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Home My WebLink About00-00205 "'.'" ',.'-J"_C, .-~ .' McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Realty Corporation P.O. Box 8604 Elmhurst, IL 60126 v. Donald W. Shephard RR 3 Box 2045 Port Royal, PA 17082 and Amy C. Shephard 3824 Mountainview Road Mechanicsburg, PA 17055 ~. .',- "'~~"''''' --<I"~"~ ""~" - - "..l' -,-t-< /",,,..;,,;, '_,s-_~. - Attorney for Plaintiff Cumberland County Court of Common Pleas Number o2QXJ _ dO~ ~ CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the follCMing pages, you must take action within twenty (20) days after this complalnt 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 judr;Jllent may be entered against you by the court without further notice for any money claimed intheccrnp1aint 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 AVISO Lehan demandado a usted en lacorte. Si ustedquieredefenderse de estasd€lllandasex-puestasenlaspaginass1guientes,ustedtieneveinte (20) dias de plazo al partir de 1a feeM de 1a demanda y 1a notificacion. Hace falta asentar una comparencia escrita 0 en persona o con un abogado y entregar a 1a corte en forma escrita sus defensas 0 susobjecionesalasdemandasencontradesupersona. Seaav1sadoque s1 usted no se defiende, 1a corte tanara medidas y puede continuar la dsnanda en contra suya sin previa aviso 0 notificacion. Memas, 1a cortepuededecidir afavordeldsnandanteyrequ1erequeustedcw!pla contodas1asprovisionesdeestademanda. ustedpuedeperderdlnero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMAND A A UN ABOGADO INMEDIATAMENTE. SINOTIENEABOGADOO SI NO TIENE EL DINERO SUFICIENIE DE PAGAR TAL SERVICO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 '1'; I I i ! I I I I I i I I I , I , . I I I I I -'-J ,1-- . ~.~",--- '. ~ '-." ,-.-'....-,.,' 'J', .'"'.i:..i:i- - ".' ,,""1&>" "" '-----.'-"il '. , McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Household Realty Corporation P.O. Box 8604 Elmhurst, IL 60126 Cumberland County Court of Common Pleas v. Donald W. Shephard RR 3 Box 2045 Port Royal, PA 17082 and Amy C. Shephard 3824 Mountainview Road Mechanicsburg, PA 17055 Number CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Household Realty Corporation, a corporation duly organized under the laws of Delaware and doing business at the above captioned address. 2. The Defendant is Donald W. Shephard, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is RR 3 Box 2045, Port Royal, PA 17082. 3. The Defendant is Amy C. Shephard, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 3824 Mountainview Road, Mechanicsburg, PA 17055. .-- ~~ - -0 , - _c ~ " ~ C," ~ -- "_,~, ' ", :.,< .' '~'_'_~_ ," "c_ ,-, _" 'd_"-,,"'- ~ .i I I " I , i I I '. 4. On September 17, 1998, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1483, Page 1076. 5. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 3824 Mountainview Road, Mechanicsburg, PA 17055. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due May 1999 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance Interest 4/1/99 through 12/31/99 (Plus $4.15 per diem thereafter) Attorney's Fee Cost of Suit Appraisal Fee Title Search $ 6,950.43 $ 1,141.25 $ 1,500.00 $ 225.00 $ 125.00 $ 200.00 GRAND TOTAL $10,141. 68 8. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. __-" _l,", , ., ,c. ~ '_','d_ _, >~ ' "---','1,-,-. ".<' ".,-:.i, ~,- ,..", ..1';"0_"': ,_~"-_,,,-,~_--,=,,~;:,,,'~,,;._>_ ....."1 .. ,. 9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. ~403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by certified mail on the date set forth in the true and correct copies of such notices attached hereto as Exhibit HE." WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $10,141.68, together with interest at the rate of $4.15 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgage property. ~ ,il!c~ T RRENCE J. cCABE, ESQUIRE Attorney for Plaintiff . _II , VERIFICATION The undersigned, Renee Turner, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within action, Household Realty Corporation, and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. ~4904 relating to unsworn falsification to authorities. ~W%Wl RENE TURNER ~U~""""'"' "'''''o''tl;~", "~I_..!b ~'"-~ "~- ~~~~ . 713303-12-10Q28S MORTGAGE o IF BOl( IS CHECKED. THIS MORTGAGE 1$ A.N OPBN-BND MO'RTGAGl'. AND SECUli>.ES F\JT\Jll11 ADY ANCES THIS MORTGAGE is made this 17TH day of SEPTEMBER 19 ~ ' between the Mortgagor, DONALO W SHEPHERD AMV C SHEPHERD (herein "Borrower"), and Mortgagee HOUSEHOLD REAL TV CORPORAT I ON 3 corporation organized and <ll<isting under the laws of DELAWARE ,whose address is 25 GATEWAY DRIVE, GATEWAV SQUARE/SUITE 107, MECHANICSBURG, PA 11066 (herein "Leoder"). The following paragr<tph preceded by a checked box is applicable. II WHEREAS, Borrower is indebred to Lender in the principal BUm 01 $ , ~enced by Borrower's Loan Repaymant and Security Agreement Or Secondary Mortgage Loan Agreement dated and any extensions Or renewals thereof (herein "Note"), providing fOr monthly installments of ptlncipal and. lI'l.tsrest. including any adJustments to the amount of payments or the contract rate if that rate is variable, with the balance of the indebtedness, if not sooner paid, due and payable On CKJ WHEREAS, Borrower is indebted to Lender in the principal sum of .$ 6 , 500. 00 , Or so much thereOI as may be advanced pursuant to Borrower's Revolving Loan Agreement dated SEPT.EMBER 11, ,99a and extensions and renewals thereof (herein "Note"), providing for monthly installments, and intere8t at the rate and under the terms specified in the Note, including any adjustments in the interest rate if that rate is variable, and providing for a credit limit stated in the principal Sum above and an initial advance oi$ 6.695. 00 TO SECURE: to Lender the repayment of (I) the indebtedness evidenced by the Note, with interest ther<<Jn, illOluding any increases if the contract rate is variable; (2) futlQ'e advances under any Revolving Loan Agreement: (3) the payment of all otner sums, wIth interest thereon. advanced in aecordance herewith to protect the security 01 this Mortgage; and (4) the performance of the covenants and agreements of Borrower herein contained, Borrower does hereby mortgage, grant and convey to Lender and Lender's successors and assigns the following described property located in the County of CUMBERLANO Commonwealth 'of Pennsylvania: ." , ~~th~~ i~11o~ln9.d.dcrtb9~'lQt ot ~roU~~:.ltu4tef lying a~d . ~,. l'igbi1n. xu! p~P,naJ~~b1$'1' CQut\ty Qt C\lmblllrhndt eolllDOnwltl~lth of ,ennsl v~~ a'~D ~ tQt 3 ~,'UbdiYi'10A ~lin'fo~ Ha~.~t E. ~!.l'r'p~~~.re~ ~y Cro~G A..OQlat'., dated A~il 19, 1..1 and 8pproV9~ ~r th, oamml..1onerw ot ~d.~ ~Qwna~!~ an ~6 4th d6Y lOt AUljab1c:1 U~l and. d111Y ~6cOfd$4 in Ph" ~k 040, PtltJe 1M W~8l'lani!...I.eQ\\nt:y Re.M:t'dlJ; .lad known a.d '~8~4, Mt.~ Vbv ' R~.4~ ~~~~9~.~~d 1~b!t9d a. t~11qy~, t~ ~~tt : . . . . ~ . .8totNMING .t.~ po!n~,!n lino ot land;ho~ 'or 1.t4 of Balph Barly ._t th. nO~~~41f-~ t::cn:tJu of LotI;. No. ~,.tJb''th.'h~Anattl!t~ ",a"'tie-held .ubd~viB16M'~la~, !~. .~lY ~P.6tty. of ~4tqar4t ..'boimlOrt th6ncc ~10nq,\htll.v.'~~lr..1!n. ct IIda' r,gt,NO.:2' south' 4 'degr$U 48 : .td.nui:.'.,ti "ge6J1d~ w,.'=- '2:i9~.lt tootd:t1' A ~oiittf,on .ti1o tlQrtbu11' ll~. ~l.Nbt'~~4~~l ~~P'~Cf of Har9a~9t.*.'~~ert' ~hqnc. alohg ~.Ll~-t.f:.et.~ihG'''~4 cr.1~hlj thoo nd:l:'th~~tl t:.!"JIilnUtJ o~ .. J:Lght-o.f-lIar, l'Io~~~;8S tl~~tUi.:.~.!I!ilqt.41ll,S9 '.Of.Inds Ht... "'....'teet to en iron ~~h~""th~~'~.~10!~,P~oP:"r.~o. or 1.~.'Of~1111tm"ri".il., No.t. ,:.. iii. liiI.~t"'u.~ .2:....~ nU1::0' 'h llIBCl:nStfIJ WEllfb 2a~I~' tGot to an !rrm :pillt ;.~~~ ~.;,~&ha ~;~:!:~!tlJ.O.~f~""~,,?~~.'i:l.,4.grtll!lQ, 44' alnuf:el:,'l :,tIS' . ". ., ".l!UrP.UI'11.t"t t~,.l!i\.!tohdiil1:.at.'!ll1o ot:lahd. now or I]U"U'.'1t"lldl '.ltlld" :tbll16ii'M, th.'l.t~.t "Un.ll,'SoUth .t d.~..... ;,t:r~.~~~u~~~,f: ,,~..~~~~.dS: 2li1...~:24.,..,h,:tA.b ~d~ ~t~. ;l:laelll ol''U:(JJ;k'HI~O. , ' , : :...... ,r ";':-,"'.' ".' . ~.~.',,' :' '. .:...,'; :. . . . " .,. I 'i~' !Ul!i~'.W."'''~8 '~t:C1,iS~B'~~!~h Evan ~>'Dd~lh' ~hd 'D1a.~n" : .~. baieltt'l hill V\t8J' by ~ij6. d.atd4 7/111/_6 dl14 nl~:lI~rdill<< 7/19/Re , in thi Olt ~a.ot th~ k9~O~.~ 0: De64, !n a>>d t~~ CUmberland county , ~ebn.y1v.nj6" 1rt Re~ord eQqk L~~3-B39, 9~~nt.d and'~onva~.d ~nto ' . OW~YHK ~'. bBXlllZB tnd lWU:H ;., DBlllt.BB,'. .".' '.:' . I.. .'.Ii'.'; , ',." '.";.,,,. ~'th4' aail! c~~nt6r..~';, ~.~';"y Wilrr'11~:.j;P'~bl1Y ~... pto.erty ho;;;;t77~~:".;. ,...'.... "'::;:;:{" .' . .:. :...: :/.". .: ho~C'(!Ei"Acf313. .,:.:;." '.' ." ..... n7"2t-97 Morrgag. PA 'E'XHIBIT ~~'It:.' FilE COPY Illm~lmIIIIIIWlIIIOOMI~IWUlllllIIIIRmlllllmUillIUIIIII n/c0'd \7l.c105"Slc15 01 85>::" 919 0>::98NlJI()d3S lI:)/Ic:D-S;:JH ~;:J >::0 :01 55. >::c ()()N -~ -~ ..... ""'", "'" ~~ ~='" ~ ,I ~~ ~ '~.tl!jl...a.'" . --'",""",l"'~"'L*",,;';' . . . -2- tOGETHER with all th.. improvements now or hereafter eract<>d on the property, and all easements: rights. "'~ appurtenances an4 rents, all of which Shall be 4...meci to be and remoin a part of the pl'operty covered by this Mortgage; and all of the foregoing, together with said property (or the leasehold estate if this Mortgage is On a lesl;ebold) are hereinafter referred 10 as the "Property." !lorrower covenants that BOl'1'Ower is lswfuIIy seised of the ostllte hereby conveyed and has the rigln to mortgage, grant and convey the Propert]', and that the property is unenCllm bered, except for MCUm brances of ~ord. Borrower covenants that Borrow... Wa",Ants and will defend gen.raIly the title to the Property against aU claims and demands, subject to en= brancos of re<:Qrd. . UNil'ORM COVENANTR BorrOWer and Lender cov_nt and agree as fullow.: I. Payment of Principal and Interest at Variable Rates. This 'm<>rtgage secures all paymonts of princip$I ana in~est due on a ,-,mable rete loan. The oontra~-t ute of int.erost and payment amounts may be subject fa change as provided in the Note. Borrowers sh.I1 promptly pay when due all amounts required by tho Note. 2. Funds ior Tutos and fusurancc. Subject to appUcable law or waiver by Lender, Borrower shall p.y to Lend.r on !he day monthly payments 'of principe.! and interoBt are payable under the Note, until !h. Note is paid in full, a SUm (herein "Funds") equal to one-wrelfth of the yearly t.xes and ase=samen1S (including condominium .nd planned unit development .-ments. if any) which may attain priority over this MoftgJIge and ground rents on the Property, if ~, plus onc'twelfth of yearly premi1l1n installments for hazard insunn~. plus one_sHih of yearly premium illSlalIme:nte fot mortzage ioourance, if any, all 88 reasonably estimated initially and frum titrie to time by Lender 00 the basis 01 assessments and bills and reasonable estimates Ihereof. Borrower .hall ntJt be obligaled to make such paym""ts of Funds to Lender to th..eX".ent that Borrower makes such payments to the holder of a prior mnrtgage or dec:d of trust if such hoMer is an institutionl<! lender. II BOrTO",er pay. Funds to Lender, the Funds shall be held in an institution the deposits Or a""ounts of which arc instlred or guaranteed by a Federal or state agency (including Lender if Lender is StIohan institution). Lender shall apply the Fund. to pay said taxes. sssesaments, insurance premiumS .00 ground rool8. Lender m.ay not charge for so holding and applying the f\ln&>, analyzing said account or verifying and compiling said ~M""ts and bilIs, unless Lender pay. Borrower interEst on the Ftlnds and appIieable law permilS Lender to make suc,\ a ollarge, Borrower and Louder may agree in writing at the time of execution of thi. Mo~t8.ge that intor...t on the Funds shall be paid to Borrower, and unless .uoh agreement is mack> Or applicable law requires such ij\te~st to be paid, Lelld.r shall not be req,llired to pay Borrower any interest <lr ..rninss on the Funds. lr.nder shall give to Borrower, wIthout cMr!:e, an annual a<wunting of the Fun&> showing credits and ~bits to the Fuods and the purpose for whicb each debit to tbe Funds was made. The Funds arc ple<ige<l as additional ,"",urity for tJ\e sums seeure<i by this Mprl@age. If the amount of the F\.ll1ds held 'coy Lender, together wl1h the future monthly installments of Funds payable prior to th", due dates of taxes, assessments, insurance premiums and sroun,\'rents, shall c.c=l tb. amount requlre<! to pay said !aXei', assessments, insurance premiums and ground "",Is as they fall due, $uoh excess shall be. at Borrower's option. either promptly repaid tn Bo:rrower or credited to Bnrrower on monthly installmetlts of Funds. II the amnunt of the Funds beld by Lender shall not be sufficient to pay taxes, assessments, insurance premiums and ground rents as they faU due, Borrower Shall pay to Lender any amount necessary to make up tho deficiency in oile or more payments sa Lender may requlro. Upon payment in full nf all S'Jms _urod by this Mortgage, Lender shall promptly refund to Bom,wor any funds hsld by Lender. Jf under paragraph 17 heffilf the Property is sold or the Property is otherwise acquired by Lender, Lenoer wI! apply, 00 later than immediately prior to the sale at tbe Proparty Or ;1$ acquisition by Lender. any Funds held by Lender at the time nf application as " credit agaillst the sums seoured by this Mortgage. 3. Applic.ation ot Paymellts. &.c<lpt for luans mado pursuant to the Pennsylvania Consumer Disco\lllt Cornp.ny A~t, all payments re<<:ived by Lender under the Note and paragraphs I and Z b.eroof chol1 ~ applied by Lendet lira< in payment 'Of amounts payable to Le.nder by Borrower under paugraph 2 hereof, then to bteresr, ana then to the prinoipal. 4. Prior Mortgages and Deed 'Of Ttust; Charges; Liens. Eorrower shall perfonn .11 of Borrower's obligations under any mortg"8'" deed of trust or 'Other security agreemOl1t with . lien which has priority aver this Mortgage, inclUding Borrower's covenants tn make payments when dlle. Barrnwer shall pay 'Or ca= to ~ paid all taxes, . assessment!; and ather cMrges, fines and impositi'On.< attributable to lhe Proparty which may .tta10 . priority over !his M'Ortgage. and leasehold paymoo!." or ground renl8, it any. S. Hazard Insurance. Bnrrower shall keep the improvem ents now e:risting or her.&1rer erected on the Propert). in;;=d against In.. by fire, hazards included within the term "extended coverage: and such 'Other hazards 88 Lencler ro.ay require. Tbe illSUt.~ carrier providing the insurance shall be chosen by the Borrower subj""t Lo approval by Lender; provided, that such approval shall not be unreasonably withheld. AU jrunlrsnce policies and renewals thereof sltall be in " torm acceptable to Le:oder and shall include a standard mortgage clause in favor of and in a form aoceptable to ~der. Lender shall have tbe right to .hold the policies and rene".,.]. 1:I=00f, subject to thc term. of any mortgage. deed 'Of trust or other ...,unty agreement with a Ii"" which has priority oVlOl' this Mortg"$e. 07.ZI-17 Morts<,e fA PA001242 FIlE COr'Y IMWllllllnm~IIIIII~III.II~IIIIUlllllllllmU~III~U[~11 H/[0'd p~c106~S1c16 01 86[~ 919 0[98NIJI~~3S IIJ/IdJ-S~H ~~ [0:01 66, [c ~ON ~~~..... ~~ ,_I~I ~'Ii--" . . .,' -3- I I i'. I: Ii In the event of loss, Borrower aholl give prompt notice to the insurance came< and Lender. Lender m.ay make proof of loss if not made promplly by Borrow.r. If lhe Property is abandoned by Borrower, or if Borrower fails to fCSVOnd to iJ:nder within 30 days from the Cate notice ,is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for illS\ll'a/lCe benefits, Lender is aut/!Qn,.ed to colleot and apply the insurance proceeds at Lender's option either to =toration or repair or the Property or to the sums secured by this Morlg.ase. 6" Preservation and Maintenance of Properly; Leaseholds; Condominiunl$; Planned Unit Developmenls. Borrower shan keep the Property in &ood repair and shall not commit waste or permit impaiNl\Ct\t or deterioration of the Pro party and shall comply with the provisions of any lease if this Mortgage is On a leasehold. If this Mortgage i. on a unit in a condominium or a planned unil development, Borrower shall perform all of Borrower's obligations under the declantion or oovcnarrts creating or gov.rning the condominium or planned unit development, the by-laws and reg\llations of the condominium or planned unit development, and oonstituOIlt documents. 7. Protection of Lend"r's Security. If Borrow.". fails to per10rm the cov""ants and agreements cootained in this Mortgage, or if any action Or proceeding is commen<:ed which malet"ially affrota L""der's interest in the Properly, then Lender, at Lender's option, upon notice to &rroll'or, may make such appearanC08, disburse such sums. including reasonable attorneys' fees, and take such action as is necessary to protect Lender's intet""t. Any amOU'lts disbursed by Lt:nder pUfSUant 1'0 this paragraph 7, with inter""t thereon. at the eontIaot rate. shan beoomo additional indebtedness of J)orrower secured by this Mortgage. Unless Borl'Ower atld Lender agree to other terms of payment, such amount.~ shall be payable upon notice from Lender to Borrower requesting payment thereof. Nothing contained in this paragraph 7 shall requi", Lender to incur any expe;ose or take any action hereunder. 8. Inlilp!lX:tion. Lender may take or cause to be:; m*c;l..;: ~6ona'b1(: entries upon and inspeC'tions of the Property I provided that Lender shall give &rrower notice prior to any such insp""tion s~ifying reasonsble cause therefor related to Lender's inter...t in the Property. 9. COlldem:oatiOll. The prooeeds of any award or claim for damages, direct Or consequential, in connection with any condemnation or other taking of the Property, or part thereof. or for conveyance in lieu of condemnation, are hereby _igoed a'ld shall be paid to Lender, subjeet to the ~rms of My mortgage, deed of trust or other security agreement with a lien which h..~ priority over this Mortgage. 10. Borrower Not Rcleased; ForbearaD.ce By tender Not a Waiver. Ex.te1\sioo of the time for payment or modification of amortization of the sums secured by this MOl"lj:agc granted by Lender to any successor in interest of Borrower shall not operate to reIeasc, in any manner, the li.bility of the original :Borrower and Borrow...'. successors in intorest. Lender sMIl not be required to commence proceeclings against such successor 01' refuse to extend time for paytnent or othernise modify amortization of the sums secured by this Mortga&o by rcaaon of any demand made by the original Borrower and Borrower's successors in interest. Any forbearen.. by Lender in .exercising any right or remedy hereunder, Or oth"rwise afforded by applicable law. shall oot be a' waiver of Or preclude the ex.rcise of any such right Or remedy. 11. Succe..ors and Assigl),s Bound; Joint and Several Liability; Co-signers. The covenant!; and agreements herein conl<lined shall bind, and the rights hereunder sholl in\ll'e to, the respective successors aD.d assigns of Lender and Borrower, subject to the provisioOll of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and severaL kty Borrower who co-sigos this Mortgage. but does not ex""ute the Note. (a) is co-.lgning this Mortgage only to mortgage, grant and convey that Borrowe,r's interest in the Property to Lender under the terms of this Mortgage, (b) is not personally liable on the Note or under IMs Mortgage, and (c) agrees that Lender and any other Borrower hereunder may .gree in extend, modily, forbear, or mab any other accommodations with regard to the tertnS of this Mortgage or the Note without that Borrower's cOllsent and without releasing that Borrower Or mndifying this Mortgage as to that Borrower's ;ot= in the Property. 12. Notice. Except for any notice required under applicable law to be given in another manner, (0) any notic.. to Borrower ptO\'ided for in this Mortgage shall be given by delivering it or by mailing such aoti.. by certified mail addressed to Borrower at the Property Address or at such other addrOS$ as Borrower may deaignatc by notice to Lender as provided herein, and (1:>) any notice to Lender shall be given by certified mail to Lender's address stated herein Or to suoh other address. as Lender m.y designate by notice to Borro\\'et as provided herein. Any not.ioo provided for in this Mortgago shall be dccmc:d t.O have been sive.n to Borrower or lAnder wbm giv~n in the :rnaD!).e1" designated herein. 13. GoveOling Law; StJverability. The state and local laws applicable to this Mortgage shall be the laws of the jurisdiotion in which the Property is looated. Tho foregoing sentence slull1 not limit the applicability of Federal la,,' to this Mortgage. ltl the event that any provision or clause of this Mortpge or 'the Note connicts with applicable law, such conflict shall not affeot other provisions of this Mortgage or the Note which can be given effect without the conflicting provisioo, and to this eo.d the provisiOtlS of this Mortg:sge sod the Note are decl.,.ed to be sev,....bl.. As uoed he~in, .costs; 'expenses" aoo "attorneys' feoo. includa all suma to the extent not prohibited by applicable law or limited herein. 14. BOl'I'ower's Copy. Borrower shall be furnished a conformed copy of the Note SD.d of this Mortgage at the time of execution or aftor recordation hereof. 07-Z1-S7 Mons'S" fA I I 1,1 " I " i.; I, I:: I' I I 1-: I I I ~llE C01'y 1~11~~IIIIWIIIIIII~IIIIIIII.IIIIIIIIUllllllmJIlmlm lI~tBlllllllllll Ml101243 11/\'0' d p~ZT05~STZT5 01 85[~ 9T9 0[99NIJI~~3S IIJ/IdJ-S~H ~~ P0:0T 65, [Z ~ON --< ,~ - . pr-~.,,~"e.._-...."k~"~>->~","_ -4- IS. Reltabilitatiol:l Loan Agreement. Bc:>rrower shall I ~lfil1 all of Borrower's obligations under any home .'\, rehabilitation, improvement, rcpair, Or otber loan agreement which Borrower enters into with Lender. Lender, at Leoder's option, may require Borrower to ""ecute and deliv"," to Lender, in . form accoptable to Lender, an assignme.<lt of any rights, claims or <leIepses which llorrower may bave againBl parties who supply labor, mat.".;als or sc:rnce$ in connection with improvements made to the Property. 16. Transfer of the Property. lf Borrow... sells or transfers all or "lY part of the Property Or an interest therein, excl\lding (a) the creation of a lien or encumbrance subordinate to this Mortgage, (b) . ttanafer by devisc, descent, of by operation of law upon the death of . joint tenant. (c) the grant 0; any leaschold interest of three years Or less not containing an option to purehase, (d) the creation of a purchase mooey security intorest for household appliances, (e) a tratlllfer to a relative resulting from the de.tll of a Borrower, (f) a transfer where tho spouse or children of the Borrowor become an OWner of tho property, (g) a transfor resulting from . de.ree of dissolution of marriage, legal separation agr""m~nt, or from an incidental property settlemeJ'lt agreement, by which the spouse of the Borrower becom.... an oWner of tho property, (h) . transfer into an inler vivos trust in which the Borrower is and rem.ins .. beneficiary .nd ..hleh dOC$ not relate to a tra!\Sf... of rigb'" of occupanCy in the property, or (il any other transfer 01' disposition deacdbed in tOg1.1lations prescribed by the Federal liome Loan Bank Board, Borrower shall cause to be submitted information required by l.Aloder to evaluate the transferee as if a new loan were being made to the transferoo. Borrower will continue to be obligated under the Note and this Mortgage W'lIess Lender releases BouQwer in writing~ . If Lender does not agree to such sale or transfet. Lender may declare all of the S\lms sec\lrro by this Mertg.ge to be immediatcly due .nd pa),.ble. If Lender e;:erciscs such option to aeceler.te, Lcndor shaU mail BOtTo",.r notice of .<Xeiera.tion in accordance with poragraph 12 h.",of. Such noti"" shall provide a period of not 1_ tban 30 days from the elate the notice is mailed or do,liverod within which llorro,,'er may pay the sums declared due. If Borrower fails to pay such sumS prinr to the cxpiration of SUCh period, Lender may, without further notice or demand on Borrower, invoke any r=edies permitted by paragraph 17 he=f. NON-UNIFORM COVENANTS. Borroworand Lender further roven.nt and agree as follows: 17. A=leratiC>n; Remedies. Except a. provided in paragraph 16 hereof. \l1'on Borrower's breach of any eovel)Jlnt or agreement of Borrower in this Mortgage, including thc covenants to pay wilen due any sums secured by this Mortgage, Lendcr prior to acccleration sball give notice to Borrower as provided in poragraph 12 hereof specifyil'!;: (1) the breaeh; (2) tll. action required to e\lre such breach; (3) a date, not less tlul:o. 30 days from the date the notiee is mailed to Borrower, by which sueb breach must be cured; and (4) that failure to cure such breaeh on or before the date specified ill the "otice may ",sult ill acceleratio" of the sum. .""ured by this Mortgage. foreclosure by judicial proceeding. and ..le of tb. Pl:opcrty. The Il.otic:e .ball f\lrther inform BOn'ower of the right to reinstate after acceleration ."d the right to ..sert in the foreclosure proceeding the nonexistence of a defnlt or any other defense or Borrower to acceleration and foreclosure. If the breach is not cured on or be'ore the date specified in the notice, L""der, at Lender'" optiOl1, may declarc all of th" $ums sccured by this Mortgage to be imm.odiately due and payable without further ~.nd anil may foroclose this Mortgage by judicial proceeding. Leild"" shall be entitled to coUect in such proceeding all erpcnsc.s of foreclos\lre, including, but not limited to. reasoll.llble .tt~eys' fees and costs of documentary evidence, abstracts and title reports. 18. BOffower's Right to Reinstate, Notwithstanding Lender's aceel...ation of the ""tns oy this Mortgage due to Borrower's breach, Borrower shall have the rigbt to have an)' proceedings begun by L~r to enforce this Mortgage discontinued at any time prior to et>try of a judgment enforcing this Mortgage if: (aJ BottO"'er pays Lender all sums which would be then due under this Mortgage and the Note bad no .ccc1e....tloll occurred; (oj Borrower cures all breaches or any other ooveoante or igrocmente of Borrower contained in this Mortgage; (c) Borrower pays aU rOllsonable expen.ses inc\lrred by Lender in enforeing tbo covenants ."d agreemeors of Borrower contained i" this Mortgage, and in enforcing Under's remedies as provided in paragraph 17 hereof, including, but not limited to, r=nabIe attorneys' fees; ond (d) Borrower tokes such action a. Lender may reasonably roq"ire to assure that th" lien of this Mortgage, Lender's interest in the Property and Borro",or's obligstioX\ to pay tho BUmS $<Cured by this MOrtgage shall continue unimpaired. Upon such paym~nt and cure by Borrow<>J', this Mortgage and the obligations secured bereby shall remain in till! force .nd effect as if no accelcration had oecl.ltrcd, 19. Assignme.n.t of Reo.ts; Appointment of Receiver. As additional security hore\lnder, Ilorrower heroby assigns to Lender the tents of the Property. provided that Borrower shall, prior to acceleration un&t' paragraph 17 herM!, in abandonment of the Propert)., havc the rigbt to collect and retain suob rents as they become due and payable. Upon oeee1eration under pllt.graph 7 hereof or sbandonment of the Ptoperty, Und... shall be entitlood to have a ,,,,,,,iver appointed by a court to enter upon. take po_;on of and manage the Property and to coIlcct the rents of the Property including those past due. All tents oollectecl by the receiver sh3l1 be applied fitlll to payment of the costs of managem~t of tile Property and collection of renl$, including. but not limited to, receiver's fees, premiUMS on receiver's bonds and reasonable attorneys' fees, snd then to the sum. secured by this Mortgage. The ~ivet" shall be liable to .eCOIJnt (mly for those rents actually received. 07-21-97 M.ng.ge fA PA001244 fiLE COPY 1~lIllnlllllllll~I~I~IHllllllmmlllllll~lmllll 1kS0'd v6c1066S1c16 O~ 86[6 919 0[99NIJInd3S IIJ/ldJ-S~H d~ v0:01 66, [c nON ,-"""",~I'.~ - _L 1,__ .~ JlII,L.~~" ""' -5- 20. Release. Upon payment of all sums secured by this Mortgage, Lend..- shall release this Mortg"ge without charge to Bot'fQW.... :Borrower shllll pay all C06t$ of recordation, if any. 21. Waiver of Homestead. Borrower hereby waives all right 01 h()mes!eOd exemption in the Property under state or Federal law . 22. Interest Rate After l1ldgm.nt. Borrower agre.. the interest rate payable aftec .. judgment is ont<:red on the Sate or in an action of mortgage foreclosure shall be the rate stated in the Note. REQUEST FOR NOTICE OF DEFAULT AND FORECLOSURB UNDER. SUPERIOR . MORTGAGES OR DEEDS OF TRUST Borrower ."d Lender request the holder of any mortgage, deed 01 trust or other mcum bnnce with s lion which has priorityov$< this Mortgage to give Notice to Lender. at Lender's address set forth on pllge one of this Mortgag<;, of any default under the superior enoumbrance and of any sale or othor foreclOSUre action. Y#T) ~W. ~;::J~9 - DONALD W SHEP D -B<>rrowe~ ~i s~p~g-~row~ I hereby oertify that tho precise .ddress of the Lender (Mortgagoo) is: HOUSEHO L 0 F I NAN GF 25 GATETWAY DRIVE. ME~HANICSBURG. PA 17055 On behalf of thd..ender. By: MAlT HERMAN COMMONWEALTH OF PENNSYLVANIA, CUMBERLAND Title: BRANCH MANAGER County ss: I, ANNE A SI AFFORD , a Notary Public in and for said county and state. do hereby certify that DONALD W SHEPHERD & AMY C SHEPHERD petSOllally knOVln to me to be the ssm" person(s) whose name(s) are subseribed to the foregoing illBlrument, appeared before me this day in person; and aoknowledge that ~ hey_ signed and delivered the said j~rument as to heir fr.. voluntary""t, for the "50S and purposes therein s..t furth. Given undllr my hand :md offlc:ialaoal. this 17th <:layo! SEPTEMBER ,1998 . My Commission "llpires: ~ AlCN l<~~:~~~.: .:. NOTARIAL SEAL ANNE It. STAFFORD FA COI.IIIISSIONER OF DEEDS !If COMMISSION EXl'IR~ APRIL 02, 2001 This instrument was prepared by: ~ j?, ~'.I~ (No.. ;.-'''' ,~'''''~.~~<'-::'LO F~NAN...,E CORPOP.A-:-:C\ "" . '.:".':~U Drive, Sl..~te 107 k: ::;;:;:~~;ee.B"'ffl. ~ro~r&S5 ~ ..; 01-21-97 M.,,9'9' PA (Space :Below This Line a~\!;rved Por Lebdet 81\d Rcoor6et) Return To: Household Finance Corporation m Lamont Road Elmhurst, It 6()126 PAO01245 FILE COPY 1III!IIIm~IIIIID~mmllll.III~~gl.lllw~IIIII~llllllllllg~1 1V90'd p~c106~Slc16 01 86[~ 919 0[9~NI)I~d3S II)/Id)-S~H d~ S0:01 66. [c ~ON ~~~= ,~ ~. ~.L_ ~"L. ~.~ ~~ TERRENCE J. McCABE LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 FIRST UNION BUILDING 123 SOUTH BROAD STREET PHILADELPHIA, PENNSYLVANIA 19109 (215) 790.1010 FAX (215) 790-1274 SUITE 600 216 HADDON AVENUE WESTMONT, NJ 08108 (609) 858-7080 FAX (609) 858-7020 SUITE 1503 52 VANDERBILT AVENUE NEWYORK,NYIOOI7 (212) 697-0011 FAX (212) 953-0986 August 3,1999 Donald W. Shepherd 3824 Moutainview Road Mechanicsburg, PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgllge on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (BEMAP) may be able to help to save your home. This Notice explains how the program works To see ifHEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DA TE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice Tfyou have any questions, you ma,y call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869. EXHIBIT uan ~...~ ~.L - -I... . -.._~ "~j ["""'", This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO EN ADJUNTO ES DE SUMA lMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVlENDO EN SU CASE. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDlATAMENTE LLAMANDA ESTA AGENClA (pENNSYLV ANlA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: CURRENT LENDER/SERVICER: Donald W. and Amy C. SheJ)herd 3824 Mountainview Road, Mechanicsburg, P A 17055 713303-12-1092882 Household Finance Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOl J MA Y BE ELIGIBLE FOR FINANCIAL ASSIST ANCR WHICH CAN SA VR YOUR HOMR FROM FORECLOSURR AND HELP YOU MAKR FUTURR MORTGAGR PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: - IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, - IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IF YOU MEET OTHER ELIGffiILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORRCLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NRXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOlJR MORTGAGE lIP TO DA TE. THE PART OF THIS "-~. ~. .~ . ~1"~ NOTICE CALLED "HOW TO CORE YOUR MORTGAGE DEFAULT," EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DA TR. CONSUMER CREDIT Cot JNSELING AGENCIES--Ifyou meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end ofthis Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for fmancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you rnust fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have the applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) N A TORE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at 3824 MOlmtainvip,w Road, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: ...- ~~~",-. '" -.' ~~ YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following amounts are now past due: approximately $17600 for the months of May 1999 through July 1999 Other charges: TOTAL AMOUNT PAST DUE: $525.00 HOW TO CURE THE DEFAULT--Youmay cure this default within THIRTY (30) DAYS ofthe date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $525 00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa~ments must be made either b~ cash, cashier's check. certified check or mone~ order made payable and sent to: Margaret Smith Household Finance Corporation P.O. Box 4153 Carol Stream, IL 60197-4153 IF YOU DO NOT CURE THE DEFAULT--Ifyou do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rigbts to accelerate the mortgagp. debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (.10) DAY period, you will not be required to pay attorney's fees. OTHER T ,ENDER REMEDIES-- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--Ifyou have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by paying the total amount then past due, plus aI'\Y late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connecten with the Sheriff's Sale as ~ecified in writing- h.y the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. . .,--,~",-,o ~ >., '~-"'-',i ,- EARLIEST POSSIBLE SHERIFF'S SAT ,E DA TE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE I,ENDER: Name of Lender: Household Finance Corporation Address: PO Rox4153,CaroIStream,TL60197-4153 Phone Number: 1-800-609-4278, Fax Number: 630-617-7744 Contact Person: Margaret Smith EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSl JMPTION OF MOR TGA GE-- Y ou mayor X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: - TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. - TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. - TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) - TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LA WSurT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. - TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. "'. ""'~--~"-.~~ I "~.~~"L..l . ~" ,- - TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. THE PURPOSE OF THIS COMMUNJCA TION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE. Very truly yours, 111A(!l:dr TERRENCE J. McCABE TJM/dt SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBERZ 400 936199 RETURN RECEIPT REQUESTED -....,'j "'~ .. PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, Pa 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, Pa 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, Pa 17101 (717) 234-5925 FAX # (717) 232-4985 YWCA of Carlisle 301 G street Carlisle, Pa 17013 (717) 243-3818 FAX # (717) 243-3948 ~ 1 -~1:1 ii Ii 'I I 'I I II ;i :1 :1 ',I I' ,I Ii il :1 , ,I II 'I :! I n II Ii j :1 I Ii II II !I ,;1 II ii 'i I II I II - ~~" .. TERRENCE J. McCABE LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 FIRST UNION BUILDING 123 SOUTH BROAD STREET prnLADELPHIA,PE~SYLVAN[AI9I09 (215) 790-1010 FAX (215) 790-1274 August 3, 1999 Amy C. Shepherd 3824 Mountainview Road Mechanicsburg, P A 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE .J-~ hIUllillllllJiM)-', SUITE 600 216 HADDON AVENUE WESTMONT, NJ 08108 (609) 858-7080 FAX (609) 858-7020 SUITE 1503 52 VANDERBILT AVENUE NEW YORK, NY 10017 (212) 697-0011 FAX (212) 953-0986 This iR an official notice that the mortgage Oil your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (BEMAP) may be able to belp to Rave your home ThiR Notice eXJ)lains how the program works To see ifHEMAP can help, you must MEET WITH A CONSl JMER CREDIT COlJNSELING AGENCY WITHIN 30 DAYS OF THE DA TR OF THIS NOTICE. Take this Notice with you when you meet with the CounReling Agency. The name, addreRR Rnd phone numher of Consumer Credit Counseling Agencies serving your County are listen at the end ofthiR Notice. Uyou have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (l'ersons with impaired hearing can call (717) 780-1869 0- ~"~ - -~ ~ -~. _. I ~~o' ~ ,J.," I ~ ,~. ""', ; " This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASE. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGlBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: CURRENT LENDERlSERVICER: Donald W. and Amy C. Shepherd 3824 Mountainview Road, Mechanicshurg, P A 17055 713303-12-1092882 HOll~ehold Finance Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOl J MAYBE ELIGIBLE FOR FIN A NCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: -IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, - IF YOU HA VB A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPOR A RY STAY OF FORECLOSl JRE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCC1JR WITHIN - - - -"- ~ fi..J_, , ~~ ~ ."..~,-~ ~'li;,,~'- , . . THE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSIST ANCE, YOlJ MUST BRING Y01JR MORTGAGE UP TO DA TH. THE PART OF THIS NOTICE CALLED "HOW TO CURE Y01 JR MORTGAGE DEF AUL T," EXPLAINS HOW TO BRING Y01JR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--Ifyou meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numhers of clesignated consumer credit counseling agencies for the county in which the proJJerty is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's EmergencyMortgage Assistance Program. To do so, you rnust fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have the applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania. Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. or you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date.) d. LJ .'~ ~ ---""1-1 . , . N A TURF. OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at 3824 Mountainview Road, Mechanicsbu(g, P A 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following amounts are now past due: approximately $176 00 for the months of May 1999 through July 1999 Other charges: TOTAL AMOUNT PAST DUE: $52500 HOW TO CURE THE DEF A ULT-- Y ou may cure this default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $525.00, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or mon~ order made payable and sent to' Margaret Smith Household Finance Corporation P.O. Box 4153 Carol Stream, IL 60197-4153 IF YOU DO NOT CURE THE DEFAIJLT--Ifyou do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments", If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the TIDRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER T ,ENDER REMEDIES-- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CTJRE THE DEFAULT PRIOR TO SHERIFF'S SALE--Ifyou have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cllre the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by paying the total amount then past due, plus any late or other chm:ges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as sJlecified in writing by the lender and by performing any other "'~ , -....,.~~ ~...~ =~ .-" . . . ' requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DA TE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Household Finance COl:poriillim Address: P.O. Box 4153, Carol Stream, II. 60197-4153 Phone Number: 1-800-609-4278, Fax Number: 630-617-7744 Contact Person: Margaret Smith EFFECT OF SHERIFF'S SALE--You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE--You mayor X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: - TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. - TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. - TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL T HAD OCCURRED, IF YOU CURE THE DEF AUL T. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) - TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ~.~~ " , '"~ . , - TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. - TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR Tms PURPOSE. ~ J 1tt~cde TERRENCE J. McCABE TJM/dt SENT VIA REGULAR MAlL AND CERTIFIED MAIL NUMBER Z 400 936 200 RETURN RECEIPT REQUESTED .1 , \" " I , , I , I i (" [' L L H ii " i--! I ;-' Ii (;1 ;"i i I'; :-i i~:l I "'j I ! "j :'! ", " , " " '~I rj i" [:1 1'1 " i,! I h ~'i Ii II '" " - ., ~ ~~- .~ - . PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Lingleatown Road Harrisburg, Pa 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, Pa 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, Pa 17101 (717) 234-5925 FAX # (717) 232-4985 YWCA of Carlisle 301 G Street: Carlisle, Pa 17013 (717) 243-3818 FAX # (717) 243-3948 ~~ ~< -ilii,~j _i.JIo_"~~~"'~".-'-;- 1>""""~I~~IIi;M"IlJ~it.w"iJ -' '" -' -' -,' o Q ~2> B;~.~ 5'g!!!. ~fD3 go'O -~ i.~ ~ VI=: g,~'~ ~o(/l -....., c: m_ro <TOo. ","~ " " .. , McCabe, Weisberg & Conway, P.C. Snite 2080 123 South Broad Street Philadelpbia, Pennsylvania 19109 FORWARDING ADDRESS REQUESTED McCabe, Weisberg & Conway, P.e. Snite 2080 123 Sonth Broad Street Philadelphia; Pennsylvania 19109 FORWARDING ADDRESS REQUESTED . - ~.~ .- ~. Z 40,0 ''i36 200 MAIL _.~- -..~ . ::?..~ ._-.& 4\2-4; '--.4 < e; <t-IO ~-l C1 OAlOVED. ~ ,!l'!!TreMp./'CFrNOA .." \ ~NCI..4u.t. "a'Nor OOl1ess "'....... OfljoBUCH"a 0':;:0""" ."'d glN~u~U;~NS:;": 1JS<iJ1il 5 ADiJ":fs~AOO~.8S .0 ullAffl.eA$ /!N, I.<rOl'o ~s>::"" '1WA~o-'4L~ , " [ Ii' l, . Z 400 '136' 1'1'1 fL-, ..,' ~ "'-~_"'L;-;'~" j ..., "'"1'. ~(~ I 0-. I . 399 - , , ):,' ....~:pl.i _.....Jpff, ~:! '''I~-1:l'a' ~ .. j , -1 . " MAIL!.: , 0 ' , ' ~ P-5 !o ~~~mNOAODRESs ~ - JO "'" NCLAIM:' N," KNDWN ~ 0 oSUCHSl1 ORe~UB<D q. -.~~ ONOSUCliNU'RfEEr o INsu~'JCJS MBER ON," DELI NT ADDRess ADDReSS<D~\~As f/1!if/""fl. TO FoRWARD SEllwce.. . " I' i: f_: , " " i 1-: I e i I 1, ~~ , ~"""'_~_~"''''ilUlIi~''''''''t.__I_;w,~~~~_..!lIllJi.__ ~~ 1~ ~~ "J "~"~ r" (') ~ ~m t&?i ~O ig z =<1' ". \ . ~ 00 <:> -n '- ~? $; rt,:o -nJTi .-nO BQ (5-+1 ~:TO Om ~ -.J '< ..., :x fSl' ,- ~ . ~~ < - , I ~"',~-,- L .... SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-00205 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD REALTY CORP VS SHEPHARD DONALD W ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SHEPHARD DONALD W but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of JUNIATA County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On February 9th, 2000 , this office was in receipt of the attached return from JUNIATA Sheriff's Costs: Docketing Out of County Surcharge Dep. Juniata Co 6.00 9.00 10.00 25.40 .00 50.40 02/09/2000 MCCABE, WEISBERG S~~~ R. Thomas Kline Sheriff of Cumberland County & CONWAY Sworn and subscribed to before me this :2S~ day of :j.~..e"U<"7 :z o-1r'\J A . D . ~a.~~J Prothonotary .~. ~~ . SHERIFF'S RETURN - REGULAR CASE NO: 2000-00205 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD REALTY CORP VS SHEPHARD DONALD W ET AL ROBERT L. FINK , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHEPHARD AMY C the DEFENDANT , at 0015:55 HOURS, on the 14th day of January ,2000 at 3824 MOUNTAINVIEW ROAD MECHANICSBURG, PA 17055 by handing to AMY SHEPPARD a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So A;::~~~l~~ 18.00 9.30 .00 10.00 .00 37.30 R. Thomas Kline day of 02/09/2000 MCCABE, ~G & CONMAY ~ By:.. ~~~~__ Deputy Sheriff Sworn and Subscribed to before ~.-~ me this oC\j J~ c2=-0 A.D. Q i-- "#U..> (2 l1/LdP,.) ~ Iprothonotary , , . ' '. . ,. ..-,..... In The Court of Common Pleas of Cumberland County, Pennsylvania Household Realty Corp VS. Donald W. Shephard, et. al. Serve: Donald W. Shephard N 2000-205 Civil o. Now, 1/14/2000 , 20 J2f2, I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Juniata County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. . ~ Sheriff of Cuinb t Affidavit of Service Now, January 19, 2000 20 at 2:30 PM o'clock , --' M. served the within NOTICE & COMPLAINT upon Donald W. Shephard at RR 1, Box 2045, Port Royal, Juniata County, Pennsylvania . by handing to Carol Fry, girlfriend and person of suitable age & discretion a true and attested' copy of the original NOTICE & COMPLAINT and made known to HER the contents thereof. ,', So answers, O!!!~;,. ~.f!{Oo H. Thomas Lyter Sworn a~drfl~scribed me this ~ Clay of 20ot) , ----,- COSTS SERVICE MILEAGE AFFIDAVIT $ 18.00 5.40 2.00 $ 25.40 $ 49.60 ;r ~!'i~ISTt~A S!'SWARNER PEPt:rT:rPFIOTHON01ARY My Coinrrilsslon Elcpires Firsl Monday In Jan 2004 REFUND ~IliIUlIlWOt'-~'~~..~ ~- ~~;J._"""..~"",..,.-...."... . ~'" ~."""- ~~"''';~-~ .= .-'- .. ~ . .,..;;;,,:r.~~~~..:,....>... '.". " AlTEMf:!r6D SERVICS TIME MII..eAGl! IN 'A 1 2 3 4 o ---'.,..--4---____ 1'-" t__~_. , '........-'....................- .... D :D i> m rn;;f 0 m . . <: G }J - m ~ 0 0 );" ."" '1", . Q)' ~ .~."1 rrr,.- n' ". :!: :~.: in .,~. ;".;; ! \:J ;~: ,fl.} }".{ r~} ." . j::~ ,t."": I (:! ~ --~ n -:1 -., ,.j (;. -- :1~ fft W ~;. ... . ~ ? ~.; ~ "";.'\~ m m ~Iro j~/~ i Ie :>' ,;:~ ::.' ;.'II~~- "",, :..:~' oft, : t,~ fl,....." _'''''''''''''- ,,-'-_...~,.~...J~".... _'~' , 1 '""n .. - v.. , t;' " o li .. ;;-.' , -.. 'C'. _ '.} -, ~-L ;. -.~ - , ,_^, I.~' '--'-',,,~"-,,,..,,,,,,I--., "~'- ,,"-.,,, ,~, ,,',--,'"i,.~,;,,--_,,<,..,_ -'.b~''- ",_,_"" ~ I" [' &' l' McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff ri t [;' i] fi, r; I" HOUSEHOLD REALTY CORP CUMBERLAND COUNTY COURT OF COMMON PLEAS if il TI r, t ~~ r " , ~- ~, F Kj , ~ ~: , " I, I t " V. DONALD SHEPHARD and AMY SHEPHARD NUMBER CV-OO-20S Defendant ORDER TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter discontinued and ended upon payment of your costs only. !/'~ TERRENCE Attorney for P ( tr~ ..... ';"T ,-;J ,n, liiiIi~.. -. .-.-,CIliil - ~^ - -' " ',>" , ., o ~ ~ulj} rrlr-:-' ~;;;~ -'< i~~ ~ c.::, (,.. ::::> r', :_-=) !'V .. Q ',-... :--.-; <=:} ::: -< -,-, ;i,~.~ .=::'\ "1,::,">- ::..; -- ,::;J ~