24 TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE NUMBER. Toll-Free: (866) 545-9070 Website: www.PennyMacUSA.com Payments: Correspondence: MF 6:00AM 6:00 PM PT Secure Messaging Online: ‘Standard Address: Attn: Correspondence Unit Sat 7:00AM 11:00 AMPT Create an account andior log in to P.O. Box 30597 P.O. Box 514387 Toll Free Fax: (866) 577 7205 hitp:/www.PennyMacUSA.com, Los Angeles, CA 90030 0597 Los Angeles, CA 90051 4387 then look for the Secured Message Overnight Address: (Please do not send payments) Center to communicate with us securely. Attn: Lockbox Operations 20500 Belshaw Ave Carson, CA 90746 (Please do not send correspondence) GEN_NOL 52 Page 1 of 4 9314 8100 1170 1056 4571 79It is possible that after payment of the amounts detailed above there may be other fees still due and owing, including but not limited to other fees, escrow advances or corporate advances that PennyMac paid on your behalf or advanced to your account. This letter is a formal demand to pay $2,982.24. If the default, together with additional payments that subsequently become due, is not cured by 04/01/2021, the sums secured by the Security Instrument may be accelerated, and PennyMac may invoke any remedies provided for in the Note and Security Instrument, including but not limited to the foreclosure sale of the property. IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, PennyMac offers consumer assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are provided without cost to our customers. You may be eligible for a loan workout plan or other similar alternatives. If you would like to learn more about these programs, you may contact the Loss Mitigation Department at (866) 545-9070, 6:00 AM - 6:00 PM PT Monday through Friday and 7:00 AM - 11:00 AM PT Saturday. WE ARE VERY INTERESTED IN ASSISTING YOU. [ACTION REQUIRED The default above can be cured by payment of the total delinquency and reinstatement amount plus any additional payments and fees that become due by 04/01/2021. Note that in addition to the regular monthly payments, additional charges, costs and fees may become due during the period between today’s date and the date the aforementioned payments are due. You may contact our Collection Department at (866) 545-9070 to obtain updated payment information. Please include your loan number and property address with your payment and send to: PennyMac Loan Services, LLC P.O. Box 30597 Los Angeles, CA 90030-0597 or Overnight: PennyMac Loan Services, LLC Attn: Lockbox Operations 20500 Belshaw Ave Carson, CA 90746 If you wish to dispute the delinquency, or if you dispute the calculation of amount of the delinquency and reinstatement amount, you may contact.us by calling (866) 545-9070, You may have the right to “cure” or reinstate the loan after acceleration, and the right to assert in a foreclosure proceeding, or to bring a court action to assert the non-existence of a default or any other defense to acceleration or foreclosure sale. Failure to respond to this letter may result in the loss of your property. To the extent your obligation has been discharged or is subject to the automatic stay in a bankruptcy case, this notice is for informational purposes only and does not constitute a demand for payment or an attempt to collect a debt as your personal obligation. If you are represented by an attorney, please provide us with the attorney's name, address and telephone number. |IMPORTANT INFORMATION Attention Servicemembers and Dependents: Servicemembers on active duty, or a spouse or dependent of such a servicemember, may be entitled to certain protections under the Servicemembers Civil Relief Act (“SCRA”) regarding the servicemember's interest rate and the risk of foreclosure. SCRA and certain state laws provide important protections for you, including prohibiting foreclosure under most circumstances. If you are currently in the military service, or have been within the last (12) months, AND joined after signing the Note and Security Instrument now in default, please contact PennyMac immediately. When contacting PennyMac as to your military service, you must provide positive proof as to your military status. Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate, or their installation’s Legal Assistance Officer. Homeowner counseling is also available at agencies such as Military OneSource (www.militaryonesource.mil; 1-800-342-9647) and Armed Forces Legal Assistance http://legalassistance.law.af.mil), and through HUD-certified housing counselors (http://www.hud.gov/offices/hsq/sfh/hcec/hes.cfm). You can also contact us toll-free at 1-866-545-9070 if you have questions about your rights under SCRA. GEN_NOI_52 Page 2 of 4 9314 8100 1170 1056 4571 79If you are experiencing financial difficulty, you should know that there are several options available to you that may help you keep your home. You may contact a government approved housing counseling agency which provides free or low-cost housing counseling. You should consider contacting one of these agencies immediately. These agencies specialize in helping homeowners who are facing financial difficulty. Housing counselors can help you assess your financial condition and work with us to explore the possibility of modifying your loan, establishing an easier payment plan for you, or even working out a period of loan forbearance. For your benefit and assistance, there are government approved homeownership counseling agencies designed to help homeowners avoid losing their homes. To obtain a list of approved counseling agencies, please call 1-800-569-4287 or visit http://www.hud.gov/offices/hsq/sfh/hec/hcs.cfm. You may contact the Homeownership Preservation Foundation's Hope hotline at 1-888- 995-HOPE (4673). If you wish, you may also contact us directly at (866) 545-9070 and ask to discuss possible options or visit our website www.PennyMacUSA.com. Pursuant to your loan documents, PennyMac may enter upon and conduct an inspection of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, and (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above described inspections and property preservation efforts will be charged to your account as provided in your security instrument. PennyMac is attempting to collect a debt, and any information obtained will be used for that purpose. You are notified that this default and any other legal action that may occur as a result thereof may be reported to one or more local and national credit reporting agencies by PennyMac. | QUESTIONS? CONTACT US If your loan is currently being evaluated for a loan modification, forbearance or other loan assistance solution, this notice will not cancel or delay that evaluation process. However, it is important that you promptly respond to all requests made in connection with your evaluation for a loan assistance solution, including all requests for you to contact us and any documentation required. If you do not comply with these requests in a timely manner, it may cause your loan to enter the foreclosure process as indicated in this notice. If your loan is not eligible for a loan assistance program, please note this letter will continue to serve as notice of our right to initiate foreclosure. This matter is very important. Please give it your immediate attention. Sincerely, PennyMac Loan Services, LLC 3043 Townsgate Rd. Suite 200 Westlake Village, CA 91361 (866) 545-9070 GEN_NOL 52 Page 3 of 4 9314 8100 1170 LOSb 4S71 749In accordance with the Fair Debt Collection Practices Act, 15 U.S.C. section 1692 et seq., debt collectors are prohibited from engaging in abusive, deceptive, and unfair debt collection efforts, including but not limited to: (j) the use or threat of violence; (ji) the use of obscene or profane language; and (ii) repeated phone calls made with the intent to annoy, abuse, or harass. NEW YORK Ifa creditor or debt collector receives a money judgment against you in court, state and federal laws prevent the following types of income from being taken, to pay the debt: 1) Supplemental security income (SSI); 2) Social security; 3) Public assistance (welfare); 4) Spousal support, maintenance (alimony) of child support; 5) Unemployment benefits; 6) Disability benefits; 7) Workers’ compensation benefits; 8) Public or private pensions; 9) Veterans’ benefits; 10) Federal student loans, federal student grants, and federal work study funds; and 11) Ninety percent of your wages or salary earned in the last sixty days. PennyMac Loan Services, LLC is registered with the Superintendent of the New York State Department of Financial Services (Department), You may obtain further information or file a complaint by calling the Department's Consumer Assistance Unit at 1 800 342 3736 or by visiting www.dfs.ny.gov. NORTH CAROLINA - Licensed by the North Carolina Department of Insurance. Permit No. 104753 6101 Condor Dr., Suite 200, Moorpark, CA 93021. Permit No. 112228 14800 Trinity Blvd., Fort Worth, TX 76155. Permit No. 112874 3043 Townsgate Rd., Suite 200, Westlake Village, CA 91361. Permit No. 112877 2201 West Plano Parkway, Suites 150 and 300, Plano, TX 75075. Permit No. 113746 10550 West Charleston Blvd., Suite A, Las Vegas, NV 89135. OREGON Residential mortgage loan servicers are regulated by the Oregon Division of Financial Regulation. To file a complaint, call (888) 877 4894 or visit http://dfr.oregon.gov. This is an attempt by a debt collector to collect a debt and any information obtained will be used for that purpose. However, if your account is subject to pending bankruptcy proceedings or if you have received a discharge in bankruptcy, this statement is for informational purposes only and is not an attempt to collect a debt against you personally. Licensing Information @.... Housing Opportunity © 2008 2021 PennyMac Loan Services, LLC, 3043 Townsgate Rd, Suite 200, Westlake Village, CA 91361, 818 224 7442. NMLS ID # 35953 (www.nmisconsumeraccess.org). Trade/service marks are the property of PennyMac Loan Services, LLC and/or its subsidiaries or affiliates. Arizona Mortgage Banker License # 0911088. Licensed by the Department of Financial Protection and Innovation under the California Residential Mortgage Lending Act. Colorado: Colorado office: 700 17th St, Suite 200, Denver, CO 80202, (866) 436 4766. Georgia Residential Mortgage Licensee #33027. Massachusetts Mortgage Lender License # ML35953. Minnesota: This Is not an offer to enter into an agreement and an offer may only be made pursuant to Minn. Stat. §47.206 (3) & (4). Licensed by the N.J. Department of Banking and Insurance. Rhode Island Lender License # 20092600LL. Washington Consumer Loan License # CL 35953. For more information, please visit www.pennymacusa.comV/state licenses. Loans not available in New York. Some products may not be available in all states. Information, rates and pricing are subject to change without prior notice at the sole discretion of PennyMac Loan Services, LLC. All loan programs subject to borrowers meeting appropriate underwriting conditions. This is not a commitment to lend. Other restrictions apply. All rights reserved. (12 2020) FILED 11-10-2022 02:19 PM GEN_NOL52 OFFICE OF sbiciaL suPPORT DELAWARE COUNTY, PA Page 4 of 4 9314 8100 L170 1OSb 4571 79