OFFIT KURMAN, P.C. By: Jason E. Powell, Esquire (ID No. 309032) 2000 Market Street, Suite 2700 Philadelphia, PA 19103 Tel: (267) 338-1300 Attorney for Plaintiff, Fax: (267) 338-1335 Reverse Mortgage Funding, LLC jason.powell@offitkurman.com ____________________________________________________________________ REVERSE MORTGAGE FUNDING, LLC, COURT OF COMMON PLEAS OF PERRY COUNTY, PA Plaintiff, v. CIVIL ACTION – LAW CATHLEEN M. HASS, No. CV-2024-587 JOHN C. McLAREN, JR., VINCENT R. McLAREN, JAMES D. McLAREN, and HOLLY THUMMA, Defendants. ________________________________________________________________ TO: HOLLY THUMMA NATURE OF THE ACTION On July 17, 2024, Plaintiff Reverse Mortgage Funding, LLC ("Plaintiff") filed a Complaint against Defendants Cathleen M. Hass, John C. McLaren Jr., Vincent R. McLaren, James D. McLaren, and Holly Thumma (collectively, "Defendants") in the Court of Common Pleas of Perry County, Pennsylvania, Case No. CV-2024-587 (the "Action"). The purpose of the Action is to quiet title to real property located at 405 Pisgah State Road, Shermans Dale, PA 17090 (the "Property"). Specifically, and as alleged in the Complaint, the Property – which was owned by John C. McLaren and Ruth J. McLaren, husband and wife – was divided into four lots (Lots 1, 2, 3, and 4), with John and Ruth McLaren retaining ownership of Lot 1; conveying Lot 2 to their son and daughter in law, Vincent and Thelma McLaren; and conveying Lot 3 to their son John C. McLaren, Jr. John Mc Laren, Sr. died on March 22, 2014, leaving his wife Ruth McLaren as sole owner of Lot 1. On or about July 16, 2017, Ruth McLaren obtained a reverse mortgage on Lot 1. As part of that transaction, Ruth McLaren signed an Adjustable Rate Open-End Home Equity Conversion Mortgage that was recorded on August 7, 2017 as instrument number 201705311 (the "Mortgage"). Plaintiff is the owner and holder of the Mortgage and the note it secures. The address shown on the Mortgage for the collateral was 405 Pisgah State Road, Shermans Dale, PA 17090, which is the address for Lot 1. As a result of mutual mistake, unilateral mistake, or scrivener's error, the Mortgage identified the incorrect property as collateral for the Mortgage. Specifically, instead of identifying the Property (i.e., Lot 1) as collateral, as the parties intended, the Mortgage incorrectly identified adjoining property to Lot 1 (the "Additional Property"). At the time of the execution of the Mortgage, Ruth McLaren no longer had an ownership interest in the Additional Property. Ruth McLaren passed away on March 5, 2020. On August 5, 2020, Ruth McLaren's will was accepted for probate and filed with the Register and Recorder of Perry County with instrument number 202004925. Under the terms of the will, Lot 1 passed to Ruth McLaren's five children, who are the five Defendants in the Action. In the Complaint, Plaintiff seeks a declaratory judgment that Plaintiff is the owner and holder of the Mortgage and the note it secures for the Property (i.e., Lot 1), and that the Property (i.e., Lot 1) is collateral for the Mortgage. Alternatively, Plaintiff seeks to reform the deed and include the correct legal description: Lying and Being in Carroll Twp, Perry County PA and being all of Lot 1 as shown on plat recorded in Plat Book 18 at Page 12 of the Perry County Public Registry. NOTICE If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the 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. MidPenn Legal Services 213-A North Front Street Harrisburg, PA 17101-1492 (800) 326-9177 or (717) 232-0581 -or- YWCA Legal Center 16 West Main Street New Bloomfield, PA 17068 (717) 582-2660 or (717) 724-0516 OFFIT KURMAN, P.C. By: /s/ Jason E. Powell Jason E. Powell, Esquire Attorney for Plaintiff, Reverse Mortgage Funding, LLC Oct 1