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CIVIL COVER SHEET AND ENTRY OF APPEARANCE
Delaware County Court of Common Pleas
Court Term & No.
Case Caption:
Wells Fargo Bank, N.A.
Christopher Jones, et al.
____Jury
X__Non-Jury
Arbitration
($0-$50,000)
2a Plaintiff(s) 2b Defendant(s)
(Name and Address) (Name and Address)
Wells Fargo Bank, N.A. Christopher Jones
11625 N Community House Rd 5206 Gramercy Drive
Charlotte, North Carolina 28277 Clifton Heights, PA 19018
Francine Hairston
5206 Gramercy Drive
Clifton Heights, PA 19018
3a Related Cases? Yes x x No 3b. Case Subject to Coordination Order? Yes _x_No
If yes, show Caption and Case Numbers If yes, show Caption and Date of Order
Entry of Appearance
To the Office of Judicial Support:
Kindly enter my appearance on behalf of Wells Fargo Bank, N.A., (a) plaintiff in this action. Papers may
be served at the address set forth below.
Katherine M. Wolf, Esquire Address: P.O. Box 165028
Attorney for party named above (please print) Columbus, OH 43216-5028
Atty File No: 24-003954
314307 Telephone: 614-220-5611; Fax: 614-220-5613
*
Attorney |.D. Number E-Mail: KMWolf@manleydeas.com
March 19, 2024
Attorney Signature Date
Choose only the one description which best reflects the principal type of case or relief sought from the list
Case Description
APPEAL Intentional Tort
Minor Court Assault and Battery
Money Judgment Defamation
Landlord and Tenant Employment/Wrongful Discharge
Code Enforcement False Imprisonment
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Breach of Contract Malicious Prosecution
Other Negligence
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Tax Assessment Boards DES
Zoning Board Implant
Other Toxic Waste
Other,
Proceedings Commenced by Pet Professional Malpractice
Appointment by Arbitrators Dental
Change of Name Legal
Compel Medical Examination Medical
Election Matters Other.
Eminent Domain Equity
Leave to Issue Subpoena Real Property
Mental Health Proceedings Stockholders Derivative Action
Other Waste Prevention
Other,
CIVIL ACTIONS COMMENCED BY WRIT OF Declaratory Judgment
SUMMONS OR COMPLAINT Ground Rent
Mandamus
Abuse of Process Real Property
Action for Wrongful Death Ejectment
Class Action Quiet Title
Confession of Judgment/Money Mortgage Foreclosure
Confession of Judgment/Real Property Mechanics Lien
Partition
Construction Prevent Waste
Insurance/Bad Faith Replevin
Negotiable Instruments Saving Action Um/Uim
Other Warranto
Other.
Manley Deas Kochalski LLC
P. O. Box 165028
Columbus, OH 43216-5028
Telephone: 614-220-5611
Email: KMWolf@manleydeas.com
IN THE COURT OF COMMON PLEAS
DELAWARE COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A-
11625 N Community House Rd CIVIL DIVISION
Charlotte, North Carolina 28277
NO.:
Plaintiff.
VS.
Christopher Jones
5206 Gramercy Drive
Clifton Heights, PA 19018
Francine Hairston
5206 Gramercy Drive
Clifton Heights, PA 19018
Defendants.
O2-PA-VIN 24-003954_MKM
C2
NOTICE TO DEFE:
NOTICE AVISO
You have been sued in court. If you wish to Le han demandado a usted en la corte. Si
defend against the claims set forth in the usted quiere defenderse de estas demandas
following pages, you must take action within expuestas en las paginas siguientes. usted
twenty (20) days afler this complaint and tiene veinte (20) dias de plazo al partir de la
notice are served, by entering a written fecha de la demanda y la notificacion. Hace
appearance personally or by attorney and falta ascentar una comparencia escrita o en
filing in writing with the court your defenses persona o con un abogado y entregar a la corte
or objections to the claims set forth against en forma escrita sus defensas o sus objeciones
you. You are warmed that if you fail to do so alas demandas en contra de su persona. Sea
the case may proceed without you and a avisado que si usted no se detiende, la cone
judgment may be entered against you by the tomara medidas y puede continuar la demanda
court without further notice for any money en contra suya sin previo aviso 0 notificacion,
claimed in the complaint of for any other Ademas, la corte puede decider a favor del
claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con
may lose money or property or other rights todas las provisiones de esta demanda, Usted
important to you. puede perder dinero o sus propiedades u otros
derechos importantes para usted.
You should take this paper to your lawyer at
once. If you do not have a lawyer or cannot Lleve esta demanda a un abogado
afford one, ga to or telephone the office set immediatamente. Si no tiene abogado a si no
forth below to find out where you can get tiene el dinero suficiente de pagar tal servicio
legal heip. Vaya en persona o llame por telefona ala
oficina cuyu direccion se encuentra escrita
Lawyers Reference Service abajo para averiguar donde se puede
Delaware County Bar Association conseguir asistencia legal
335 WestFront Street
Media, PA 19063 Lawyers Reference Service
(610) 566-6625 Delaware County Bar Association
335 West Front Street
Media, PA 19063
(610) 566-6625
HOUPA-V 1D 24-003954_ MKM
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Wells Fargo Bank. N.A., by its attorneys, Manley Deas Kochalski LLC.
and files this Complaint in Mortgage Foreclosure as follows:
1 The Plaintiffis Wells Fargo Bank, N.A., 11625 N Community House Rd. Charlotte.
North Carolina 28277 (hereinafter "plaintiff").
The Defendant(s) is/are, Christopher Jones, with a last known address of 5206 Gramercy
Drive. Clifton Heights, PA 19018 and Francine Hairston, with a last known address of
5206 Gramercy Drive, Clifton Heights, PA 19018.
In order to protect the borrower's privacy, certain personal information of the borrower
(such as loan account. Social Security numbers and birth dates), may have been partially
or completely redacted on the exhibits to this Complaint.
Wells Fargo Bank, N.A. directly or through an agent, has possession of the Promissory
Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the
Promissory Note has been duly indorsed. A copy of said Promissory Note is marked
Exhibit A, attached hereto and made a part hereof.
On or-about November 30. 2020, Christopher Jones and Francine Hairston made.
executed and delivered to American Financial Network Inc. dba: Orion Lending, a
Mortgage in the original principal amount of $163,975.00 on the premises described in
the tegal description marked Exhibit B, attached hereto and made a part hereof. Said
mortgage was recorded in the Recorder's Office, Delaware County, Pennsylvania, on
February 8, 2021, in Instrument Number 2021008934, and recorded in Book 6643, Page
5946. The Mortgage is a matter of public record and is incorporated herein by reference
in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation
OO2PA-V LO 24-003954_MKM
to attach documents to pleadings if those documents are of public record. The folio
number is 16130208600.
Plaintiff is the current Mortgagee. By assignment of Mortgage recorded January 24,
2024, the mortgage was assigned to Wells Fargo Bank, NA, which Assignment is
recorded in Office of the Recorder of Deeds for Delaware County as Instrument Number
2024002658, and recorded in Book 6954, Page 2383. The Assignment is a matter of
public record and is incorporated herein by reference in accordance with Pa.R.C.P.
1019(g), which rule retieves the Plaintiff trom its obligation to attach documents to
pleadings if those documents arc of public record.
Christopher Jones and Francine Hairston are the record and real nwner(s) of the aforesaid
mortgaged premises.
Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure
to pay the instaliments of principal and interest due November 1, 2023.
062-PA-VIO 24-003954 MKM
As of 03/19/2024, the amount due and owing Plaintiff on the mortgage is as follows.
The total amount due the Plaintiffon said Note through 03/19/2024 is $157,235.41 which
breaks down as follows:
Principal $152,894.39
Interest
From 10/01/2023 to 03/19/2024 @ 2.5% $1781.15
Pre-acceleration Late Charges $103.68
Hazard Insurance Disbursements $0.00
Tax Disbursements $2,176.22
Property Inspections/Preservation $0.00
PMI\MIP Insurance $279.97
Other (specify charges/fees) $0.00
Escrow Balance Credit $0.00
Credits to Borrower $0.00
Total $157,235.41
Interest will continue to accrue until the date of judgment under the terms of the Note and
Mortgage
plus. interest and all other additional amounts authorized under the Mortgage and
Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not
limited 10, costs (including escrow advances) and Plaintif?’s attorneys’ fees and expenses.
Plaintiff reserves the right to file a motion in the above-captioned action to add such
additional sums authorized under the Mortgage and Pennsylvania Law to the above
amount due and owing when incurred.
962-PA-V 1G 24-003954_MKM
10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in
2008. and/or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s). A copy of said Notice is marked Exhibit C, attached hereto
and made a part hereof.
iN This action does not come under Act 91 of 1983 because the morigage is FHA insured.
12 This is an ém rer action only against the aforesaid mortgaged premises. Plaintiff is not
seeking a judgment of personal liability against the Defendant(s) but reserves its right to
do so ina separate legal action if such right exists. If Defendant(s) have received a
discharge of personal liability in a bankruptcy proceeding, this actionis inno way an
attempt to re-establish such liability.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the
amount due of $157,235.41, with interest thereon plus additional costs (including additional
escrow advances), additional attorneys’ fees and costs and tor foreclosure and sale of the
mortgaged premises.
Respgctfully submitted,
octhuwn
VN). Dod
Katherine M. Wolf, Esquire (314307)
Meredith H. Wooters, Esquire (307207)
Kimberly J. Hong, Esquire (74950)
Michael E. Carleton, Esquire (203009)
Alyk L. Oflazian, Esquire (312912)
Cristina L. Connor, Esquire (318389)
Ed E, Qagish, Esquire (309463)
Manley Deas Kochalski LLC
P. O. Box 165028
Columbus, OH 43216-5028
Telephone: 614-220-5611
Fax: 614-220-5613
Email: KMWolfi@manieydeas.com
62-FAV IO 24-003954_MKM
or?
cow
Covyo
VERIFICATION
Farisha Demery, hereby states that he/she is Vice President Loan
Documentation of WELLS FARGO BANK, N.A., plaintiffin this matter, that he/she is
authorized to make this Verification, and verify that the statements made in the foregoing
Civil Action in Mortgage Foreclosure are true and correct to the best of his/her
information and belief. The undersigned understands that this statement is made subject
to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
ts
Farisha Demery
Vice President Loan Documentation
Wells Fargo Bank, N.A.
03/20/2024
O86-PA-V3
I certify that this filing complies with the provisions of the Public Access Policy of the
Unified Judicial System of Pennsylvania: Case Records of the Appellate and Trial Courts that
require filing confidential information and documents differently than non-confidential
information and documents.
Kechuwne Woe
Katherine M. Wolf, Esquire (314307)
Meredith H. Wooters, Esquire (307207)
Kimberly J. Hong, Esquire (74950)
Michael E. Carleton, Esquire (203009)
Alyk L. Oflazian, Esquire (312912)
Cristina L. Connor, Esquire (318389)
Ed E. Qagish, Esquire (309463)
Manley Deas Kochalski LLC
Telephone: 614-220-5611
Fax: 614-220-5613
Email: KMWolf@manleydeas.com
Attorney for Plaintiff
062-PA-V10
NOTE
ec
FHA Case No.
a
toa
Mil ptevercleicare|
NOVEMBER 30, 2020 BROOMALL, PENNSYLVANIA
{Date} {City] [State]
5206 GRAMERCY DR, CLIPTON HEIGHTS, FA 19018
[Property Address}
1, BORROWER'S PROMISE TO PAY
Jn retum for a toan that | have received, | promise to pay U.S. $163,975.00 (this amount is called “Peincips!"}, plus
interest to the order of the Lender. The Lender ts AMERICAN FINANCIAL NETWORK INC DBA: ORION LENDING. | will
make ail payments under this Note in the form of cash, eheck or moncy order.
1 understand that the Lender may transfer this Note, The Lender or anyone who takes this Note by transfer and who is entitled
to receive payments under this Note is called the "Note Holder.”
2. INTEREST
Interest will be charged on unpaid principal und! the full amount of Principal has been peid. [ will pay interest at a yearly rate
of 2.500%,
The interest rate required by this Section 2 is the rate J will pay both before and after any Survival Event as defined in this
Note.
3. PAYMENTS
{A) Time and Place of Payments
I will pay principal and interest by making a payment every month.
I will make my monthly payment on the LST day of cach month beginning on JANDARY 1, 2021.1 will make these
payments every month until | have paid all of the principal and interest and any other charges described below that I may owe under
this Note, Each monthly payment will be applied as of its scheduled due date and will be applied to interest and other items in the
order described in the Security Instrument before Principal If, on DECEMBER 1, 2050, f still owe amounts under this Note, { will
pay those amounts in full on that date, which is called the "Maturity Date." 1 will continue to pay those «mounts both before and after
any Survivel Event as defined in this Note, until 1 have paid all of the principal and interest and any other charges described below that
1 may owe under this Note.
twill make my monthly payments at 770 THE CITY DRIVE SOUTH, SUITE 1100, ORANGE, CA 92B6Borata
different place if required by the Note Holder,
(B) Amount of Monthty Payments
My monthly payment will be in the amount of U.S, $647. 90.
4, BORROWER'S RIGIIT TO PREPAY
[ have the right to make payments of Principal at any tine before they aie due. A payment of Principal only is known as a
"Prepayment." When! make a Prepayment, | will teil the Note Holder in writing that | um doing so. | may not designate a payment as
a Prepayment if L have not made all the monthly payments due under the Note.
I may make a full Prepayment or partiz! Prepayments without paying a Prepayment charge. The Note Holder will use my
Prepayments to reduce the amount of Principal that 1 owe under this Note. However. the Note Holder may apply my Prepayment to
any accrued and unpaid interest on Lhe Prepayment amount before applying my Prepayment to reduce the Principat amount of the
Note. [f] make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the
Note Holder agrees in writing to those changes.
5. LOAN CHARGES
Ifa law, which applies to this loan and which sets maximum loan charges, is finafly interpreted so thal the interest or other
loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall
be reduced by the amount necessary to reduce the charge to the permitted lirnit; and (b) any sums already collected from me which
exceeded permitted limits will be refunded to me. The Note Holder may choose ta make this refund by reducing the Principal I owe
under this Note or by making a dircct payment to me. If a refund reduces Principal, the reduction will be treated as a partial
Prepayment.
6, BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
er 36.84 Page 1 of 3 FHA Peunpylvania Fixed Rate Note - 05/416
peorerseL
If the Note Holder has not received the full amouul of any monthly payment by the end of15 calendar days afler the date 1 is
duc, J will pay a late charge to the Note Holder. The amount of the charge will be 4.000% of my overdue payment of principal and
interest. 1 will pay this late charge promptly but only once on cach late payment.
(B) Default
1f 1 de not pay the full amount of each monthly payment on the date it is due, | will be in default.
(C) Notice of Default
If] am in default, the Note Holder may send me a written notice telling me that if] do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and afl the
interest that ] owe on thal amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by
other means.
(D) No Waiver By Note Holder
Eveo if, at a time when | am in defauli, the Note Halder does not require me to pay immediately in full as described above,
the Note Holder will still have the right to do so if fam in default at a Inter time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Halder has required me to pay ininiediately in fall as described above, the Note Holder will have the right to be
paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses
include, for example, reasonable atiorneys' fees. | will pay the Note Holder back (ur those expenses paid by the Note Holder holh
hefore and after any Survival Event as defined in tbis Note.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will he given by
delivermy it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a
notice of my different address,
Any notice that nvust be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class
mail to the Note Holder at the address stated in Section 3(A)} uhove or ata different address if | am given 2 notice of that different
address,
8, OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more (han one person sigos this Note, each person is fully and personally obligated to keep all of the promises tnade in this
Note, including the promise to pay the full amount owed: Any person who is.a guarantor, surety or endorser of this Notc is also
obligaled to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser
of this Note, is also obligated to keep all of the promises made in this Note, The Note Holder may enforce its rights under this Note
against each person individually or against all ofus together. This means that any one of as may be required to pay all of the amounts
owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor
"Prescntment" means the right to require the Note Holder to demand payment of amounts due. “Notice of Dishonor” means the right
to require the Note Holder te give notice (o other persons thal amounts duc have not been paid.
10. UNIFORM SECURED NOTE
This Note isa uniform instrument with limited variations in some jurisdictions. In addition to the protectiuns given to the
Note Holder under this Note, a Mortgage, Deed of Trust. or Security Deed (the "Security Instrument"), dated the same date as this
Note, proicets the Note Holder from possible losses which might result if | do not keep the promises which I make in this Note. That
Security Instrument describes how and under what conditions { may be required to make irsmediate payment in full of all amounts |
owe under this Note. Some of those conditions are described as follows:
[fall or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not 0
natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent,
Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option
shall not be exercised by Lender if such exercise ix prohibited by Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of accelcration. The notice shall provide
6 period of not less than 30 days from the date the notice is given in accordance with Section 14 within which
Borrower must pay all sums secured by this Security Instrument, If Borrower fails to pay these sums prior to the
eapiratiun of ubis period, Lender may invoke any remedies permited by this Security Instrument without further
notice or demand on Borrower.
11, EFFECT OF SURVIVAL EVENTS
For purposes of this Note, "Survival Event” is defined as follows:
a 36.f44 Page 2 of 3 FHA Pennsylvania Fized Rate Note - U5/16
BislOrsleiiste
Resveerec)
(a) any default described in Section 6(B) of this Note:
(b) Noteholder requiriny me to pay immediately the Full amount of Principal which has not been paid and all the interest that
1 owe on that amount under Section 6(C) of this Note:
(c) Noteholder requiring immedinte payment in full of ull swans secured by the Security Instrument;
(d) the Maturity Date as defincd in this Note;
(e) the entry of any judgment against me under this Note; and
(£) the crury of any judgment under the Security Instrument.
WIT. iegs THE-HAND(S) AND SEAL(S) OF THE UNDERSIGNED.
Note a
i
14 é i
- BORROWEA - CHRISTOPHER JONES
[Sigs Original Only)
Individual Loan Originator: JOHN PILOYANTS, NMLSR ID:
Loan Originator Organization: ATLANTIC FINANCE GROU! RR... wRERER
BMRA Page 3 of 3 FItA Pennsylvania Fixed Rate Note - 08/16
=
a ALLONGE
AMERICAN FINANCIAL NETWORK INC.
FINANGING THE AMERICAN ORBAN
Loan Number: Ep
Loan Date: 11/30/2020
Borrower(s): Christopher Jones
Property Address: 5206 Gramercy Dr
Clifton Heights, PA 19018
Principal Balance: $163,975.00
PAY TO. THE ORDER OF
Wells Fargo Bank, N.A.
WITHOUT RECOURSE
COMPANY NAME:
American Financial Network, Inc., DBA Orion Lending, A California Corporation
fA ORA SVP of Onerations
Richard Plummer Title
WITHOUT RECOURSE
PAY TO THE ORDER OF
WELLS FARGO BANK, NA
_ C o © o
Uphi
p h
sull tes —
R, SENIOR VICE PR
ESIDENT,
JACKIE G. MUELLE!
ALLONGE TO THE NOTE-Orion (RP)-14 » Rev, 09/07/2016 Page lofi
EXHIBIT B
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 Commonwealth of
Pennsylvania, being Lot No. 719 on Plan No. 5 of Westbrook Park made by Damon and Foster,
Civil Engineers of Sharon Hill, Pennsylvania, dated December 28, 1948 which Plan is recorded
in the Office for the Recording of Deeds etc. in and for the County of Delaware aforesaid, at
Media in Plan Case No, 7 Page 16, etc, and described as follows, to wit:
Beginning at a point on the northwesterly side of Gramercy Drive (50 feet wide) which point is
measured South 83 degrees 5 minutes West 411.75 feet from a point, which point is measured on
the arc of a circle curving to the right having a radius of 25 feet, the arc distance of 38.64 feet
from a point on the southwesterly side of Seven Oaks Drive (50 feet wide).
Containing in front or breadth on the said Gramercy Drive 16 feet and extending of that widthin
length or depth northwestwardly between parallel lines at right angles to the said Gramercy
Drive and crossing the bed of a certain 12 feet wide driveway which extends northeastwardly
into Seven Oaks Drive and southwestwardly, thence southeastwardly into Gramercy Drive 120
feet. The northeasterly and southwesterly lines thereof partly passing through the party walls
between this premises and the premises adjoining on the Northeast and Southwest respectively.
Together with the free and common use, right, libertyand privilege of a certain driveway as
shown on the aforesaid Plan, laid out across the rear of these and adjoining premises, as and for a
driveway and watercourse at all times hereafter forever, in common with the owners, tenants and
occupiers of the lots of ground bounding thereon and entitled to the use thereof.
Subject, however, tothe proportionate part of the expense of keeping said driveway in good
order, condition and repair at all times, hereafter forever.
Prior Deed Reference: Instrument Nuinber 2021008933, and recorded in Book 6643, Page 5941.
062-PA-VIO 24-003954_MKM
WI
Wells Fargo Home Morigaga
PO Box 9065 PRESORT
Temecula, CA 92589-9065 First-Class Mail
U.S. Postage and
Fees Paid
wso
4 7200 L170 1254 bbeb 74
RETURN RECEIPT REQUESTED
Send Payments to:
Wells Fargo Home Mangage
3440 Flair Drive
El Mante, CA 91731
20240105-67
Send Correspondence to.
Wells Fargo Home Mortgage ee
Written Customer Contact CHRISTOPHER JONES
P.O. Box 10335 5206 GRAMERCY OR
Des Moines, 1A 60306
CLIFTON HEIGHTS, PA 19018-1003
First Unpaid Payment Due Date at time of this mailing: November 1, 2023
O ee PAACT6
Wells Fargo Home Mortgage
PO Box 90465
pyres Temacula, CA 92589-9005
Return Adldiess only
Da not send payments to this address
January 4, 2024
CHRISTOPHER JONES
5206 GRAMERCY DR
CLIFTON HEIGHTS. PA 19018-1003
L
Where appropriate, Wells Farge Home Mortgage is required to inform you that, as your account servicer, we are
atiempting to collect a debt and any information obtained will be used for that purpose.
Page | oft 9344 7200 LL?7C 2154 bbAab 74
Wells Fargo Home Mortgage
bonne) FO Box 9065
By ticle) Temecula, CA 92589-9065
Keturn Address only
Do not seed payments to this address
January 4, 2024
CHRISTOPHER JONES
5206 GRAMERCY DR
CLIFTON HEIGHTS, PA 19018-1003
RE: Wells Fargo Home Mortgage Loan Number
Mortgugor(s): CHRISTOPHER JONES. FRANCINE HAIRSTON
Mortgaged Premises: 5206 GRAMERCY DR
CLIFTON HEIGHTS, PA 19018
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear CHRISTOPHER JONES:
The mortgage held or serviced by Wells Fargo Bank, N.A. (hereinafter we, us of ours) on your property located at 5206
GRAMERCY DR, PA 19018 {8 IN SERIOUS DEFAULT because you've not made the payments since November {,
2023 through January 3, 2024. Late charges and other charges have also acerued to this date. The total amount now
required to cure the default, or in other words, bring your loan current, is calculated below.
3 Overduc Payments Totaling 33,866.72
Late Charge Balance S3LR4
Other Fees. Unpaid Advance Balance $0.00
Unapphied Funds $0.00
Total Overdue amount as of January 3, 2024 $3,918.56
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the amount of
$3,918.56 plus any additional payments and late charges which may fall due during this period.
How to send your payment
You may send us your payments by phone or mail:
Phone; Call us at 1-800- 416-1472 to make a one-time paymeot over the phone or obtain other payment options.
Mail: Write a check for the total averdue amount payable to Wells Fargo Home Mortgage. Be sure to include your
account number on your payment and send i to us via regular or overnight mail:
Regular mail Overnight mail
Wells Fargo Home Mortgage Wells Fargo Home Mortgage
PO Box 77036 3440 Flair Drive
Minneapolis, MN 55480-7734 El Monte, CA 91731
If you do not cure the default within THIRTY (30} DAYS of the date of this letter, we intend to exercise our right to
accelerate the morlgage payments. This means that whatever is owing on the original amount borrowed will be
considered duc immediately and you may tose the chance to pay off the original mortgage in mstallments.
If full payment of the umount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our
attorney(s) to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged
Page 3 of 4 F914 7100 3170 2154 bbab 74
property will be sold by a Sheriff(s) or other similar official{s} sale 10 payoff the mortgage debt. Hf you cure the default
before we begin legal procecdings against you, you will still lave to pay the reasonable attorney(s) fees actually
incurred, up to $50.00.
However, if legal proecedings are started against you, you will have to pay the reasonable attorney(s) fees even if they
are over 350,00. Any attorney(s) fees will be added to whatever you owe the lender, which may also inelude their
reasonable costs, [If you cure the default within the THIRTY (30) DAY period you will not be required to pay
attorney{s) fees.
We may also sue you personally for the unpaid principal balance and all other sums duc under the mortgage.
If you have not cured the default within THIRTY (30) DAY period and foreclosure proceedings have begun, you still
have the right to cure the default and prevent the sale at any lime up to one four before the Sheri Ms) ur other similar
official(s) foreclosure sale, You may do so by paying the total amount of the unpaid payments plus any 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 Sheriffts) or other similar official(s)
sale could be held would be approximately four to six months from the date of this notice. A notice of the date of the
Sheriff{s) or similar official(s) sale will be sent to you before the sale. Of course, the amount needed to cure the default
will increase the tonger you wail. You may find out at any time exactly what the required payment will be. by calling
ug al the following number: 1-800-416-1472, The payment musi be made by cash, cashicr’s check, certified cheek or
money order made payable to us at the address stated above. For your own protection, please do not mail cash.
You shoutd realize that a Sherif(s) or other similar official(s) sale will end your ownership of the mortgaged property
and your right to remain in if. Lf you continue to live in the property afer the Sheriff's) or other similar officral(s) sale,
a lawsuit could be started 10 evict you.
You shall have the right to assert in the foreclosure proccedings, the nonexistence of a defaultor any other defense that
you may have to acceleration or foreclosure.
You have the additional right to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE
PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM
ANOTHER LENDER 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 OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY(S)
FEES AND COSTS ARE PAID»PRIOR TO OR AT THE SALE AND THAT 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 this default, ihe 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.
Sincerely,
Default Management Department
Wells Fargo Home Mortgage
Page 4 af4 A3L4 7100 L470 1254 bbbb 74
UTA
Wolls Fargo Home Morigage PRESORT
PO Box 8065.
Temecula, CA 92589-8065 First-Class Mail
U.S, Postage and
Fees Pad
wsa
238bbL852b
Send Payments to.
Wells Fargo Home Mortgage
3440 Flair Orive
€l Monte, CA 94731
20250105-67
Send Correspondence to.
Wells Fargo Home Morlgage ae
Written Customer Contact CHRISTOPHER JONES
P.O. Box 10335 5206 GRAMERCY DR
Des Moines, 14 50306 CLIFTON HEIGHTS, PA 19018-1003
First Unpaid Payment Due Date at time of this mailing: November 1, 2023
a
PAACTE
Wells Fargo Home Mortgage
PO Bax 9065
Temecula, CA 92589-9065
Return Address only
Do nol send payments to this address
January 4, 2024
CHRISTOPHER JONES
3206 GRAMERCY DR
CLIFTON HEIGHTS, PA 19018-1003
a
Where appropriate, Wells Fargo Home Mortgage is required to inform yoo that, ax your account servicer, we are
attempting to collect a debt and any information obtained will be used for that purpose.
Page } of I 278bb145eb
Wells Fargo Home Morgage
PQ) Box 9005
Temecula, CA 92589-9065
Return Address only
Do not send payments to this addres
January 4, 2024
CHRISTOPHER JONES
5208 GRAMERCY DR
CLIFTON HEIGHTS, PA 19048-1003
RE: Wells Fargo Home Mortgage Loan Number Sa
Maortgagor(s): CHRISTOPHER JONES, FRANCINE HAIRSTON
Mortgaged Premises: 5206 GRAMERCY DR
CLIFTON HEIGHTS, PA 19013
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear CHRISTOPHER JONES:
The mortgage held or serviced by Wells Fargo Bank, N.A. (hercinafier we, us or ours) on your property located at 5206
GRAMERCY DR, PA 19018 IS IN SERIOUS DEFAULT because you've not made the payments since November 1,
2023 through January 3, 2024. Late charges and other charges have also acertied 10 this date, The total amount now
required to cure the default, or in other woids, bring your loan current, is calculated below.
3 Overdue Payments Touling $3,866.72
Late Charge Balance $31.84
Other Fees, Unpaid Advance Balance $0.00
Unapplied Funds $0.00
Total Overdue amount as of January 3, 2024 $3,918.56
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the amount of
$3,918.56 plus any additional payments and late charges which may fall due during this period.
How to send your payment
You may send us your payments by phone or mail:
Phone: Call us at J-800- 416-1472 to make a one-time payment over the phone or obtain other payment options.
Mail: Write a check for the total overduc amount payable to Wells Fargo Home Mortgage. Be sure to include your
account number on your payment and send it fo us via regular or overnight mail:
Regular mail Overnight mail
Wells Fargo Hfome Mortgage Wells Fargo Home Mortgage
PO Box 77036 3440 Flair Drive
Minncapotis, MN $$480-7736 El Monte, CA 91731
Tf you do not cure the default within THIRTY (30) DAYS of the date of this letter, 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 duc immediately and you may lose the chance to pay off the original mortgage in instattiments.
If full payment of the amount of the default is not made within THIRTY (20) DAYS, we also intend to instruct our
attorneyts) to start a lawsuit to fureclose your mortgaged property. If the mortgage is foreclosed, your mortgaged
Page 3 of 4 O3bbLaSeb
property will be sold by a Sherifl(s) or other similar official(s} sale to payoff the morigage debt. Hf you cure the default
before we begin Icgal proceedings against you, you will siill have to
Preview
CIVIL COVER SHEET AND ENTRY OF APPEARANCE Delaware County Court of Common Pleas Court Term & No. Case Caption: Wells Fargo Bank, N.A. Christopher Jones, et al. ____Jury X__Non-Jury Arbitration ($0-$50,000) 2a Plaintiff(s) 2b Defendant(s) (Name and Address) (Name and Address) Wells Fargo Bank, N.A. Christopher Jones 11625 N Community House Rd 5206 Gramercy Drive Charlotte, North Carolina 28277 Clifton Heights, PA 19018 Francine Hairston 5206 Gramercy Drive Clifton Heights, PA 19018 3a Related Cases? Yes x x No 3b. Case Subject to Coordination Order? Yes _x_No If yes, show Caption and Case Numbers If yes, show Caption and Date of Order Entry of Appearance To the Office of Judicial Support: Kindly enter my appearance on behalf of Wells Fargo Bank, N.A., (a) plaintiff in this action. Papers may be served at the address set forth below. Katherine M. Wolf, Esquire Address: P.O. Box 165028 Attorney for party named above (please print) Columbus, OH 43216-5028 Atty File No: 24-003954 314307 Telephone: 614-220-5611; Fax: 614-220-5613 * Attorney |.D. Number E-Mail: KMWolf@manleydeas.com March 19, 2024 Attorney Signature Date Choose only the one description which best reflects the principal type of case or relief sought from the list Case Description APPEAL Intentional Tort Minor Court Assault and Battery Money Judgment Defamation Landlord and Tenant Employment/Wrongful Discharge Code Enforcement False Imprisonment Personal Injury Fraud Breach of Contract Malicious Prosecution Other Negligence Motor Vehicle Local Agency Real Property Civil Service Premises Liability Motor Vehicle Product Liability Licenses and Inspections Toxic Tort Liquor Control Board Asbestos Tax Assessment Boards DES Zoning Board Implant Other Toxic Waste Other, Proceedings Commenced by Pet Professional Malpractice Appointment by Arbitrators Dental Change of Name Legal Compel Medical Examination Medical Election Matters Other. Eminent Domain Equity Leave to Issue Subpoena Real Property Mental Health Proceedings Stockholders Derivative Action Other Waste Prevention Other, CIVIL ACTIONS COMMENCED BY WRIT OF Declaratory Judgment SUMMONS OR COMPLAINT Ground Rent Mandamus Abuse of Process Real Property Action for Wrongful Death Ejectment Class Action Quiet Title Confession of Judgment/Money Mortgage Foreclosure Confession of Judgment/Real Property Mechanics Lien Partition Construction Prevent Waste Insurance/Bad Faith Replevin Negotiable Instruments Saving Action Um/Uim Other Warranto Other. Manley Deas Kochalski LLC P. O. Box 165028 Columbus, OH 43216-5028 Telephone: 614-220-5611 Email: KMWolf@manleydeas.com IN THE COURT OF COMMON PLEAS DELAWARE COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A- 11625 N Community House Rd CIVIL DIVISION Charlotte, North Carolina 28277 NO.: Plaintiff. VS. Christopher Jones 5206 Gramercy Drive Clifton Heights, PA 19018 Francine Hairston 5206 Gramercy Drive Clifton Heights, PA 19018 Defendants. O2-PA-VIN 24-003954_MKM C2 NOTICE TO DEFE: NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within expuestas en las paginas siguientes. usted twenty (20) days afler this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta ascentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warmed that if you fail to do so alas demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se detiende, la cone judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso 0 notificacion, claimed in the complaint of for any other Ademas, la corte puede decider a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisiones de esta demanda, Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. You should take this paper to your lawyer at once. If you do not have a lawyer or cannot Lleve esta demanda a un abogado afford one, ga to or telephone the office set immediatamente. Si no tiene abogado a si no forth below to find out where you can get tiene el dinero suficiente de pagar tal servicio legal heip. Vaya en persona o llame por telefona ala oficina cuyu direccion se encuentra escrita Lawyers Reference Service abajo para averiguar donde se puede Delaware County Bar Association conseguir asistencia legal 335 WestFront Street Media, PA 19063 Lawyers Reference Service (610) 566-6625 Delaware County Bar Association 335 West Front Street Media, PA 19063 (610) 566-6625 HOUPA-V 1D 24-003954_ MKM CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank. N.A., by its attorneys, Manley Deas Kochalski LLC. and files this Complaint in Mortgage Foreclosure as follows: 1 The Plaintiffis Wells Fargo Bank, N.A., 11625 N Community House Rd. Charlotte. North Carolina 28277 (hereinafter "plaintiff"). The Defendant(s) is/are, Christopher Jones, with a last known address of 5206 Gramercy Drive. Clifton Heights, PA 19018 and Francine Hairston, with a last known address of 5206 Gramercy Drive, Clifton Heights, PA 19018. In order to protect the borrower's privacy, certain personal information of the borrower (such as loan account. Social Security numbers and birth dates), may have been partially or completely redacted on the exhibits to this Complaint. Wells Fargo Bank, N.A. directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. On or-about November 30. 2020, Christopher Jones and Francine Hairston made. executed and delivered to American Financial Network Inc. dba: Orion Lending, a Mortgage in the original principal amount of $163,975.00 on the premises described in the tegal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage was recorded in the Recorder's Office, Delaware County, Pennsylvania, on February 8, 2021, in Instrument Number 2021008934, and recorded in Book 6643, Page 5946. The Mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation OO2PA-V LO 24-003954_MKM to attach documents to pleadings if those documents are of public record. The folio number is 16130208600. Plaintiff is the current Mortgagee. By assignment of Mortgage recorded January 24, 2024, the mortgage was assigned to Wells Fargo Bank, NA, which Assignment is recorded in Office of the Recorder of Deeds for Delaware County as Instrument Number 2024002658, and recorded in Book 6954, Page 2383. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule retieves the Plaintiff trom its obligation to attach documents to pleadings if those documents arc of public record. Christopher Jones and Francine Hairston are the record and real nwner(s) of the aforesaid mortgaged premises. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the instaliments of principal and interest due November 1, 2023. 062-PA-VIO 24-003954 MKM As of 03/19/2024, the amount due and owing Plaintiff on the mortgage is as follows. The total amount due the Plaintiffon said Note through 03/19/2024 is $157,235.41 which breaks down as follows: Principal $152,894.39 Interest From 10/01/2023 to 03/19/2024 @ 2.5% $1781.15 Pre-acceleration Late Charges $103.68 Hazard Insurance Disbursements $0.00 Tax Disbursements $2,176.22 Property Inspections/Preservation $0.00 PMI\MIP Insurance $279.97 Other (specify charges/fees) $0.00 Escrow Balance Credit $0.00 Credits to Borrower $0.00 Total $157,235.41 Interest will continue to accrue until the date of judgment under the terms of the Note and Mortgage plus. interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited 10, costs (including escrow advances) and Plaintif?’s attorneys’ fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 962-PA-V 1G 24-003954_MKM 10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008. and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). A copy of said Notice is marked Exhibit C, attached hereto and made a part hereof. iN This action does not come under Act 91 of 1983 because the morigage is FHA insured. 12 This is an ém rer action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s) but reserves its right to do so ina separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding, this actionis inno way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $157,235.41, with interest thereon plus additional costs (including additional escrow advances), additional attorneys’ fees and costs and tor foreclosure and sale of the mortgaged premises. Respgctfully submitted, octhuwn VN). Dod Katherine M. Wolf, Esquire (314307) Meredith H. Wooters, Esquire (307207) Kimberly J. Hong, Esquire (74950) Michael E. Carleton, Esquire (203009) Alyk L. Oflazian, Esquire (312912) Cristina L. Connor, Esquire (318389) Ed E, Qagish, Esquire (309463) Manley Deas Kochalski LLC P. O. Box 165028 Columbus, OH 43216-5028 Telephone: 614-220-5611 Fax: 614-220-5613 Email: KMWolfi@manieydeas.com 62-FAV IO 24-003954_MKM or? cow Covyo VERIFICATION Farisha Demery, hereby states that he/she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiffin this matter, that he/she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ts Farisha Demery Vice President Loan Documentation Wells Fargo Bank, N.A. 03/20/2024 O86-PA-V3 I certify that this filing complies with the provisions of the Public Access Policy of the Unified Judicial System of Pennsylvania: Case Records of the Appellate and Trial Courts that require filing confidential information and documents differently than non-confidential information and documents. Kechuwne Woe Katherine M. Wolf, Esquire (314307) Meredith H. Wooters, Esquire (307207) Kimberly J. Hong, Esquire (74950) Michael E. Carleton, Esquire (203009) Alyk L. Oflazian, Esquire (312912) Cristina L. Connor, Esquire (318389) Ed E. Qagish, Esquire (309463) Manley Deas Kochalski LLC Telephone: 614-220-5611 Fax: 614-220-5613 Email: KMWolf@manleydeas.com Attorney for Plaintiff 062-PA-V10 NOTE ec FHA Case No. a toa Mil ptevercleicare| NOVEMBER 30, 2020 BROOMALL, PENNSYLVANIA {Date} {City] [State] 5206 GRAMERCY DR, CLIPTON HEIGHTS, FA 19018 [Property Address} 1, BORROWER'S PROMISE TO PAY Jn retum for a toan that | have received, | promise to pay U.S. $163,975.00 (this amount is called “Peincips!"}, plus interest to the order of the Lender. The Lender ts AMERICAN FINANCIAL NETWORK INC DBA: ORION LENDING. | will make ail payments under this Note in the form of cash, eheck or moncy order. 1 understand that the Lender may transfer this Note, The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder.” 2. INTEREST Interest will be charged on unpaid principal und! the full amount of Principal has been peid. [ will pay interest at a yearly rate of 2.500%, The interest rate required by this Section 2 is the rate J will pay both before and after any Survival Event as defined in this Note. 3. PAYMENTS {A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the LST day of cach month beginning on JANDARY 1, 2021.1 will make these payments every month until | have paid all of the principal and interest and any other charges described below that I may owe under this Note, Each monthly payment will be applied as of its scheduled due date and will be applied to interest and other items in the order described in the Security Instrument before Principal If, on DECEMBER 1, 2050, f still owe amounts under this Note, { will pay those amounts in full on that date, which is called the "Maturity Date." 1 will continue to pay those «mounts both before and after any Survivel Event as defined in this Note, until 1 have paid all of the principal and interest and any other charges described below that 1 may owe under this Note. twill make my monthly payments at 770 THE CITY DRIVE SOUTH, SUITE 1100, ORANGE, CA 92B6Borata different place if required by the Note Holder, (B) Amount of Monthty Payments My monthly payment will be in the amount of U.S, $647. 90. 4, BORROWER'S RIGIIT TO PREPAY [ have the right to make payments of Principal at any tine before they aie due. A payment of Principal only is known as a "Prepayment." When! make a Prepayment, | will teil the Note Holder in writing that | um doing so. | may not designate a payment as a Prepayment if L have not made all the monthly payments due under the Note. I may make a full Prepayment or partiz! Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that 1 owe under this Note. However. the Note Holder may apply my Prepayment to any accrued and unpaid interest on Lhe Prepayment amount before applying my Prepayment to reduce the Principat amount of the Note. [f] make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 5. LOAN CHARGES Ifa law, which applies to this loan and which sets maximum loan charges, is finafly interpreted so thal the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted lirnit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose ta make this refund by reducing the Principal I owe under this Note or by making a dircct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6, BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments er 36.84 Page 1 of 3 FHA Peunpylvania Fixed Rate Note - 05/416 peorerseL If the Note Holder has not received the full amouul of any monthly payment by the end of15 calendar days afler the date 1 is duc, J will pay a late charge to the Note Holder. The amount of the charge will be 4.000% of my overdue payment of principal and interest. 1 will pay this late charge promptly but only once on cach late payment. (B) Default 1f 1 de not pay the full amount of each monthly payment on the date it is due, | will be in default. (C) Notice of Default If] am in default, the Note Holder may send me a written notice telling me that if] do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and afl the interest that ] owe on thal amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Eveo if, at a time when | am in defauli, the Note Halder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if fam in default at a Inter time. (E) Payment of Note Holder's Costs and Expenses If the Note Halder has required me to pay ininiediately in fall as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable atiorneys' fees. | will pay the Note Holder back (ur those expenses paid by the Note Holder holh hefore and after any Survival Event as defined in tbis Note. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will he given by delivermy it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address, Any notice that nvust be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A)} uhove or ata different address if | am given 2 notice of that different address, 8, OBLIGATIONS OF PERSONS UNDER THIS NOTE If more (han one person sigos this Note, each person is fully and personally obligated to keep all of the promises tnade in this Note, including the promise to pay the full amount owed: Any person who is.a guarantor, surety or endorser of this Notc is also obligaled to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note, The Note Holder may enforce its rights under this Note against each person individually or against all ofus together. This means that any one of as may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor "Prescntment" means the right to require the Note Holder to demand payment of amounts due. “Notice of Dishonor” means the right to require the Note Holder te give notice (o other persons thal amounts duc have not been paid. 10. UNIFORM SECURED NOTE This Note isa uniform instrument with limited variations in some jurisdictions. In addition to the protectiuns given to the Note Holder under this Note, a Mortgage, Deed of Trust. or Security Deed (the "Security Instrument"), dated the same date as this Note, proicets the Note Holder from possible losses which might result if | do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions { may be required to make irsmediate payment in full of all amounts | owe under this Note. Some of those conditions are described as follows: [fall or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not 0 natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise ix prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of accelcration. The notice shall provide 6 period of not less than 30 days from the date the notice is given in accordance with Section 14 within which Borrower must pay all sums secured by this Security Instrument, If Borrower fails to pay these sums prior to the eapiratiun of ubis period, Lender may invoke any remedies permited by this Security Instrument without further notice or demand on Borrower. 11, EFFECT OF SURVIVAL EVENTS For purposes of this Note, "Survival Event” is defined as follows: a 36.f44 Page 2 of 3 FHA Pennsylvania Fized Rate Note - U5/16 BislOrsleiiste Resveerec) (a) any default described in Section 6(B) of this Note: (b) Noteholder requiriny me to pay immediately the Full amount of Principal which has not been paid and all the interest that 1 owe on that amount under Section 6(C) of this Note: (c) Noteholder requiring immedinte payment in full of ull swans secured by the Security Instrument; (d) the Maturity Date as defincd in this Note; (e) the entry of any judgment against me under this Note; and (£) the crury of any judgment under the Security Instrument. WIT. iegs THE-HAND(S) AND SEAL(S) OF THE UNDERSIGNED. Note a i 14 é i - BORROWEA - CHRISTOPHER JONES [Sigs Original Only) Individual Loan Originator: JOHN PILOYANTS, NMLSR ID: Loan Originator Organization: ATLANTIC FINANCE GROU! RR... wRERER BMRA Page 3 of 3 FItA Pennsylvania Fixed Rate Note - 08/16 = a ALLONGE AMERICAN FINANCIAL NETWORK INC. FINANGING THE AMERICAN ORBAN Loan Number: Ep Loan Date: 11/30/2020 Borrower(s): Christopher Jones Property Address: 5206 Gramercy Dr Clifton Heights, PA 19018 Principal Balance: $163,975.00 PAY TO. THE ORDER OF Wells Fargo Bank, N.A. WITHOUT RECOURSE COMPANY NAME: American Financial Network, Inc., DBA Orion Lending, A California Corporation fA ORA SVP of Onerations Richard Plummer Title WITHOUT RECOURSE PAY TO THE ORDER OF WELLS FARGO BANK, NA _ C o © o Uphi p h sull tes — R, SENIOR VICE PR ESIDENT, JACKIE G. MUELLE! ALLONGE TO THE NOTE-Orion (RP)-14 » Rev, 09/07/2016 Page lofi EXHIBIT B 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 Commonwealth of Pennsylvania, being Lot No. 719 on Plan No. 5 of Westbrook Park made by Damon and Foster, Civil Engineers of Sharon Hill, Pennsylvania, dated December 28, 1948 which Plan is recorded in the Office for the Recording of Deeds etc. in and for the County of Delaware aforesaid, at Media in Plan Case No, 7 Page 16, etc, and described as follows, to wit: Beginning at a point on the northwesterly side of Gramercy Drive (50 feet wide) which point is measured South 83 degrees 5 minutes West 411.75 feet from a point, which point is measured on the arc of a circle curving to the right having a radius of 25 feet, the arc distance of 38.64 feet from a point on the southwesterly side of Seven Oaks Drive (50 feet wide). Containing in front or breadth on the said Gramercy Drive 16 feet and extending of that widthin length or depth northwestwardly between parallel lines at right angles to the said Gramercy Drive and crossing the bed of a certain 12 feet wide driveway which extends northeastwardly into Seven Oaks Drive and southwestwardly, thence southeastwardly into Gramercy Drive 120 feet. The northeasterly and southwesterly lines thereof partly passing through the party walls between this premises and the premises adjoining on the Northeast and Southwest respectively. Together with the free and common use, right, libertyand privilege of a certain driveway as shown on the aforesaid Plan, laid out across the rear of these and adjoining premises, as and for a driveway and watercourse at all times hereafter forever, in common with the owners, tenants and occupiers of the lots of ground bounding thereon and entitled to the use thereof. Subject, however, tothe proportionate part of the expense of keeping said driveway in good order, condition and repair at all times, hereafter forever. Prior Deed Reference: Instrument Nuinber 2021008933, and recorded in Book 6643, Page 5941. 062-PA-VIO 24-003954_MKM WI Wells Fargo Home Morigaga PO Box 9065 PRESORT Temecula, CA 92589-9065 First-Class Mail U.S. Postage and Fees Paid wso 4 7200 L170 1254 bbeb 74 RETURN RECEIPT REQUESTED Send Payments to: Wells Fargo Home Mangage 3440 Flair Drive El Mante, CA 91731 20240105-67 Send Correspondence to. Wells Fargo Home Mortgage ee Written Customer Contact CHRISTOPHER JONES P.O. Box 10335 5206 GRAMERCY OR Des Moines, 1A 60306 CLIFTON HEIGHTS, PA 19018-1003 First Unpaid Payment Due Date at time of this mailing: November 1, 2023 O ee PAACT6 Wells Fargo Home Mortgage PO Box 90465 pyres Temacula, CA 92589-9005 Return Adldiess only Da not send payments to this address January 4, 2024 CHRISTOPHER JONES 5206 GRAMERCY DR CLIFTON HEIGHTS. PA 19018-1003 L Where appropriate, Wells Farge Home Mortgage is required to inform you that, as your account servicer, we are atiempting to collect a debt and any information obtained will be used for that purpose. Page | oft 9344 7200 LL?7C 2154 bbAab 74 Wells Fargo Home Mortgage bonne) FO Box 9065 By ticle) Temecula, CA 92589-9065 Keturn Address only Do not seed payments to this address January 4, 2024 CHRISTOPHER JONES 5206 GRAMERCY DR CLIFTON HEIGHTS, PA 19018-1003 RE: Wells Fargo Home Mortgage Loan Number Mortgugor(s): CHRISTOPHER JONES. FRANCINE HAIRSTON Mortgaged Premises: 5206 GRAMERCY DR CLIFTON HEIGHTS, PA 19018 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear CHRISTOPHER JONES: The mortgage held or serviced by Wells Fargo Bank, N.A. (hereinafter we, us of ours) on your property located at 5206 GRAMERCY DR, PA 19018 {8 IN SERIOUS DEFAULT because you've not made the payments since November {, 2023 through January 3, 2024. Late charges and other charges have also acerued to this date. The total amount now required to cure the default, or in other words, bring your loan current, is calculated below. 3 Overduc Payments Totaling 33,866.72 Late Charge Balance S3LR4 Other Fees. Unpaid Advance Balance $0.00 Unapphied Funds $0.00 Total Overdue amount as of January 3, 2024 $3,918.56 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the amount of $3,918.56 plus any additional payments and late charges which may fall due during this period. How to send your payment You may send us your payments by phone or mail: Phone; Call us at 1-800- 416-1472 to make a one-time paymeot over the phone or obtain other payment options. Mail: Write a check for the total averdue amount payable to Wells Fargo Home Mortgage. Be sure to include your account number on your payment and send i to us via regular or overnight mail: Regular mail Overnight mail Wells Fargo Home Mortgage Wells Fargo Home Mortgage PO Box 77036 3440 Flair Drive Minneapolis, MN 55480-7734 El Monte, CA 91731 If you do not cure the default within THIRTY (30} DAYS of the date of this letter, we intend to exercise our right to accelerate the morlgage payments. This means that whatever is owing on the original amount borrowed will be considered duc immediately and you may tose the chance to pay off the original mortgage in mstallments. If full payment of the umount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorney(s) to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged Page 3 of 4 F914 7100 3170 2154 bbab 74 property will be sold by a Sheriff(s) or other similar official{s} sale 10 payoff the mortgage debt. Hf you cure the default before we begin legal procecdings against you, you will still lave to pay the reasonable attorney(s) fees actually incurred, up to $50.00. However, if legal proecedings are started against you, you will have to pay the reasonable attorney(s) fees even if they are over 350,00. Any attorney(s) fees will be added to whatever you owe the lender, which may also inelude their reasonable costs, [If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney{s) fees. We may also sue you personally for the unpaid principal balance and all other sums duc under the mortgage. If you have not cured the default within THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any lime up to one four before the Sheri Ms) ur other similar official(s) foreclosure sale, You may do so by paying the total amount of the unpaid payments plus any 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 Sheriffts) or other similar official(s) sale could be held would be approximately four to six months from the date of this notice. A notice of the date of the Sheriff{s) or similar official(s) sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the tonger you wail. You may find out at any time exactly what the required payment will be. by calling ug al the following number: 1-800-416-1472, The payment musi be made by cash, cashicr’s check, certified cheek or money order made payable to us at the address stated above. For your own protection, please do not mail cash. You shoutd realize that a Sherif(s) or other similar official(s) sale will end your ownership of the mortgaged property and your right to remain in if. Lf you continue to live in the property afer the Sheriff's) or other similar officral(s) sale, a lawsuit could be started 10 evict you. You shall have the right to assert in the foreclosure proccedings, the nonexistence of a defaultor any other defense that you may have to acceleration or foreclosure. You have the additional right to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDER 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 OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY(S) FEES AND COSTS ARE PAID»PRIOR TO OR AT THE SALE AND THAT 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 this default, ihe 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. Sincerely, Default Management Department Wells Fargo Home Mortgage Page 4 af4 A3L4 7100 L470 1254 bbbb 74 UTA Wolls Fargo Home Morigage PRESORT PO Box 8065. Temecula, CA 92589-8065 First-Class Mail U.S, Postage and Fees Pad wsa 238bbL852b Send Payments to. Wells Fargo Home Mortgage 3440 Flair Orive €l Monte, CA 94731 20250105-67 Send Correspondence to. Wells Fargo Home Morlgage ae Written Customer Contact CHRISTOPHER JONES P.O. Box 10335 5206 GRAMERCY DR Des Moines, 14 50306 CLIFTON HEIGHTS, PA 19018-1003 First Unpaid Payment Due Date at time of this mailing: November 1, 2023 a PAACTE Wells Fargo Home Mortgage PO Bax 9065 Temecula, CA 92589-9065 Return Address only Do nol send payments to this address January 4, 2024 CHRISTOPHER JONES 3206 GRAMERCY DR CLIFTON HEIGHTS, PA 19018-1003 a Where appropriate, Wells Fargo Home Mortgage is required to inform yoo that, ax your account servicer, we are attempting to collect a debt and any information obtained will be used for that purpose. Page } of I 278bb145eb Wells Fargo Home Morgage PQ) Box 9005 Temecula, CA 92589-9065 Return Address only Do not send payments to this addres January 4, 2024 CHRISTOPHER JONES 5208 GRAMERCY DR CLIFTON HEIGHTS, PA 19048-1003 RE: Wells Fargo Home Mortgage Loan Number Sa Maortgagor(s): CHRISTOPHER JONES, FRANCINE HAIRSTON Mortgaged Premises: 5206 GRAMERCY DR CLIFTON HEIGHTS, PA 19013 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear CHRISTOPHER JONES: The mortgage held or serviced by Wells Fargo Bank, N.A. (hercinafier we, us or ours) on your property located at 5206 GRAMERCY DR, PA 19018 IS IN SERIOUS DEFAULT because you've not made the payments since November 1, 2023 through January 3, 2024. Late charges and other charges have also acertied 10 this date, The total amount now required to cure the default, or in other woids, bring your loan current, is calculated below. 3 Overdue Payments Touling $3,866.72 Late Charge Balance $31.84 Other Fees, Unpaid Advance Balance $0.00 Unapplied Funds $0.00 Total Overdue amount as of January 3, 2024 $3,918.56 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the amount of $3,918.56 plus any additional payments and late charges which may fall due during this period. How to send your payment You may send us your payments by phone or mail: Phone: Call us at J-800- 416-1472 to make a one-time payment over the phone or obtain other payment options. Mail: Write a check for the total overduc amount payable to Wells Fargo Home Mortgage. Be sure to include your account number on your payment and send it fo us via regular or overnight mail: Regular mail Overnight mail Wells Fargo Hfome Mortgage Wells Fargo Home Mortgage PO Box 77036 3440 Flair Drive Minncapotis, MN $$480-7736 El Monte, CA 91731 Tf you do not cure the default within THIRTY (30) DAYS of the date of this letter, 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 duc immediately and you may lose the chance to pay off the original mortgage in instattiments. If full payment of the amount of the default is not made within THIRTY (20) DAYS, we also intend to instruct our attorneyts) to start a lawsuit to fureclose your mortgaged property. If the mortgage is foreclosed, your mortgaged Page 3 of 4 O3bbLaSeb property will be sold by a Sherifl(s) or other similar official(s} sale to payoff the morigage debt. Hf you cure the default before we begin Icgal proceedings against you, you will siill have to