IN THE COURT OF COMMON PLEAS Allegheny COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. GD-19-013754 NOTICE OF ACTION IN MORTGAGE FORECLOSURE KEYBANK S/B/M FIRST NIAGARA BANK, NA Plaintiff vs. The Unknown Heirs of Mary H. Worthy, Deceased, ANGELA MICHELLE MORGAN A/K/A Angie Morgan, Solely in Her Capacity as Heir of Mary H. Worthy, Deceased & KENNETH E. MORGAN, SOLELY IN HIS CAPACITY AS HEIR OF MARY H. WORTHY, DECEASED Mortgagor and Real Owner, Defendant The Unknown Heirs of Mary H. Worthy, Deceased MORTAGOR AND REAL OWNER, DEFENDANT whose last known address is 512 Delmont Avenue Pittsburgh, PA 15210. THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. You are hereby notified that Plaintiff KEYBANK S/B/M FIRST NIAGARA BANK, NA, has filed a Mortgage Foreclosure Complaint endorsed with a notice to defend against you in the Court of Common Pleas of Allegheny County, Pennsylvania, docketed to No. GD-19-013754 wherein Plaintiff seeks to foreclose on the mortgage secured on your property located, 512 Delmont Avenue Pittsburgh, PA 15210 whereupon your property will be sold by the Sheriff of Allegheny. N O T I C E You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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. ALLEGHENY COUNTY BAR ASSOCIATION 400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 412-261-5555 Michael T. McKeever Attorney for Plaintiff KML Law Group, P.C., PC Suite 5000, BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322