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Home My WebLink About97-01938 '? , . .~ 9: Cj. . ~ ~ t9 ~ ~ '" ~ ~r < t i cj t-\ "cl .'.............. u ' t cw .... \- :2 "2 ~ u cJ " " J~ , , I ! / ,,/ ~_t' " ,I" ! Ii ~. 15725642 MERRI R. LANE Attorney 1.0. No. 37617 400 Market Street Twelfth Floor Philadelphia, Pennsylvania 19106 215.922.0066 Attorney for Plaintiff GREEN TREE CONSUMER D1SC6UNT COMPANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. q7- GREEN TREE CONSUMER DISCOUNT COMPANY 332 Minnesota Street SI. Paul, Minnesota 55101 Plaintiff /43r ~ v. MICHAEL N. GRIFFIN ERIKA G. REED afkIa ERIKA GRIFFIN 196 Willow Mill Park Road Mechanicsburg, Pa. 17055 Defendant(s) TERM COMPLAINT IN MORTGAGE FORECLOSURE NOTICE TO DEFEND NOTICE Yo. haw ...... 11IId fa QlIIrt. It yO. wills la dafcn4,apjasl " Ibe daia tot fanls ill I" followiac pqa. yOII' /IIUlaP actIoa MdIlII 1_" (2DI cia" alia llda "'......1 aad naUc8 ... ..... by IllIaiq .. wriuea awaaaca ~y ar by IUDrDIY uscIl1IIa.l. writIaJ wilh I,," "'11ft yOur dar..... or ..IlJI~- 10 I,," cIaIn 111 fonb apWl yau. YOII..._d IllaIlf )'011 ~ 10 da 10 lbe CUI may pracnd wilholll YOlIlDd. JIldJa-I ..y "" IIII11Wd ap!usl YCl1I by I,," COIll't ",ho," I'Ilnlllf nolleo for aoy -r dallllld in It. ,,"..,,1ailI1 Dr for IDY olbor cIalm Dr rdIIf roq.slCd by tbe 1I!ailI1Iff, VOII may "* """"" Dr I'IO","Y Dr olbor riahllllll1'O'wu la YOII, YOU SHOULD TAKE THlS PAPER TO VOUR LAWYER AT ONCE. IF YOU DO NOTIlAVEA LAWYER OR CANNOT AFFORD ONE. CO TO OR TELEPHONE THE OmCE SET FORTH BELDW TO FIND OUT WHERE YOU CAN eET LECAL HELP, SEE ATTACHED AV'SC La' haa.-....... .,.... .. Ia _ S11l11ed qaim cII!a"I.... .. da ._.. 'iI ""- .. !all pif/IiII siplonl'" ...... lIMo ..... (2DI dIa da'plam al JlUtir da Ia l'tcIIa do Ia dImuda r Ia IlOIllIcadOa. Ita ralla .....ar _ "'....... ~ acrl1lI 0 .. por..,. 0 coa .. abopda r otmapr I II cone .. fo.... acrila I" dal'_ 0 111I abjocl..... a laa cia1I1aDdaI CIS CllIItra da 10 \lIrIDlIL Su arisado q.. Ii lIItacl no . dIfIaadI. II com 1011III& IIIOCIIdu r puodl _aolllt Ia dalltllllla III CDIItra 11Il'Il da prnIo aYlla 0 ..ollftc:aclOa. AdtmU. II com ..- daddIr . f.",r dtI domancta"tl Y rwqlliln q.. U11ld aurIl'Ia COG todu loa PlDrisIonas do IS" dlmaoda. lIstld pIlIda pordor dlal'O 0 111I PlDpiodada II Otl'Ol dlndlos h..""nIllIG para lilted. LLEVE ESTA DEMANDA A UN ABOCAOO IN. MEDIATAAIENTE. $1 NO nENE ABOGADO 0 $1 SO nENE EL DINERO $UFlCENTE DE PAC.l.R TAL SERVICO. VAVA EN PERSONA 0 LLAIoIE POR TELEFONO A LA ORCNA CUY A DIRECCON SE ENCUENTRA ESCRlTA ABAJO PARA .l.VERIGUAR DON DE SE PtlEDE CONSEeUIR ASISTENClA J.E(;.l.L. SEE ATTACHED' .. I . f: . J Where arc lawyer referral servic~ available? . - At the prescnt time, there arc nineteen local referral services in Pennsylvania, 3I\d they serve twenty counties. If you live in one of those counties or need 31\ attorney there, you should conlllel that county referral service, Each loCai service is operated by the county bar association. If you live in a county that docs not have a local service, telephoDe the Pennsylvania Lawyer Referral Service oPcraled by the Pennsylvania Bar Association. You should also phone the Pennsylvania Lawyer Referral Service if you need a lawyer in a county without a local service, even if you don'llive there. If you need an attorney in a state other than Pennsylvania, contact that stale's bar association by calling directory information and requesting the telephone number. Most stales have local or state refeml services, and the state bar association will be able 10 direct you 10 them. REFFERAL SERVICES IN PENNSYLVANIA For COWIli.. Without, local Kni", CZlDI)'lvacia Lawyer Rd'cmI5<tvi", 1 SoulhSlr<<I H' PA 17108 717. 8-6713 (llanisl>uraanaaodoutor.....caIlm) 1-8 .73" (ToU fRo in PA, outside Ilanisl>ura ana) ALLEO COUNTY.PITTSBUROH AIl<&hmY au ] 10 Orant SL 410 Orant BuDdin8 l'ituburJb, PA 15119. 0] 411.161~518 DAIJPHIN CO~mY.HARJUSBURO Dauphin Counry au Auociallon 11] North Frool Slr<<l HanisbuT& PA 17101 717.131.7l36 DElAWARE COUNTY.MEDIA Delawue Counry au AuociaIioo Froo1 A Lemon SIre<lJ Modi.. P A 1906] 610.5~15 LUZERNECOUNTY. WlLKES-BARRO Willt...1lano Libr.uy AaocU1ioo Room 13 Will< 71 MONTGOMERY COUNTY- NORRlSTOWN MONTGOMERY COUNTY BAR ASSOCIATION 100 WEST AIRY STREET P.O. Box168 Nmislawo, PA 19404 0168 610.170.9660 BEA VEIl COUNTY.BEA 77541h Slr<<I BcaVCl', PA 15009 412.718-4888 ERIE COUNTY.ERIE Eri, Counry au AuociaIioo 50lSusafiuSlr<<I Eri.. PA 165D7 814-459.]111 BERKS COUNTY.READINO Ilcrlu COOllI)' au ADo<iatioo 544 Court Slr<<I P.O..Box 1058 Radin&. PA 1960] 610.37l-4591 BLAIR COUNTY HOUlDAYSBURO, Blair Coumy au AuociaIlon Counhow<o Librvy Hollida)'lburs. PA 16648 814-695.5541 Cll1. 418 NORlllAMPTON COUNTY. EASTON NonhamptDa au Auociallon W South 9Ih Slr<<I Easloo, PA 1&041 213.1'8-6]3] BUCKS COUNTY. DOYLESTOWN Iludts Coumy au AuociaIioo 135 East Slalo Slr<<I DoylcslaWll, PA 18901 215.]48-941]1S36-84]5nsl.1666 LEIIIOH COUNTY.ALLENTOWN Lehisb COOllI)' au ADo<iation Old Cow1howI, Room ]04 F'Ulh A Hamihon Sl:<CU AIlcmown, PA 18105 115-43].7094 YORKCOUNTY.YORK Yed< Counry au AJoociatioo Courlhowa Vorl<, PA 17401 717-854-8755 WASHlNOTO WASHlNOTON WuhinglDnCOOllI)' Bu 'on 513 Wuhin&!oo Trust BuD Washinglllll, PA mOl ' 412-155-6710 CHESnR COUNTY. WESTCl!EsTER Cbcsl<t au Associalloo 13 West Oay Slrect . West Cbat<r, PA 19 610-696-5094 ,/ g~~:~R~~~~NISTRATOR 1 COURTHOusiOsCOURTHOUSE 4th FLOOR CARLISLE QUARE (717) 240 :;0017013 3387 . (a). By written assignment Vinyl Exteriors Inc. assigned said mortgage to plaintiff herein GREEN TREE CONSUMER DISCOUNT COMPANY. Said assignment was recorded in the office of the Recorder of Deeds of CUMBERLAND County. 2. Each defendant is an individual whose name and last residence is stated in the caption and the interest of each is as Mortgagor and real owner, The information regarding the Mortgage is as follows: Mortgaged Premises: 196 Willow Mill Park Road Mechanicsburg, Pa. 17055 MunicipalityfTownship/Borough: City of Mechanicsburg County: CUMBERLAND Date Executed: November 30,1995 Date Recorded: Book: Page: The legal description of the mortgaged premises is attached hereto as Exhibit "Au, 3. The mortgage secures Defendant(s) certain Note dated November 30, 1995 In the amount of $21,500.00 with interest at the rate of 12.340% per annum payable in monthly payments of $262.76,plus interest and escrow payments. A copy of the Mortgage and Note is attached hereto as Exhibit "B". If the United States of America is named as a defendant then th United States of America claims a federal tax lien against the mortgage premises as set forth In Exhibit "F" attached hereto. 4, The Mortgage is in default because of defendant(s) failure to make the payment due August 15, 1996 and the following amounts are due on the Mortgage: Principal Balanca Interest from July 15, 1996 to March 15, 1997 Attorneys Fees Cumulative late charges Costs of suit and title search $21,339.26 I) '100.07 $1,066.96 $45.00 400.00 Subtotal 12'1) ~5"/.~4 .:; ,'~" IF' :J ~v. i' .'~ . Escrow Deficit Credit TOTAL 5. The attorney's fees, set forth above are in comformity with the Mortgage documents and Pennsylvania law, and will be collected in the event judgment is entered against the defendants, If the Mortgage is reinstated prior to judgment being entered, reasonable attorney's fee will be charged. 6. If required, Notice of Intention to Foreclose has been sent to Defendant(s) by Certified Mail as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the date set forth in the true and correct copy of such notice attached hereto as Fxhibit "C". 7. Notice required by Pennsylvania Act 91 has been sent to each defendant and is attached hereto and marked Exhibit "D" and each Defendant has either failed to proceed thereunder within the prescribed time limit, or has been determined ineligible or Plaintiff has not been notified of Defendant's eligibility in a timely manner. If this Mortgage is insured by the Federal Housing Administration (FHA) under Tille II of the National Housing Act, by the FHA as above described, then the notice described in this paragraph is not required and has not been sent and therefore no copy is attached. WHEREFORE, the Plaintiff demands judgment against each defendant herein, jointly, severally in the total sum stated in paragraph 4 plus interest from JUly 15, 1996 at the rate of $7.22 to the date of judgment and other costs and charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged property. DATE: March 25,1997 z,~~ MERRI R. LANE Attorney for Plaintiff 15725642 MERRI R. LANE Attorney 1.0. No. 37617 400 Market Street Twelfth Floor Philadelphia, Pennsylvania 9106 215-922-0066 Attorney for Plalnllff GREE TREE CONSUMER DISCOUNT COMPANY GREEN TREE CONSUMER DISCOUNT COMPANY 332 Minnesota Street St. Paul, Minnesota 55101 Plaintiff : NO, v. MICHAEL N, GRIFFIN, et 81 . : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY Defendant(s) TERM VERIFICATION I, the undersigned heeby verify that I am a representallve of the plalnllff and I am authorized to make this Verification. I hereby verify that the facts set forth In the foregoing Campi Int are true and correct to the best of my Information and belief and th t this statement Is made subject to the penalties of 18 Pa. C,S.A. 4904 relating t unsworn falsification to the aulhorltles. Oale:3-.;75-Q7 f~R1.JHrJ-u~ , f , , '. ~ G~15 1721B19 320 13534 PENNSYLVA " 1{"7).<) 6'1:J.. Prepared by and Return tOI Green Tree Consumer Discount Company Home Improvement Division 332 Hinnesota St., suite 610 st. Paul MN 55101 " !";t. Commonwealth of Pennsvlvanla CT,15l9090 19/94) Space Above This Une For Recording Data OPEN.END MORTGAGE This Mortgage secures future advances 1. DATE AND PARTIES. The date of this Mortgage (Security Instrument) Is Z~..,I.I.:..J.p..:7.~.........,........., and the parties, their addresses and tax Idenllflcatlon numbers, If required, are as follows: MORTGAGOR: Hichael N Griffin and Erika GReed. 196 Willow Hill Park Rd Hechanicsburg PA 17055 .....,If checked, refer to the attached Addendum Incorporated herein, for additional Mortgagors, their signatures and acknowledgments, LENDER: VINYL EXTERIORS INC SUITE BBBB GREENTREE SQ HARLTON NJ OB053 2. CONVEYANCE. For good and valuable consideration, the receipt and sufficiency of which Is acknowledged, and to secure the Secured Debt (defined below) and Mortgagor's performance under this Security Instrument, Mortgagor grants, bargains, conveys and mortgages to Lender the following described property: Parcel 10' 3~- /6-10'0' or:; I (see attached legal) "AKA ERIKA GRIFFIN The property Is located In ,..........,...........9.Il1:1.1l!l1!~l\1IP........................,...., at ,...,.,.....,...........,....,............... (County) 196 !f!.n'?,':'..1:I1t\..r.!\f.~..J;l.r;I.......,..............., ....,......H!!!':h!\n!.9,~.I;>,':'"g,..,........... , Pennsylvania ....H9.?L.......,. IAdd'fII) ICily) (ZIP Cod.) Together with all rights, easements, appurtenances, royalties, minerai rights. 011 and gas rights. all water and riparian rights, ditches, and water stock and all existing and future Improvements, structures, fixtures, and replacements that may now. or at any time In the future, be part of the real estate described above (all referred to as "Property"). EXHIBIT PENNSYLVANIA. MORTCMjE (NOf roll: nIM^. "Iwe. rIIAOl\ VAUSt) I c 1994 ".."~.,. htttmt.'nc., St. CloO'f, J4N 11 800 1911141) FOlm rom MfCLAlrA 10/11/9 () CT 15.)9 O~ IQ/94' (pdf" of 1':1 '""'" ., , ~ 3. MAXIMUM OBLIGATION LIMIT. The total principal amount secured by this Security Instrument at any one time sh~1I not el\ceed S...,..fi................21saa..ao........... This limitation of amount does nQllnclllde ".. Interest and other fees and c arges validly made pursuant to th 5 Security Instrument, A 50, this ,limitation does not apply to advances made under the terms of this Security Instrument to protect , Lender's security and to perform any of the covenants contained In this Security Instrument. 4. SECURED DEBT AND FUTURE ADVANCES. The term .Secured Debt" Is defined as follows: A, Debt Incurred under the terms of all promissory note(s), contraclls), guaranty(s) or other evidence of debt described below and all their extensions, renewals, modifications or substitutions. (When referencing fhe debfs below If Is suggested that you Include Items such as borrowers' names, note amounts, Interest rates, maturity dates, etc,) The 8ecured debt i8 a note I IIome Improvement Retall In8tallment Contract I executed by the mortgagor I borrower on ~ ; 11.1v , 19~ 8, All future advances from lender to Mortgagor or other future obligations of Mortgagor to lender under any promissory note contract, guaranty, or other evidence of debt executeCl by Mortgagor In favor of Lender executed after this Security Instrument whether or not this Security Instrument 15 speCifically referenced. If more than one person Signs this Security Instrument each Mortgagor agrees that this Security Instrument will secure all future advances and future obligations that arc given to or Incurred by anyone or more Mortgagor, or anyone or more Mortgagor and others. All future advances and other future obligations are secured by this Security Instrument even though all or part may not yet be advanced, All future advances and other future obligations are secured as If made on the date of this Security Instrument. Nothing In this Security Instrument shall constitute a commitment to make additional or future loans or advances In any amount, Any such commitment must be agreed to In a separate writing. C. All obligations Mortgagor owes to lender, which may later arise, to the extent not prohibited by law, Including, but not limited to, liabilities for overdrafts relating to any deposit account agreement between Mortgagor and lender, D. All additional sums advanced and expenses Incurred by lender for Insuring, preserving or otherwise protecting the Property and Its value and any other sums advancea and expenses Incurred by Lender under the terms of this Security Instrument, This Security Instrument will not secure any other debt If lender falls to give any required notice of the right of rescission. 5. PAYMENTS. Mortgagor agrees that all payments under the Secured Debt will be paid when due and In accordance with the terms of the Secured Debt and this Security Instrument, 6. WARRANTY OF TITLE. Mo:tgagor warrants that Mortgagor Is or will be lawfully seized of the estate conveyed by this Security Instrument and has the right to grant, bargain, convey, sell, and mortgage the Property. Mortgagor also warrants that the Property Is unencumoered, except for encumbrances of record. 7. PRIOR SECURITY INTERESTS, With regard to any other mortgage, deed of trust, security agreement or other lien document that created a prior securlly Interest or encumbranc~ on the Property, Mortgagor agrees: A, To make all payments when due and to perform or comply with all covenants, 8, To promptly deliver to lender any notices that Mortgagor receives from the holder, C. Not to allow any modification or extension ofl nor to request any future advances under any note or agreement secured by the lien document w thout lender's prior written consent. B. CLAIMS AGAINST TITLE. Mortgagor will pay all taxes, assessments, liens, encumbrances, lease payments, ground rents, utilities, and other charges relating to the Property when due, lender may re'lulre Mortgagor to provide to lender copies of all notices that such amounts are due and the receipts evidencing Mortgagor's payment, Mortgagor will defend title to the Property against any claims that would Impair the lien of this Security Instrument. Morlgagor agrees 10 aSSign to lender, as requested by Lender, any rights, claims or defenses MOrlgagor may have against parties who supply labor or materials to maintain or Improve the Properly. 9. DUE ON SALE OR ENCUMBRANCE. lender may, at Its option, declare the entire balance of the Secured Debt to be Immediately due and gayable upon the creation of, or contract for the creation of, any lien, encumbrance, transfer or sale of the Progeny. This right Is subject to the restrictions Imposed by federal law (12 C.F.R. 591), as applicable. This covenant shall run with the Property and shall remain In effect until the Secured Deblls paid In full and lhls Security Instrumenlls released, 01994 hn",,, SYlllm',ItK., 51 Clo~d. MN 41 lOa J91114l) fUlm GTlI...,W1PA 10/11/94 &r " II DiG {f1t4' ,,,,.1"" , , ~ ,,-. 10. PROPERTY CONDITION, ALTERATIONS AND INSPECTION. Mortgagor will keep the Property In good condition and make all repairs that are reasonably necessary. Mortgagor shall not commit or allow any - waste, Impairment, or deterioration of the Property, Mortgagor wllll<eep the Property free of noxious '.. . weeds and grasses, Mortgagor agrees that the nature of the occupancy and use will not substantially '. 'thange without lender's prior written consent, Mortgagor will not permit any change In any license, restrictive covenant or easement without lender's prior written consent, Mortgagor will notlty lender of all demands, proceedings, claims and actions against Mortgagor, and of any loss or damage to the Property. lender or lender's agents may, at lender's option, enter the Property at any reasonable time for the purpose of Inspecting the Property, lender shall give Mortgagor notice at the time of or before an Inspection specifying a reasonable purpose for the InspectIon, Any Inspection of the Property shall be entirely for lender's benefit and Mortgagor will In no way rely 011 lender's Inspection, , 11. AUTHORITY TO PERFORM. If Mortgagor falls to perform any duty or any of the covenants contained In this Security Instrument, lender may, without notice, perform or cause them to be performed, Mortgagor appoints lender as attorney In fact to sign Mortgapor's name or pay any amount necessary for Ilerformance, lender's right to perform for Mortgagor shal not create an obligation to perform, and lender's failure to perform will not preclude lender from exercising any of lender's other rights under the law or this Security Instrument. If any construction on the Property Is discontinued or not carried on In a reasonable manner, lender may take all steps necessary to protect lender's security Interest In the Property, Including completion of the construction. 12. ASSIGNMENT OF lEASES AND RENTS. Mortgagor Irrevocably grants, bargains, conveys and mortgages to lender as additional security all the right, title and Interest In and to any and all existing or future leases, subleases, and any other written or verbal agreements for the use and occupancy of any portion of the Property, Including any extensions, renewals, modifications or substitutions of such agreements (all referred to as "leases") and rents, Issues and profits (all referred to as "Rents"). Mortgagor will promptly provide lender with true and correct copies of all existing and future leases, Mortgagor may collect, receive, enjoy and use the Rents so long as Mortgagor Is not In default under the terms of this Security Instrument, Mortgagor agrees that this assignment Is Immediately effective between the parties to this Security Instrument. Mortgagor agrees that this assignment Is effective as to third parties when lender takes affirmative action prescribed by law, and that this assignment will remain In effect during any redemption period until the Secured Debt Is satisfied. Mortgagor agrees that lender may take actual possession of the property without the neceSSity of commencing legal action and that actual possession Is deemed to occur when lender, or Its agent, notifies Mortgagor of default and demands that any tenant pay all future Rents directly to lender. On recelvln9 notice of default, Mortgagor will endorse and deliver to lender any payment of Rents In Mortgagor s possession and will receive any Rents In trust for lender and will not commingle the Rents with any other funds, Any amounts collected will be applied as prOVided In this Security Instrument. Mortgagor warrants that no default exists under the leases or any applicable landlord/tenant law. Mortgagor also agrees to maintain and require any tenant to comply with the terms of the leases and applicable law. 13. lEASEHOLDS; CONDOMINIUMS; PLANNED UNIT DEVELOPMENTS. Mortgagor agrees to comply with the provisions of any lease If this Security Instrument Is on a leasehold. If the Property Includes a unit In a condomInium or a planned unit development, Mortgagor will perform all of Mortgagor's duties under the covenants, by-laws, or regulations of the condominium or planned unit development. 14. DEFAULT. Mortgagor will be In default If any party obligated on the Secured Debt falls to make payment when due, Mortgagor will be In default If a breach occurs under the terms of this Security Instrument or any other document executed for the purpose of creating, securing or guarantying the Secured Debt, A good faith belief by lender that lender at any time Is Insecure with respect to any person or entity obligated on the Secured Debt or that the prospect of any payment or the value of the Property Is Impaired shall also constitute an event of default, 1 S. REMEDIES ON DEFAULT. In some Instances, federal and state law will require lender to provide Mortgagor with notice of the right to cure or other notices and may establish time schedules for foreclosure actions. Subject to tHese limitations, If anYblender may accelerate the Secured Debt and foreclose this Security Instrument In a manner provided y law If Mortgagor Is In default, At the option of lender, all or any part of the agreed fees and charges, accrued Interest and prinCipal shall become Immediately due and payable, after giving notice If required by law, upon the occurrence of a default or ~nytlme thereafter, In addition, lender shall be entitled to al the remedies provided by law, the terms of the Secured Debt, this Security Instrument and any related documents, All remedies are distinct, cumulative and not exclusive, and the lender Is entitled to all remedies provided at law or equity, whether or not expressly set forth. The acceptance by lender of any sum In payment or partial 01'194 lIan"." CjYt!'f?1I, ''''t.. 51. Cloucf. Wt 11 ..... 1072]41) rfJfm eTII MTCL\lrA, 10/11/94 Cl '': 19M!) fO/9.) (('aI' '''(l'il """'" -.. , ' , payment on the Secured Debt after the balance Is due or Is accelerated or after foreclosure proceedings are flied shall not constitute a waiver of Lender's right to require complete cure of any existing default. <'.- By not exercising any remedy on Mortgagor's default, Lender does not waive Lender's right to later , ", consider the event a default If It continues or happens again. 16. EXPENSES; ADVANCES ON COVENANTSj ATTORNEYS' FEESj COLLECTION COSTS. Except when prohibited by law, Mortgagor agrees to pay all of lender's expenses If Mortgagor breaches any covenant In this Security Instrument. Mortgagor will also pay on demand amount Incurred by Lender for Insuring, Inspecting, preserving or otherwise protecting the Property and Lender's security Interest. These expenses will bear interest from the date of the payment until paid In full at the hlgheSl Interest rate In effect as provided In the terms of the Secured Debt, Mortgagor agrees to pay all coSU and expenses Incurred by Lender In collecting, enforcing or protecting Lender's rights and remedies under this Security Instrument. This amount may Include, but Is not limited to, allorneys' fees, court cosu, and other legal expenses. This Security Instrument shall remain In effect until released. Mortgagor agrees to pay for any recordation costs of such release. 17. ENVIRONMENTAL LAWS AND HAZARDOUS SUBSTANCES. As used In this section (1) Environmental Law means, without limitation, the ComprehenSive Environmental Response, Compensation and Liability Act (CERCLA, 42 U.S,C. 9601 et seq.l, and all other federal, state and local laws, regulations, ordinances, court orders, attorney general opinions or Interpretive lellers concernlnllthe public health, safety, welfare, environment or a hazardous substance; and (2) Hazardous Subnance means any toxic, radioactive or hazardous material, waste, pollutant or contaminant which has characteristics which render the substance dangerous or potentially dangerous to the public health, safety, welfare or environment. The term Includes, without limitation, any substances defined as "hazardous materIal," "toxic substances," "hazardous waste" or "I,azardous substance" under any Envlronlllent~llaw. Mortgagor represents, warrants and agrees that: A. Except as previously disclosed and acknowledged In writing to Lender, no Hazardous Substance Is or will be located, stored or released on or In the Property. ThIs restriction does not apply to small quantities of Hazardous Substances that are generally recognized to be appropriate tor the normal use and maintenance of the Property. B. Except as previously disclosed and acknowledged In wrlllng to Lender, Mortgagor and every tenant have been, are, and shall remain In full compliance with any applicable Envlronmenlallaw. C, Mortgagor shall Immediately notify Lender If a release or threatened release of a Hazardous Substance occurs on, under or about the Property or there Is a violation of any Environmental Law concerning the Property, In such an event, Mortgagor shall take all necessary remedial action In accordance with any Environmental Law, D, Mortgagor shall Immediately notify Lender In writing as soon as Mortgagor has reason to believe there Is any pending or threatened InvestIgation, claim, or proceeding relallng to the release or threatened release of any Hazardous Substance or the violation of any Environmental Law. 18. CONDEMNATION. Mortgagor will give Lender prompt notice of any pending or threatened action, by private or public entities to purchase or take any or all of the Property through condemnation, eminent domain, or any other means, Mortgagor authorizes Lender to Intervene In Mortgagor's name In any of the above described actions or claims. Mortgagor assigns to Lender the proceeds of any award or claim for damages connected with a condemnation or other taking of all or any part of the Property. Such proceeds shall be considered payments and will be applied as provided In this Security Instrument. This assignment of proceeds Is subject to the terms of any prior mortgage, deed of trust, security agreement or other lien document, 19. INSURANCE. Mortgagor shall keep Property Insured against loss by fire, nood, theft and other hazards and rIsks reasonably associated with the Property due to Its type and location. This Insurance shall be maintained In the amounts and for the periods that Lender requires. The Insurance carrier providing the Insurance shall be chosen by Mortgagor subject to lender's approval, which shall not be unreasonably withheld. If Mortgagor falls to maintain the coverage described above, Lender may, at Lender's optIon, obtain coverage to protect lender's rlghll In the Property according to the terms of this SecurIty Instrument. All Insurance policies and renewals shall be acceptable to Lender and shall Include a stanclard "mortgage clause" and, where applicable, "loss payee clause." Mortgagor shall Immediately notify Lender of cancellation or termination of lhe Insurance. Lender shall have the right to hold the policies and renewals. if Lender requires, Mortgagor shall Immediately give to Lender all receipts of paid premiums and renewal nOllces. Upon loss, Mortgagor shall give Immediate nollce to the Insurance carrier and Lender. Lender may make proof of 1055 If nol made Immedlalely by Morlgagor. o 1994hnklnSy)uml,In(.,SlCkJud.',m 1I100)il1UII 'u,m(.lIIMltt.AlI".A 10111/\14 GI U JI 090 191141 (pD,.4 of 61 I'. f-" r'" Unless otherwise agreed In writing, all Insurance proceeds shall be applied to the restoration or repair of the Property or to the Secured Debt, whether or not then due, at lender's option. Any application of " . proceeds to principal shall not extend or postpone the due date of the scheduled payment nor change the amount of any payment, Any excess will be paid to the Mortgagor, If the Property Is acquired by '", lender, Mortgagor's right to any Insurance policies and proceeds resulting from damage to the Property before the acquisition shall pass to lender to the extent of the Secured Debt Immediately before the acquisition. 20. ESCROW FOR TAXES AND INSURANCE. Unless otherwise provided In a separate agreement, Mortgagor will not be required to pay to lender funds for taxes and Insurance In escrow, 21. FINANCIAL REPORTS AND ADDITIONAL DOCUMENTS. Mortgagor will provide to lender Upon request, any financial statement or Information lender may deem reasonably necessary, Mortgagor agrees to sign, deliver, and flJe any additional documents or certlflcatlons that lender may consider necessary to perfect, continue, and preserve Mortgagor's obligations under this Security Instrument and lender's lien status on the Property, 22. JOINT AND INDIVIDUAL LIABILITY: CO.SIGNERS: SUCCESSORS AND ASSIGNS BOUND. All duties under this Security Instrument are Joint and Individual. If Mortgagor signs this Security Instrument but does not sign an evidence of debt, Mortgagor does so only to mortgage Mortgagor's Interest In the Property to secure payment of the Secured Debt and Mortgagor does not agree to be personally liable on the Secured Debt, If this Security Instrument secures a guaranty between lender and Mortgagor, Mortgagor agrees to waive any rights that may prevent lender from bringing any action or claim against Mortgagor or any party Indebted under the obligation, These rights may Include, but are not limited to, any antl.deflclency or one.actlon laws. Mortgagor agrees that lender and any party to this Security Instrument may extend, modify or make any change In the terms of this Security Instrument or any evidence of debt without Mortgagor's Consent, Such a change will not release Mortgagor from the terms of this Security Instrument. Tne duties and benefits of this Security Instrument snail bind and benefit the successors and assigns of Mortgagor and lender, 23. APPLICABLE LAW: SEVERABILITY; INTERPRETATION. This Security Instrument Is governed by the laws of the Jurisdiction In which lender Is located, except to the extent otherwise required by the laws of the Jurisdiction where the Pmperty Is located, This Security Instrument Is complete and fully Integrated. This Security Instrument may not be' amended or modified by oral agreement. Any section In this Security Instrument, attachments, or any agreement related to the Secured Debt that conflicts With applicable law will not be effective, unless that law expressly or Impliedly permits the variations by written agreement. If any section of this Security Instrument Cannot be enforced according to Its terms, that section will be severed and will not affect the enforceability of the remainder of this Security Instrument, Whenever used, the singular shall Include the plural and the plural the singular. The captions and headIngs of the sections of this Security Instrument are for convenience only and are not to be used to Interpret or define the terms of this Security Instrument. Time Is of the essence In this Security Instrument. 24. NOTICE. Unless otherwise required by law, any notice shall be given by delivering It or by mailing It by first class mall to the appropriate party's address on page 1 of this Security Instrument, or to any other address designated In writing, Notice to one mortgagor will be deemed to be notice to all mortgagors. 25. WAIVERS. Except to the extent prohibited by law, Mortgagor waives any right io appraisement relating to the Property. 26. OTHER TERMS. If checked, the following are applicable to this Security Instrumeflt: ...... line of Credit. The Secured Debt Includes a revolving line of credit provision, Although the Secured Debt may be reduced to a zero balance, this Security Instrument will remain In effect until released. ,X... Construction loan, This Security Instrument secures an obligation Incurred for the construction of an Improvement on the Property. ...... FIxture FlIlng. Mortgagor grants to Lender a security Interest In all goods that Mortgagor owns now or In the future and that are or will become fixtures related to the Property. This Security Instrument suffices as a finanCing statement and any carbon, photographic or other reproduction may be flied of record for purposes of Article 9 of the Uniform Commercial Code, ...... Purchase Money. This Security Instrument secures advances by lender used In whole or In part to acquire the Property. Accordingly, this Security Instrument, and the lien hereunder, Is and shall be construed as a Purchase money mortgage with all of the rights, priorities and benefits thereof under the laws of the Commonwealth of Pennsylvania. a 19~4 hnh" 'liYJI,ml, I,.. 51. (rourf. MN 11 11M 1971)111 rnrM GTII Mrr.IAlrA IO/II/IIi roT I~ l~noo 1'1/91) I..~ltf '''(II --.. ~ , ...... NOTICE TO BORROWER: THIS DOCUMENT CONTAINS PROVISIONS FOR A VARIABLE INTEREST RATE. " ...... Riders. The covenants and agreements of each of the riders checked below are Incorporated Into and supplement and amend the terms of this Security Instrument, [Check all applicable Items) lUll Condominium Rlder~(,~.. Planned Unit Development Rider Ijl.fl, Other ................,.................... .....' Additional Terms. SIGNATURES: By signing below, Mortgagor, Intending to be legally bound hereby, agrees to the terms and covenants contained In this Security Instrument and In any attachments, Mortgagor also acknowledges receipt of a copy of this Security Instrument on the date stated on page 1, 1h:~!.f.-#:t?!.d.:....qfh:..."......./1.1.:3~ ~5::....,..,....,........................................,..............,...,. ISlgnl'u,,) 7'(7...... (Oil.) (Slgnl'u,,) (om) II ~~~~~~~...~" ~.~,~ ,~.~~~, ...,.....,. .......,...., ......, .Vt.t3 ~ .? r-:',.."......., ............,.,.., .....,.... ............. .......".....,...,.. VV ~lgnlCure.) IDate) (Slgnlture) (Oil e) ~!.~ft~rr..~ ,;..R~,fJ&........".......,......," MUnus) ..~ ............................................................................ ('Nllnlu) ACK.~~~~~'::%~::i.?~.wovm. ,COUtnY OF;(1f:f.~~'1 " On this, the i.l~............... day of .iL.................I/......'J:l!.9.fS~o~ei..., "~g:;"~.u ,1nd~~...Q th nil rslgned offlc r per~allY appeared ;'::...../.!If.p...f.:r..~,;;;............... .. ...., ..oc., ,~..., ,+oQ ..l!.#.k~"'t;....!R:.....~.~.............................................. known to me (or satisfactorily ven) to be the person(s) whose name(s)Is subscribed to the within Instrument, and acknowledged that he/she executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seal. :~..:~-::::-..S~~~~~.=::-..........,.....,..... My commission expires: 15..,) NOTARIAL SEAL SCOTT KAMAN, Nolaty Public Cily 01 PlllladDlphia. Phil.. County M Commi:.!Ion EJI Ires Jul 7. 1997 , , ..,......................................................................... Title of Olllcer It Is hereLy c~rtlfled that the address of the Lender within named Is: ....!!!H.T.J?...l!,l!!l!l..!lM.~I,I.'!'.I,t,1i=,1i=..!!Sl...... '..!1IH!HhH!i..I,I,O),...9,l!!llll....................................................)......'71......,....................................,........,.. ,'?,:.,iL.@;............"............"........,.. 01994 ...nhu Srmm'.II1(, SL Cluud, MH 11100 J91 ZUII farm elll ""CLAIrA 10/11/94 GT U 19090 19/941 lJNil6o(6J I I i I,.,', I f, I "I I , I ~>, I ~ r GTFC 15 1721819 320 13534 '., , I hereby eertity that the preeiss address of the assignee is 332 Minnesota St., Suite 610 St. Paul MN 55101 tL Signedl /)7:J.C;.(,'/:L PrBparsd by and Return to, Green Tres Consumer Discount Company Home Improv.ment Division 332 Minnesota St., Suite 610 St. Paul MN 55101 PENNSYLVANIA MORTGAGE ASSIGNMENT For value received, Vinyl Extsriors Inc a Corporation ("Assignor") organized and eXisting under the laws ot the state ot New Jersey assigns to Green Tree Consumer Discount Company and assigns, its successors, whose addresB iB listed above, a certain mortgage dated.. . . I/-,J{} ,19 9~ wherein Michael N Griffin and Erilea G Reed" ("Mortgagor(S)") granted a mortgage to ASsignor as mortgagse, recorded concurrently with this Mortgags Assignment in the ottics of the Recordsr, CUmberland "'""" ,...."...,., ""'h., "'h 'h. ,.,." ,..,.,,,.., "'.".., ., .". ....,., h, Such mortgage on the following described real property situated in CUmberland County, Pennsylvania, (see attachsd legal) "AKA ERIKA GRIFFIN Parcel No. 38' - /6 -to;!") -C()' Considsration amount on assignmsnt is Ths above rsterenced Mortgags was rscordsd in Boole _____, on Page _____. Datel 1/ -?Jj - 75- . ., Vinyl Extsriors Inc By: .1'\, - 'r ~ I II , '.. " I II' I..",! i I i ! I I~ STATB or v'\'V(U)-=~I'\ .;:)~'-~ COUNTY or ..J\~l.A c.. \ \ ~-\()~ ss (Corporate Acknowlsdgsmsnt) ~/20 day ot...,/NOWM hor , 199~-; bsfore me, .)n / , ths undsrsigned officer, personally appeared . ( ~ .' , who acknowledged himself/herself to be the . " ,''1\(', l~' (, (, D ,.-' of VINYL EXTERIORS INC, a corporation, and thllt he/she as duch"..\:V"'or, {'.r, ,', '" ( , being authorized to do so, executed the foregoing instrument for the purposes therein contained, by eigning the name of the corporation by himself/herself as I "., j. 1'-' 'f',l',i.()r J In witnsss whereof, I hsr<t:rsll~. my hand and ofH=~al se~,. \ ~ ~ \ /\,-)c' Q.L()1...c ~\ (L ~"'k.. wa'zR.... Notary Public " -- My Commission expirssl v' i._ ~ "-' , ' Ul:cUnIIn ,1"" ,,/IHll NOTARV PUBUC tr( COMMISSION EXPJRESJANUARY 13, 2CO' 'HI.~RIC r.c 15 l72lB19 320 13534 Seller Reed. VINYL EXTERIORS INC f"'lyercs) Hichael N Grittin, Erika G ClU)9 010 (9/941 HIRIC HOME IMPROVEMENT RETAIL INSTALLMENT . '. CONTRACT AND SECURITY AGREEMENT Account No, I J 77. r(,'/1- SUITE BBBB GREENTREE SQ HARLTON NJ OB053 196 Willow Hill Park Rd Hechanicsburg PA 17055 "You" and "your" means each Buyer above 'We," 'ours," and "us" means the Seller and any guarantor, Jointly and severally, above, I~s successors and assigns, SALE: You agree to purchase the property Cand/or services) described below according to the following terms, Including those on pages 2 and 3, You agree to pay us the principal sum of ~enty-one thousand, t!ve hundred and No/lOO dollars CS 21500.00 ) plus Interest from the disbursement date at the rate of 12.340 " per year until paid In full. You agree to pay this contract according to the payment schedule and late charge provisions shown In the TRUTH IN LENDING DISCLOSURES, and pay any additional amounts according to the terms and condlllons of this contract, DESCRIPTION OF COODS AND/OR SERVICES AND SECURITY AGREEMENT. Here Is a description of the goods and/or services you are purchaSing, To secure the payment of this contract, you give us a security Interest In the goods plus all accessions, attachments, accessories and equipment, plus all proceeds arising from all of these, ~ If checked, you also agree to give us a separate mortgage Cor deed of trust) on the real property described below, The goods and services Installed will be located at the real property address listed below. DESCRIPTION OF COODS/SERVICES Interior remodeling & finishin g, Windows. Roofing WARRANTIES: WARRANTY INFORMATION IS SUPPLIED TO YOU SEPARATELY. ANNUAL PERCENTAGE RATE The cost of your credit as a yearly rate. TRUTH IN LENDING DISCLOSURES AMOUNT FINANCED TOTAL OF PAYMENTS The amount of credit The amount you will have provided to you or paid when you have made on your behalf. all scheduled payments. TOTAL SALE PRICE The toral cost of your purchase on credlr. Including your down payment of S FINANCE CHARGE The dollar amount the credit will cost you. 12.34 96 S 25796.BO S 21500,00 Number of Pa ments Amount of Pa menlS lBO S 262,76 S Your Payment Schedule will be: 47296,BO S 47296.80 When Pa ments Are Due Honthly Beginning Apprx 30 Days from Disbursmn Date "e". First payment may be slightly larger/ smaller due to a longer/shorter payment period. Security: You are giving a security Interest In: _lbrl" descrlpllon 01 o.her prop.r1yl ...! the goods or property being purchased, ...! the real property located at 196 Willow Hill Park Rd, Hechanicsburg PA 17055 ...! Late Charge: You will be charged 5.000 " of the unpaid amount of an Installment that Is lare by more rhan 10 days afrer Ills due up to a maximum of S 5,00 , but nor less rhon S .00 Prepayment: If you payoff this conrract early, you will not have to pay a penalty. Filing fees S You can see your contract documents for any additional Information about nonpavmont, default. any required repayment before the scheduled date, and prepayment refunds and pellallles. "e" means an esllmate. If you do not meet your contract obligations, you may lose your house, or the property that you bought with this loan. ~ 19A2, 1994 "'"k." 5v'I~m~, t,,(.. 5t. Clt)urf, MNflllfln 19121411 rllrm GTII RCLAl rA IOn~/q4 (f'dgl. ,,,(4) CiT n 1901ll1Q/il41 ,~ CREDIT INSURANCE Credll life Insurance Is not required to obtain credll, and will not be provided unless you sign and agree to pay the addlllonal COSll. T e Credit Life oint Credit Life You :.- do .!.. do not X N/A You _ do X N/A XX _ If checked, Group Credit Life Insurance Is applicable. Premium Term .00 0 .00 0 want credllllfe Insurance, .!.. do not want Joint credit life Insurance. (Name of Insurance Company) PROPERTY INSURANCE You may obtain propeny Insurance from anyone that Is acceptable to us, ITEMIZATION OF AMOUNT FINANCED 1. Cash PrIce (Including Sales Tax) $ N/A 2. Cash D~wn Payment S 3. Unpaid Balance of Cash Price (1 minus 2)$ 4. Olher Charges: A, To Insurance Companies S B. To Public Officials S ~ S D, S E, S F. S G. S H, S L S 5. Subtotal (3 plus 4A. through 41.) $ 6. Prepaid Finance Charges S 7, Amount Financed (5 minus 6) $ N/A ADDITIONAL TERMS OF THE CONTRACT AND SECURITY AGREEMENT GENERAL TERMS . As used In this document. "contract" Includes the terms of the mortgage or deed of trust, If applicable, Terms regarding foreclosure shall apply only If you have signed a mortgage or deed of trust as part of this contract, You have been given an opportunity to purchase the propeny on page 1 for the cash price or the total sale price, which Is the total price of the property If you buy It over lime. The total sale price disclosed In the outlined box on page 1 Is based on the terms In effect today and the assumpllon that all payments will be made as scheduled. The aclual total sale price may be more or less than the amount disclosed depending on your payment record. You agree to buy this from us at the actual total sale price according to the lerms of this contract. You agree this contract will be governed by the law of the state of Pennsylvania, Including the Uniform Commercial Code If applicable. You agree that we have not made any oral warranlles or promises regarding the secured property. This contract takes effect when signed by you. It terminates when all paymenll have been made as scheduled. Any term of this contract which does not comply with applicable law will not be effecllve If that law does not expressly or impliedly permit varlallons by agreement. If any part of this contract or security agreement cannot be enforced according to III terms, this fact will nol affect lhe balance of the conl/act and security agreement. Q 1911. In<4 "'n".n SWlllml,InC.,!it. Cloud. t.4Nll 100 J91lJ411 FQ,mGTlIR(LAZ PA IO/U/9.. ,-~ ., You agree to pi , all allowable charges for the return by a depository Instltullon of a dishonored check 'or other negollable Inst/umentto the full extent provided byappllca,ble law. You agree to cooperate with us regarding any requests after closing to correct errors made concerning this contract or the transacllon and to provide any and all addlllonal documentallon deemed necessary by us to complete this transacllon, You agree that we may enforce this agreement by Judicial process and are enlllled to altorneys' fees, COSll and dlsbursemenls Incident 10 such enforcement. PREPAYMENT. You may prepay this contract In full or In part at any lime. Any partial rrepayment will not excuse any later scheduled paymenll unll this contract Is paid In full. INTEREST. You will pay Inlerest from time to lime on the unpaid principal balance until paid In full, Each payment will be flrSl applied to Interest accrued up to the lime the payment Is actually made and then to principal, The actual amount of your final payment may be more or less than the amount scheduled, depending on your payment record. OWNERSHIP AND DUTIES TOWARD PROPERTY. By giving us this security Interest or mortgage or deed of trust, If applicable, you represent and agree: A, You will defend this property against any claim made by anyone else, and will do whatever Is necessary to preserve our status In the property; B. You have signed or Immediately will sign any additional documenll or provide us with any addltlonallnformallon we may require to perfect and preserve our priority In this property, You will not hereafter do anything to defeat our position; C. You will provide us reasonable access to the property for the purpose of Inspection, and nollfy us of any loss or damage; and D. If you fall to pay taxes, assessmenll or other liens, or you fall to make repairs to the property, we may pay the taxes, assessmenll or liens, or have the repairs made, We are not required to do so. however, If we do, the amount we pay will be added to the principal, will be Immediately due, and will accrue Interest at the annual percentage rate In effect on the contract. DEFAULT. You will be In default on this contract If anyone or more of the follOWing occurs (except as prohlblled by law): A. You fall to make a payment on this contract in full when due; B. You become Insolvent (either yourllabllllles exceed your assets or you are unable to pay your debts as they become due); C. You default under the terms of the mortgage or deed of trust which secures this contract. If any event of default occurs as to anyone of you, we may exercise our remedies against any or all of you, REMEDIES, If you are In defaull on this contract, we have all of the remedies provided by law and this contract. These remedies Include (among others): A. After nollce as provided by law, we may accelerate the due date of the contract, making all unpaid principal, accrued Interest, and all other agreed charges due. B. If your default consists of failure to pay taxes. assessments, or other liens, we may pay these ourself. We are not required to do so, however. If we do, the amount we pay will be added to the secured obligations, will be Immediately due, and will accrue Interest at the rate In effect from time to lime, until paid In full, C. We may require you to assemble the property and make It available to us at a place we designate which Is reasonably convenient to you and us. D. We may after nollce as required by law. repossess or foreclose upon the property by legal process or self.help, without the use of force. We may then sell the property and apply the proceeds as provided by law to our expenses and then toward your secured obllgallons. Expenses Include our cost of repossession or foreclosure, altorneys' fees (where permllted), repairs (If necessary) and costs of sale. E. We will be enlltled to a deficiency Judgment against you If the proceeds of the sale do not pay all of the expens", and secured obllgallons (except where prohibited by law), IPfI,.1o(4J GT IS )9010(9/94, If the property Is foreclosed upon because of your d.fault, ~otlce will be provided to you of~e Intended sale or disposition of the property, This no. will be provided by mall (certlned or registered mall when required by law) addressed to you at the address listed on page 1, and will be mailed to you at least 10 days before the date of lhe Intended disposition (or such other period of time as Is required by law). EXCEPTIONS . After you default, we must provide you with written .(lotlce (by certified mall) of your default and right to cure suc/i pefault. You have 30 days from receipt of such notice to cur. your default. We may exercise our remedIes only If you fall to cure your default wIthin the tIme allowed after the notice, However, we need not pravlde such notice to you more than once In any 'Z month period, COSTS AND ATTORNEYS' FEES. You agree to pay all costs of collection, If you default, Including reasonable altorneys' fees, ARBITRATION. All disputes, claims, or controversies arising from or relating to this contract or the relationships which result from lhls contract, or lhe validity of lhls arbitration clause or the entire conlract, shall be resolved by binding arbllration by one arbitrator selected by us Wllh consent of you. This arbitration contract Is made pursuant 10 a transaction In Interstate commerce, and shall be governed by the Federal Arbitration Act at g U.S,C, Section 1, Judgment upon the award rendered may be entered In any court having Jurisdiction, The parties agree and understand that they choose arbitration Instead of litigation to resolve dlspules, The parties understand that they have a right or opportunity to litigate disputes through a court, but thaI they prefer to resolve their disputes through arbllratlon, excepl as provided herein, THE PARTIES VOLUNTARILY AND KNOWINGLY WAIVE ANY RIGHT THEY HAVE TO A JURY TRIAL. EITHER PURSUANT TO ARBITRATION UNDER THIS CLAUSE OR PURSUANT TO A COURT ACTION BY US (AS PROVIDED HEREIN), The parties agree and undersland that all dlspules arising under case law, statutory law, and all other laws Including, but not limited to, all conlract, tort, and property disputes, will be subject to binding arbitration In accord with this contract, The parties agree and understand that the arbitrator shall have all powers provided by the law and lhe contract. These powers shall Include all legal and equllable remedies, Including, but not IImlled 10, money damages, declaratory relief, and Injunctive relief. Notwllhslandlng anylhlng hereunto lhe contrary, we retain an option 10 use JudiCial or non.judlclal relief to enforce a mortgage, deed of trust, or olher security agreement relating to the real property secured In a transaction underlying this arbitration agreement, or to enforce the monetary obligation secured by the rea property, or to foreclose on lhe real property, Such Judicial relief would take the form of a lawsuit. The Institution and maintenance of an action for Judicial relief In a court to foreclose upon any collaleral, to obtain a monelary judgment or 10 enforce the mortgage or deed of trust, shall not constitule a waiver of the right of any party 10 compel arbitration regarding any other dlspule or remedy subject 10 arbitration In this contract, Including the filing of a counterclaim In a suit brought by us pursuant 10 lhls provision. OBLIGATIONS INDEPENDENT . Each buyer who signs lhls contract agrees jointly and severally to pay It according to Its terms. This means that: A. You must pay lhls contract even If someone else has signed It; B. We may release any co.slgner and you will still be obligated to pay lhe contract; C. We may release any securlly and you will stili be obligated to pay lhe conlract; D. Waiver by us of any of our rights will not affect your duty to pay this contract; and E, EXlendlng new credit or renewing this contract will not affect your dUly to pay lhls contract, NOTICE OF PROPOSED INSURANCE . Group credit life Insurance coverage will be applicable to lhls contract If so marked on page 2 of lhls contract and each type of coverage will be wrllten by lhe Insurance company named. This Insurance. subject to acceptance by the Insurer. covers only lhe person signing lhe request for such Insurance (or each .f') IlI"", 1qq411"ft"'" SVllfml,lof., SI. (I(turf, "'NIl 1100 Hl1HlI rOlm GTII AClAlrA 101211/94 person signing th~quest for Joint credit life Insurance). The amount of the t Je Is Indicated for each type of credll Insurance 10 be purchased, The lerm of Insurance will commenCe as of lhe dale lhe Indebtedness Is Incurred and will expire on the originally scheduled maturity dale of the Indebtedness. Subject 10 acceptance by the Insurer and within 30 days there will be delivered 10 you a certlncate of Insurance more fully describing the Insurance. In lhe event of prepaymenl of the Indebtedness, a refund of Insurance charges will be made when due, INSURANCE. You agree to purchase Insurance on the property against such risks and In such amounts as we may reasonably require, In addition, you agree as follows; A, You will arrange for us to be named as mortgagee or benenclary under a standard loss payable clause on any such policy so that any benents arising from the Insured risks will nrst be paid to us for application toward the secured obligations; B. You agree that we may, In the event of a loss, require addlllonal securlly or assurances of payment of the secured obligations as a condition of permllting any Insurance benents to be used for repair or replacemenl of the property; C. You agree to purchase Insurance from a company authorized to do business In this state and which Is reasonably acceptable to us; D. You will maintain this Insurance until all the secured obligations are paid In full; and E. If you fall 10 obtain or maintain this Insurance, or you fall to arrange for us to be named as mortgagee or beneficiary under a standard loss payable clause, we may (but In no event are required to) purchase such Insurance to secure only our Interest In the property. The cost of such Insurance may be added to the principal balance and shall earn Inlerest from that dale until paid at the rate In effect from time to time. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. (pII"h(4' r.T n 19010f9/94) ~ ~, NOTICE TO BUYER: (1) Do not sign this contract before you read It. (2) You are entitled to a completely fllled.ln copy ~f this contract. (3) Under the law, you have the right to payoff In advance the full amount due and, under certain conditions, to obtain a partial refund of the finance charge. (4) You may rescind this contract, subject to liability for any liquidated damage provision thereof authorized by law, not later. than five P.M, on the business day following the date thereof by giving written notice of rescissIon to the contractor at his place of business given In the contract, but If you rescind after five P;M. on the business day following, you are stili entitled to offer defenses In mitigation of damages and to pursue any rights of action or defenses that arise out of the transaction. BUYER ACKNOWLEDGES RECEIPT OF A COpy OF THIS RETAIL INSTALLMENT CONTRACT Date' /1- 30 ''i 5'" . Buyer Signed X Buyer Buyer Signed X Bu\'er EXECUTI07 AND ASS~NMI'NT Seller executes and assigns this contract on .J' I - ~() - S to Green Tree Consumer Diecount Company In accordance with the provisions of a separate Dealer A9reement. Tille X I .. (Seller) <e", ',., ".." ~ IVIl, 1994 '.Inll." Syll.ml, IlK.. !II. Cloud. loiN t1 '00 U7 U411 form GTIIIII.CLAl rA IO/U".. ".,.. 0( 41 ~ . ~ ('., GREEN TREE FINANCIAL CORPORATION 332 Minnesota street St. Paul, Minnesota 55101 612-292-2589 I I January 13, 1997 ,>', ERIKA GRIFFIN 196 Willow Mill Park Road Mechanlcsburg, Pennsylvania 17055 " Re: Loan No. 15725642 ERIKA GRIFFIN 196 Willow Mill Park Road, Mechanicsburg, Pa. NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear Ms. Griffin: " l~ The mortgage held by Green Tree Financial Corporation on your property located at 196 Willow Mill Park Road, Mechanicsburg, Pa, IS IN SERIOUS DEFAULT because you have not made the monthly payments of $262,76 r1r the months 8/15/96thru 1/13/97, Late charges and/or other charges hav7.l 91. ,accrued to this date, in the amount of, The total amount now required to cure this default, or In other words, get caught up on your payments, as of the date of this letter is $1,367.40, You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the above amount of $1 ,367.40, plus any additional monthly payment and late charges which may fall due during this period, Such payment must be made either by cash, cashier's check, certified check or money order, and made to: GREEN TREE FINANCIAL CORPORATION 332 Minnesota Streot St. Paul, Minnesota 55101 612-292- 2589 EXHIBIT I~ . ,. , Extended Peat 10.1 ("J~""ahtVlnortQ:I1tI\or,ocI""'\Ki..nuan -.1,1 :hat It ,.,ncu/Wa'Ul.I .... \Viol , 1IJ(; Q""'~not : . I'!~'" ,~.........n'~nd~"== ....( "'.,.. ......""~'_r:, (.I"""h""""'Nlm.t",,~I" I.th. ,1_-' ~.,."'c'a.""t..; 00"""","10 o/lI"9IU....... lNnuprcr.t,I-1iId I\lrlOlnJ. .1I,oon4iaonlOAufIIaIl"fundinQ ....-. " ''M''..NU """"r.d. .. brtiIChId Of' wnllUt. ~IM wm. woon . n "M'ftAnlf purd\I&llrll.t(ONl'CUtOrl'U~' ~~... n:...,":l,._....""'........b.'.~I.. ~ '100 .....1'1I0 ~ o. Nil;"" WN~. ..... ._'/1#11 rnf'lltttuioa- ~*tM. Met II un Clj~' I'~ ~r II' ,.....;\ o~ ~ tnlU .;.". =Nt .l\,s '9?~~&t(n .t d....1'II4 ~,... tQt\I\n ..~!. 31 ., '1oUt\Ia :\~lIca cll1Ml acetO''''''' of,u.LJ ~'iCI"l"Mn\.lK'riat 0( mn,-o..ayrna"'l ct norrf'.-fonr"lm::o an1 mw.e or .ny OU'lJt rrmeo.11A ~'~I::JL.:O tuIQ"'" .. .~:"oN f:'A",~"" ,,,<dOl \Q ...1'-<<. aNI ~~ .tftdr'l9 "'. Ib~!IJ1'/ of ,".tllllnc:._'_l~ lu.a::mcnl"COIf\i)QUflft c;.t rfI1tutl/'Pf ~:!tI '~Inc"...M Q'T&m USGnJ.'1:oWl Dr 11m. tot 04ymtr.~w b9 mlIIda. to bvytf .f.d ttN ~.r PI~ t)O(I;a\.cd \II1d.. Chit ~~~:ta. \. 'MT"rt)U~~'I'\::I..n,;unJ'lJnmanUt'laUbc"""r.hC'UI~ ~1~1:Jl~1I~. :;, 'MTl1~' '" 1Ql>J"" '" lhoao.......-.I-..... _....' doIlabs,,"""""""'-.l."""'Clul.d"""""'" _~C__ on .................. p=.\o< _...... d "" <>or"" ''''''''''''_'''''''''''It\lliItl..__~'''' . r"p;;.,~" NClCtIl1Ittba':\~'lMlIt1n:>> .wr~.otlh.U'~~a ~ t1Mrtt:JClUt&l tmI. 3. SVIl.~ J.ClIWtW!. Thls ~ I, ~-*" '" ~:r.w...a."'''.r.;)fr.noo. ~: J I Eli ClleDITCllKT1Vol:l1S Sf. WI1ICl1 me 1lfB'lli1l lJOOQ.'i Gll SEF1\W ell- t-tli PP.OCmlS HE\!G!\ .. ". ~",'f..:.':' .r.~_ I:.:", , ...~...........-:""". .,.':':'_'1"'-\' . '''!. -: ;..;....:.4 - ." - "-',-" .... " .:. , , , 'I ~ a ',' . '0.;.:"\' ,"~~;"::'.'" ',' '.}',' '.......",,'\: l . '.,' ',- ..', . . ,~1t'."" \\.'\ l, '.k"~ ......., '\ ''':''~ ": . . '. :. ~ ,',' .... ..... . ~t ~~ . *~_~~. ...... "". EXHIBIT 1\ A'l ' .,-\\...~' . .,i, :(;.... ~ ., \~. ......,.. AU.tTAftUlW.tul"f\YCO 1 . . \ .l _ . "'"" r-", ERIKA GRIFFIN January 13, 1997 Page Two If you do not cure the default within THIRTY (30) DAYS, 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 due immediately and you may lose the chance to payoff the original mortgage in monthly installments. i I i; I i i ~ I If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorney to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff (or other similar official) to payoff the mortgage debt. if you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attorney fees actually incurred, up to $50.00. Any attorney fee s will be added to whatever you owe us, which may also include our reasonable costs. if you cure the default within the thirty day period you will not be required to pay any attorney fees. We as lender may also sue you personally for the unpaid principal balance and all other sums due under the Mortgage. If you 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 Sheriffs (or other similar official foreclosure sale.) You may do so by paying the total due, as well as the reasonable attorney 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 Sheriffs (or similar official) sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriffs (or similar officials sale will be sent to you before the sale. of course the amount needed to cured the default will increase the longer you wait. you may find out at any time exactly what the required payment will be by calling us at 612-292- 2589 This payment must be cash, cashier's check, certified check or money order and may payable to us at the address stated above. You should realize that a Sheriffs (or other similar official) sale will end the ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs (or other similar official) sale, a lawsuit could be started to evict you. YOU SHALL HAVE THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDINGS THE NONEXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE THAT YOU MAY HAVE TO ACCELERATION OR FORECLOSURE. . t 1.. ' Extended paae 10. , rlhl=hlVtnortQntlUlfJOCII'o.slKl..NIVI .-atl thu . . ~"' nolloe ...... W'lCe fU I ghtt ...... not &XIfIh :. "'~I"" SEbo....'liIi.nd~......=oAAI ~...~.." ~......."lM.~r:. l~l~h_n...m"'''~' l"l~ln'.. ,1_""'" b:KroIn"""""'YID!."" nQ6\I1w"",," ~"'~lb'''''''' lNn&DOtMIW~nQWIQ:. .M1'Q)naldon$OAUIQ""~ Iho"'_. h"'M' snut Wlmr.UM .. bttltCtlItcl Of vr4l\II. "UN..m. uoon . n :Utnln~ ;lUrtNUlnU<ONU,e&fronus .~... n;....,n;l,.-.....,""'.......ll.'."..~= ~ ~.1Do.....n0 flP.~ af ...1;......lt'Idudl tiN.. Sd!...."'Il~"'flI'v~_t:H~tHSf.Vf. ntd lI~un 01 jud.it.i.J.1 ,~11r .II . fltua o' . r1IiCC'YIry muo '1Ilttlll m,gMt ..., ~~'9r. ~&I(n at ~.....,.. 'OcJY'f.... a4tV\C1..s!1a:' S~~.~ n"U~ c! ~ &O(lIOt.lt:W;.ll O(Ii'.b ~UIO"ment. notl~ of rYln"cuyrrlll." Cf nor.."lriom"otrn:O aM ~ Or '01 0\11'" 1"."""._ ....'''''''. to __ _0 ,~!'lN r.\.r(. ~:.n "~OI to ~I"'. and wunuu:. ,iffldtl9 \I'll '1.I?\II1'/ Qfu~larunc'_'.~~ a :ltr'C",-COIfIi)Otltlf1tot "':tUft/Y1 r~~tI .~I~...r<i Q1.tr:&lGl.nJi')JW: ~m. fgr eut.,II'ltt'lCW t.frYd)" lObu'pf If.d Mrt ~.t PINOn t)bQ.al.cd "",d.. ttlit Of,lrH:tCt. 1. .mrti)U':'RECeI..,.tl~.;n~t..UgMlItl:INUbll*'~ftIQM'M.. ~,_Itl~.bc'-4. ::. wml ~'1:' '" ~OI'.'" v-1uMI C'.WII:d.......... _"'_' doI'....!/IfIJi..........;:."""".....el.......,...... ~J;--'" _,,,In''''''''''''_...a.oI,,,, ""01 ~_?!"""_tv,,.,,.,U>dU:I.. -"...''''~- . ....I_rt~ 1l\.iIc:cnD"ltttla':1astg11t'4ln In':lG .wrl:lUrl~ ". U'l~~a ~ t\M1I't1UOJI at tm.L :r. "''''''WI! IoCtlmUHT''ThIo ~ ~ ~ 10 ~y.utY'l:a". =!g>>O. (: J I . . '0. ...". '..i"~' .r.:. ,: .:". , , ...~.........""':-. "....1'-.1.....,. '''At. -:;:;;....;.,1 -"... .f_.._.. \ \ ~ ill '. ..~... :~, \.,"l"~" .... . . . . ; . '.' . " I '. " ...,o.f. ... .'........- ~ ' ",:!;,."",c.:. .\\', ..~'. .'; '" .,', ".".., .,',:",\~.' . ' '''I,'', \... .- EXHIBIT 1\ A'l . -~'.""'''' ~~ ~ . , , \', ......... AU-ITAnllOAlIUl't"lYCO 1 . . ! I ! ~ J .... " r I I I ~ ! .. ... r' GREEN TREE FINANCIAL CORPORATION 332 Minnesota Street S1. Paul, Minnesota 55101 612-292- 2589 January 13, 1997 I>> .- . . " MICHAEL GRIFFIN 196 Willow Mill Park Road Mechanicsburg, Pennsylvania 17055 ., Re: Loan No, 15725642 MICHAEL GRIFFIN 196 Willow Mill Park Road, Mechanicsburg, Pa. NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear Mr, Griffin: The mortgage held by Green Tree Financial Corporation on your property located at 196 Willow Mill Park Road, Mechanicsburg, Pa. IS IN SERIOUS DEFAULT because you have not made the monthly payments of $262.76 for the months 8/15/96 thru 1/13/97, Late charges andlor other charges have also accrued to this date, in the amount of. The total amount now required to cure this default, or in other words, get caught up on your payments, as of the date of this letter is $1,367.40. You may cure this default within THIRlY (30) DAYS of the date of this letter by paying to us the above amount of $1 ,367.40, plus any additional monthly payment and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made to: "/. '..it.~~.'....... ~.: GREEN TREE FINANCIAL CORPORATION 332 Minnesota Street St. Paul,Minnesota 55101 612.292. 2589 . ~ ,~ ., MICHAEL GRIFFIN January 13, 1997 Page Two If you do not cure the default within THIRTY (30) DAYS, 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 due immediately and you may lose the chance to payoff the original mortgage in monthly installments. . .r ". If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorney to start a lawsuit to foreclose your mortgaged property, If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff (or other similar official) to payoff the mortgage debt. if you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attorney fees actually incurred, up to $50,00. Any attorney fee s will be added to whatever you owe us, which may also include our reasonable costs. if you cure the default within the thirty day period you will not be required to pay any attorney fees, We as lender may also sue you personally for the unpaid principal balance and all other sums due under the Mortgage. If you 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 Sheriffs (or other similar official foreclosure sale.) You may do so by paying the total due, as well as the reasonable attorney 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 Sheriffs (or similar official) sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriffs (or similar officials sale will be sellt to you before the sale. of course the amount needed to cured the default will increase the longer you wait. you may find out at any time exactly what the required payment will be by calling us at 612-292- 258!1 This payment must be cash, cashier's check, certified check or money order and may payable to us at the address stated above. You should realize that a Sheriffs (or other similar official) sale will end the ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sh~.riffs (or other similar official) sale, a lawsuit could be started to evict you, ~~ . ~ . r YOU SHALL HAVE THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDINGS THE NONEXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE THAT YOU MAY HAVE TO ACCELERATION OR FORECLOSURE. , , . MICHAEL GRIFFIN January 13, 1997 Page Three You 'have additional rights 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 LENDING INSTITUTION TO PA'Y"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 THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THE 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 the default, the 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. GREEN TREE FINANCIAL CORPORATION 612-292-2589 .":-0"', . . " . E~tQnded Paae 10.1 Inl~NW""'ahWIMrtQ:Il1:I\G~\K.i"1WVI ~ ..-u....t1J4Vt... "bi~l'O,""nouOl"="" "Y1I oiYU\ , tUf: Qh'l........ not : I.) IC'O' -.Ah&abl..,P' D"'nd~"'" MIOl ("caL:::"-:':'~:~' ~~'i1.r~. . ~""". .''''''''''''''''1."" roo, ",.",,,lIo;l1&tl1M. III IC\I:nIDQl'MI W~nGWJg. ,iI,oondltlonIOAaItO".. 11-._. " ....;r.ot..1N.tI ~ 1I1!W't.cl'\ltd 01 \lnIl\It. Nl'", 'Mft. uoon uwn ...".,nd.""'rcN~ln~CONl6lS'rom"~~ :';"'~" ";...,""'._...'..........~hl'.,...ll.. .U)O......_o~ot...,;,...lfodull .. tIt....""Il~"'"',..,n$iQ_.......w~.M Md U~t-. al j~' I II1'Ott qr U .,.....;\ 0'. rtet:Nery tnHe nl\lill inl;,.. .au '9c. ~ at t!.....,.. tMi.,." tot. IGMn ..~ , llh ~.,.",....,n;&;l;8c'tlMaoc"'t..".,.of.l/.b~...""*"-nvfIc:.ol mn-o.rtr.:Jlc"l CI norrlJmm-.tntO m notI(..I of In, 0\11" ""*- "'"'.....'" ......-~ ",__ ""t.... ' n~ 10 "".... M' _, 0#"'''911'' 1\.I?\Il1"Qf\4i~"'Urw:.', . ':'lmcr-..CQ.tTlptJUIJft,c.rtt:NM"",N:ltI 1:;..Unt:".._,.,s, Q1'.tr.~n,.'2I:' urn. tor ",ymer.(N be""'d"tO~ If.d.,., liUI.r Plr'OOn l'JOQ.I\Dd \oII'Id., thlt ~nl:'ta. 1. wrrrl~':'~,"'OJ:-1l1t."'1!8M1an:.talUbl'M"rMur~ ~'-IQ~ .~. ::. MT11~."'addll"""U-_"""_"''' ..-",,,' lkr"'!Ilftll_~""""dIII.<l""_ "7~- '" .-....... '""""" -....... "" (doc '::IDlP('~.N~tv,<<'lJ:\diItf..~~..... , ope; """".... ....j-'01lla...-. ~"" _""" In"'" .llTJOOt. oi tt. U"t~~ blIWa Drdudin; .,>>*lJ 001. 1& ti'nI. 1 .....'WZ IoCl'lrolVlT.lNo ~ h r.A>jt:> ID ~~"'iL~"',r.o:)'r.noo. (: J I DI CReDIT cmmw:1" IS 3U W1IIC1l n~,omtiR r~~'i\R~ . . , , ". .......,.. ."~' .r.:, t:.:". r -- ",~,,""".-:"'". -... .....--.. . ". '.:";,,-.,,,,,,",' '."!.::;';.~ \ , ,I ~ ill '. .', "~.' "~:";:\~'~''''':~~''''''':..','i.'' ...> :', ;'.....,;:\;~. ..)...."01... '\r',' ..~.~ .........\''':~-' . . ~ .. . "'''''\ 'l"'~"''' '. . .,;. '. \',' .. EXHIBIT 1\ A'l~' . .t~~r' .i :~< "', \" -""''''', AlL.aTATtlfGALIl.Pf'lYCO 1 I ',t';&. .... .. " '1 ~ 0. Date: January 15, 1997 Re: Michael Griffin & Erika Griffin 196 Willow Mill Park Road, Mechanicsburg, Pal Loan#15725642 To: ERIKA CRIFFIN From: Merri R. Lane, Esquire .... You may be eligible for financial assist~nce that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance If your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains a\l explanation of your rights. 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 a representative of the lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding In mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Merri R. Lane, P.C. 400 Market Street Philadelphia, Pennsylvania 215-922-0066 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $1,367.40, That sum includes the following: monthly payments of $262.76, monthly late charges of $5,00, plus previous, unpaid late charges of N/A, If you have tried and are unable to resolve this problem at or after your face-to- face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and . . . .. . Extonded Paae 10. tn] ~1~U. ~hlVtnoItQM:lt.ar,oal'\:l\Ki"naM'l ?lV "/ tlU.t~:hd ~~,",noIK1lol=""'" !1I)U1tl Yl& 0"'" ..... noI : 1.1~,I..r e.:x.::~"'p.I ""Nf~"" I/IlOI lie'" t ..:~. JJ ba UIiId Dt'I~tW'I(\'I'l . 1.I~h-'-'no",,"""'" ......1"111. . --, bllI~.r"""""'''''''' rq_"","lo <11I"""_'" 1Nn..""",IIfdIl",olnll' .IO,OlltlOIU...IOAaalQllIO_ 111I"'....... """;Pnl,jrJ'rtU ~.. brtllCr.w DC' "nII\lI. ...,..... UDOn IYWn ,jamlll~ pun:hI&.elnlaCONlt(i'torn~... ...- .f,i[... n'..."';I,...........tna.......dllo......11M i_6111 ~,mo-..u:-"d~or...,;rQlttd\Ht1 ..... '~......ll~!'nf'llttf'Ui04_fr:if~lH. . Md Utlaun 01 ;UCUcia,l.~qru I '.....:10'. ~ tNC..t~:tnaI ~ .t.\a~~f..c;:...I(n.,dolJlt,..bvt-tfN.lQtlnn . s~~ 'IIJNW n:.1O cf u.1CCtC)I~ ot'.lI,b ,.stlr;nrMfl't. nvri~ of r:nl'i~yr:Jl"'1 CI nor,.p.tonr.aa eM notU or my 0Ul1t ~ ...,..... "'~... .. ,~_ !rA", ;;;w,.. "~' '" ..,.... on. -, .~..."" ... I~?!l.tl of \4aatunc:.~~.. ::mc"" co.mi)'JUndc.rt1:tut Ihf nQ:ttI 1~1n::-...MCl'1.tn~n,.-'1:w IUTWj(,rp.lll'mtnCwbemact..Ulbu'r" If,d IC'IV cQ\tt pcra.on l')b(l.~ \lI'idef Chi, "",":'1(1. \ .MrH~1.J':~'I\G!..'J1',i.n"8M\Itl~It'ltl.lbli*,~nrovnc.. ~,.."Itata4.b(ooooI. ::. =~.;.~~:'==~"J~ ~..Ji;;;:"~ _........ """'" __01 "" ~iJ'~blC>tl~iLQJ.,<<t.t:\ditU.IIIIl>>.\.Ml'I;,~"" . Mo.s:.~~~=:~=~: ~... 1.......'Wl!JQlro..",..thlo~kr.t.jo:L... ~.,.,..lflL'\,..cl~ r; J I mCllEOITCllKfMCl1S SU WIll ClI nre D:BlliR GtJOll.'i GIl SEIi\';{1S ell- lliIi JlllOC(EIlS ~.f.iI.."Iil'. . . ........."../'1. r.' ,... ':- ,..... . , --' ............ ......-:-. .~_ ,.:":1-., I+,,",' '."!. ~;';...:.4' - ,0. - eI_..... ~.' " "', .:.. \ \ - - ~ . ',~,';~'.1.,,'''~''''... ',",~.' ~. \ .....\.. . , '\ "'" - '0 \.... .. . ti,,,,v.,,t" '\f\ ',..~. ' .,":...,.... \;", ", .... .... ",' ;;; .~.u., .\'t.'''~. . , \\" .. EXHIBIT .... ~'l' '\:7 :\< .... . "'.......,.. M.L.fT.flLlQ.f4....",'C:O 1 I i I' t\; ,.~l.....~..,: .-.,. ,. ... , . ~ (\, file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out the application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting. j. I It is extremely important that you file your application promptly. If you do not do so, or if you do not follow other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional 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 Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1 (800) 342-2397 (toll free number), Persons with impaired hearing can call 1(800) 342-2397. In addition, you may receive another notice from this lender under Act 6 of 1974. This notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania Law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. GREEN TREE FINANCIAL CORPORAT:~ /~ L- MERRI R. LANE . ' J I . . ~ 41 . . ......,..,. '''''~'l.' .. .,.,'" . "':'~".'" ~ '~'"'' , . 1 ,. , Extended Paae 10. 1 'nl~'-""~hMnottgntJ\O~MiH.I"NrM1 '" ,.~.t :h11 ~. ~1'Op.wnoIKII"'=' .... of YU AI' ght........not : ,.hrIlC'O~ ..........tnp.l OUnd~"'" loIIlo:O ( .....,........'"'.~~"'. ~1 h~ no nwCllfIll Ct I" Ih.. ltNI. ='=.r onc>lD'T"..e!. ",,' IlW ",....loo ~~...:;:; 1CIIn&:nlf'MIMdI\l.....'W. .",oond;Uon\O~"~ ...."l"""". H "'M" 4ft'. ~ .. brt.chH Of "5 ...,.....m. woon IMn "AtMnd."U";hultnllconulelrron'l~- ./.Or-.. n:....""'.-....""............".. Jnc iltowtJl/ iJf'!lmo.....a~.'...,grkWhHi .... Sdl*'.~U~"""fv~-......~\.HI"-II ntd tI~UIt 01 iUCllci.o.\ . r al . I,lu:l 0'. ~'" ..... ..., -.- ..,>11....1\~. . .. 4....... """" ~.. ..0l0Ift ..... :I,"~ 'MaNa"1;I ~ cr the ~."" of.ll,b ~'lOn"""", nvriat 01 mf'~"" C:{ norliJlrionr.anat aM nr>>ee of '01 OUI'" ~ ""',........ "'i1l-~ . .'"'inH r,.rr. ' , ...'1100 Ie ",.... .... _, '.""l'O9 "'. 1..'II~IQf",lor.nr:'rl, ._n""'..."""poII.1<I"'..,....l/'ftlo,l'lI .~I~.Pi Q1.I'I't.xIGnh-~:ilDr 111M for ~'rtnttlC_ '" m.ada. to buyt'I .Ii',d lItf1 c:Qlu pcroon t)tl(J.I\od ~d.. Chit 0nt:'ta. 1. wrrri~~RECe4."U'z..n,j....ueMlIn:."'Ubli'IV~ft\CI\InI. ~11IlS1ta~.~. 1. MTlt~. '" odcIlJ.......,.. UmI..........." .......".' doo.....,Ui_<:l.Io4lInMcI............. ~"'UMlt:n ~orintM~o.rfl;lnT...,a.at"'1 ....~"::l..C<I_~lV,cr.-U.._~~- . ~~~=:~=~&l tAh :L .......""'" IoCllWItN1'.Tlllo __I. ~ 10 ...~..',....... n'_ to" ~""""''II''''''G)!r.noe. ~: ... - f..... ...._#. .....-..-:-" ....,:,.:1......1...-1.. '.":. ~:.;...:.( . - ." .. .'-.-" ~.:.....:..:....- .:.. , , , ., J '.~., .~, 'i"'.,...:..... '.. ',..... '.'- . .~~. . f ',I \ . _ "",' " ...... '.. .r,....IIC..~. ".X\,' '.L'~ '.........,:.- ~'-' ., . . . '. ',j ..... ,,,. , EXHIBIT 1\ A'l: \. ......\ '. AlL-ITATILlQALlt.Pl"\yCO " . .- r ,-, 21) JOHN F. KENNEDY CENTER. INC, 2021 East 20th Street Erie. PA 16510 (614) 898-0400 Crawford & Erie Counties 14) L YCOMING-CLINTON COUNTIES COMMISSION FOR COMMUNITY ACTION (STEP) 1221 West 3rd Street, P.O. Box 1328 WiIIlamsport, PA 17703 (717) 326-0587 r .. Clinton & Lycomlng Counties 26) MON-VALLEY UNEMPLOYED COMMITTEE 116 Fifth street McKeesport, PA 15132 (412) 678-1409 Allegheny, Beaver, Butler. Fayette. Greene, Washington & Westmoreland Counties 28) NEIGHBORHOOD DEVELOPMENT ALLIANCE 5935 Ogontz Avenue Philadelphia. PA 19141 (215) 424-1111 Bucks, Chester, Delaware, Montgomery & Philadelphia Counties 31) INDIANA COUNTY COMMUNITY ACTION PROGRAM Box 187 Indiana. PA 15701 (412) 465-2657 Armstrong, Cambria, Clearfield. Indiana. Jefferson & Westmoreland Counties 12) HOUSING COUNCIL OF YORK 116 North George Street York, PA 17401 (717) 854-1541 York County 19) HOUSING ASSOCIATION OF DELAWARE VALLEY 1314 Chestnut Street. Suite 900 Philadelphia. PA 19107 (215) 545-6010 658 North Watts Streel Philadelphia, PA 19123 (215) 976-0224 20) HOUSING OPPORTUNITIES, INC. 133 Seventh Street. P.O. Box 9 McKeesport. PA 15132 (412) 684-1590 Allegheny. Beaver. Butler. Washington & Westmoreland Counties .- -.--------... ll" , Extended Peae 10, 1 n ~__lhO~hWtnortgntl\a~~\ISI"nuan ~""I ~u" ..-noualII&M -- IU' Q~""'not . . c)t.,. ~.., ..'lifnd~"=w.. ~.. ~ ... ........ ",,~_r: . <,1""".-'-'''''''''''''''' ~Il"'" .~' . _or.nol<''''''I"'; no 0\llW "","\I oN"ll" '''''1''' IC\InCOfMfai.stwr'lQlt1li. :t",oondulonlOAUIQft.. 11II"'_. "'~1f. ....n ~ · btt.chH Of ~~ ....'" VrfIl. "con . n ~tc'M"" PURhU.lll\lIC4N1Il:i"O",,= ~~... ";",,";I,._...c...~...,.,...... ~ ..Ulo........-"d~.r...,;,..,,[f.du. t.e~ sIl.,..,.CLntM!'nf'IIfynPG- M1~'''''' ntd II UN cl iud1ci.l.."noon '71' u. ,,,,,,,,;\ o'f. ~rv ~ClI;'~ =~ J,\ .~-qr. c:W(:1.r d.....,., ~ N' aoQ~,u!la:' s",'.,.HJNG :I~"c:a cf lhlI8ClCeC)I."..... of.U'.\II.-s.IO""*"" nort~ of D'l,,~...'\1 Ct raor,.".,tom'AnCD tn1 t'IQW.I of It'rf O\Jlfl ~ """.~. tp a&IJogMt . .~:"IN (:1'. ;::h.,,:.n "'~ \CJ ,.1.. .,.(1 ~~ .rt'edlf'19 _11" I~'~~I of ,,~..unc.~. ....."''''''';>00.11'' ..:.....",. ",,'II '~InC"...MQTlm&lGG"1O'1ra ,uMkJtOo'ymtmNtlerNIcl"lIl~ .r,d Itf'I tal., J)troon 1)bQ..\od \11\'" Uti' G')1'll:'t(\. \. 'MT"rl~J':'~'t\t1J:.'Thi.nuenmlft:''''lJbrI''''''dKouftflQ\lnC, ~11O ft~.bc-ooh :;, tllTH~' . '" 1d<llJOI'. '" I/.- ...... ..... ...... "'11 ..-.... doIlah!n/lJl__doAdn- "7~u_:n .- ..11.1106 """-'" -.... 01 "" ....... ""'.....,_..,.bJ{ttu:wlOtU.._"..~:: . fJIX:t ~...... ,..~~MCCncratba':"lmtQl'M:n ~'='I MII)d.l'I IU' ~ bt\atca lItddnO "Mf'tIU C)"I 1& tmIo 1. ..,..,'Wl! 1QlWo1tNf. ThIt __ h ~.A>jt:;t. '" 1Jl?!J'*"ll....:O". cirJ*L f: . J I .. Ell ClIfOITCllKTiWlI' IS ~!5 WI1ICl1 nre D-::rniR GOOllS IJIl Sffi\';(1S ClJ. t-tS mams Hfj\.'(;f. ......".'.....1..11':. I:.:',., . . --' " ....-". .............. ....:..:I~.I"""'. ..."'t. -;;.;....:.t . -..' ....-.-.. , .... " , , , ~ I ..... ..~:. ~\ ~.".'.:.:~.........,~:_:,~.. ~..;.~.. \.,~....~-.i'\: f. .to,......:~ .\~...' '.k'~ ....;.....~..~ ......,... '. .' .r .. ~i"~ . !~~.~~.. ,,,. .. EXHIBIT '~'l'~ ALL-ITATtUGI4tu'f'\YC:O ....,......--. "g \1 ...,...... t. ......., 1 . . ff .. ,-.. r-. 18) WARREN. FORREST COUNTIES ECONOMIC OPPORTUNITY COUNCIL 204 Liberty Street P.O. Box 547 Warren, PA 16365 (814) 726-2400 Forest & Warren Counties 29) YWCA OF CARLISLE 311 South West Street Carlisle, PA 17013 (717) 243-3818 .. Cumberland, Franklin & Perry Counties 30) NORTHWEST COUNSELING SERVICES 5601 Norlh Broad Street, Suite 209 Philadelphia. PA 19141 (215) 540-2344 Philadelphia County only 22) PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 1701 Arch Street, Suite 304 Phlladelflhla, PA 19103 (215) 567.7803 Chester, Delaware. Montgomery & Philadelphia Counties 15) SHENANGO VALLEY URBAN LEAGUE, INC. Housing Counseling Services 39 Chestnut Street Sharon, PA 16146 (412) 981.5310 Mercer, Crawford and Lawrence Counties 23) SOUTHWEST GERMANTOWN COMMUNITY DEVELOPMENT CORPORATION 5002 Wayne Avenue Philadelphia, PA 19144 (215) 843-2000 Philadelphia County only 16) TABOR COMMUNITY SERVICES, INC. 320 South Duke Street Lancaster, PA 17602 (717) 397-5182 Chester. Lebanon & Lancaster Counties 13) GUIDELINE Doane Center, Mansfield University Mansfield, PA 16933 1.800-332-6718 or (717) 882-4214 Bradford, Potter, Sullivan & Tioga Counties ...( ~ .. . ~ r. 7) CONSUMER CREDIT COUNSELING DIVISION OF FAMILY SERVICES 110 West 10th Street Erie. PA 16501 (614) 454-6478 Clarion, Crawford. Elk, Erie. Jefferson, McKean, Mercer. Venango & Warren Counlies 8) CONSUMER CREDIT COUNSELING SERVICE OF NORTHEASTERN PENNSYLVANIA Connell Building. Sulle 401IBox 168 Scranton. PA 18501 (717) 655-9527 Bradford, Carbon, Columbia, Lackawanna, Luzeme, Lycomlng. Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tioga. Wayne & Wyoming Counlies 9) ECONOMIC OPPORTUNITY COUNCIL OF READING-BERKS COUNTY. INC. 227-229 North 4th Street Reading, PA 19601 (215) 376-6571 Berks, Chester. Montgomery & Schuylkill Counlies 10) FAYETTE COUNTY COMMUNITY ACTION AGENCY, INC. 48 East Church Street Unlontown, PA 15401 (412) 437-6050 or (412) 437-4400 Fayette County only 3) CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 1031 West Linden Street Allentown, PA 19102.3903 (610) 821-4011 Berks. Bucks, Carbon, Lancester. Lehigh. Monroe. Northampton & Schuylkill Counlies m CCiviMISSION ON ECONOMIC OPPORTUNITY OF LUZERNE COUNTY 211-213 South Main Street Wilkes-Barre, PA 18701 (717) 826-0510 Carbon, Columbia. Luzeme, Monroe. Schuylkill & Wyoming Counlies 4) CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PA., INC, 309 Smithfield Street.Sulte 2000 Pittsburgh, PA 15222 (412) 471-7584 662 North Main Street Greensburg, PA 15601 (412) 838-1290 500-02 3rd Avenue P.O. Box 278 Duncensville. PA (814) 696-3546 1 st Federal Plaza-Sulle 406 North Mill Street New Castle, PA 16101 (412) 652-8074 Allegheny, Armstrong, Beaver, Bedford. Blair, Bul"" , C""II"i.., Crill I'JI "", C'JlJliu, Cldliun, Clui"r,uld, Fayette. Franklin, Fullon, Greene. Hunllngdon, Indiana, Jefferson, Juniata, Lawrence, Mercer, Mlmln. Snyder, Somerset, Union. Venango, Washington & We51I,',.,i"I"nd C..unli"". ~ ". . ~..- '1 .J , Merri R. Lane, P.C. 400 Market Street Twelfth Floor Philadelphia, P A 19106 215-922-0066 Fax 215-625-2501 ., ,-.( ~ J<tl1-'M'(7- J J( /'7'" 7 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works, If you need more information, call the Pennsylvania Housing Finance Agency at I-{BOO) 342-2397, LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMADO ESTA AGENCIA [ PENNSYLVANIA HOUSING FINANCE AGENCY] SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELIGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO 'HOMEOWNERS' EMERGENCY ASSISTANCE PROGRAM' AL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. .' J ;! ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS '" .1 I ". : ~ .ft .J> . J 1 Date: January 15,1997 Re: Michael Griffin & Erika Griffin 196 Willow Mill Park Road, Mechanicsburg, Pal Loan#15725642 To: MICHAEL GRIFFIN " From: Merri R. Lane, Esquire You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Assistance Act of 1983 (the "Act"), You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your contro', you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. 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 a representative of the lender, or with a designated consumer credit counseling agency. The purpose of this meeting Is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency Identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Merri R. Lane, P.C. 400 Market Street Philadelphia, Pennsylvania 215-922-0066 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting, You should advise this lender Immediately of your intentions. , :;1, . .,. ,', ::,;;;~~ur mortgage is in default because you have faile~to pay promptly installments of principal and interest, as required, for' a period of at least sixty (60) days, The total amount of the delinquency is $1,367.40, That sum includes the following: monthly payments' of $262.76, monthly late charges of $5.00, plus previous, unpaid late charges of N/A, ~4 ~ If you have tried and are unable to resolve this problem at or after your face-to- face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and :.- " file a completed Homeowners' Emergency Assistance Application :~ith one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency, The consumer credit counseling agency will assist you in filling out the application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow other time periods set forth in this letter. foreclosure may proceed against your home immediately, . .". ., Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application, During that additional 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 Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1 (800) 342-2397 (toll free number). Persons with impaired hearing can call 1(800) 342-2397. In addition, you may receive another notice from this lender under ActS of 1974. This notice is called a "Notice of Intention to Foreclose", You must read both notices, since they both explain rights that you now have under Pennsylvania Law, However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. GREEN TREE FINANCIAL CORPORATION --) ~ ~ By: ~c..- L--- MERRI R. LANE ..; 'I ... .1 .>" ~i ., . ..... , . 21) JOHN F. KENNEDY CENTER, INC. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 Crawford & Erie Counties 14) L YCOMING-CLINTON COUNTIES COMMISSION FOR COMMUNITY ACTION (STEP) 1221 West 3rd Street, P.O. Box 1328 W1l11amsport, PA 17703 (717) 326-0567 Clinton & Lycomlng Counties " , " 26) MON-VALLEY UNEMPLOYED COMMITTEE 116 Fifth Street McKeesport, PA 15132 (412) 678-1409 Allegheny, Beaver, Butler, Fayette, Greene, Washington & Westmoreland Counties 28) NEIGHBORHOOD DEVELOPMENT ALLIANCE 5935 Ogontz Avenue PhiladelphIa, PA 19141 (215) 424-1111 Bucks, Chester, Delaware, Montgomery & Philadelphia Counties 31) INDIANA COUNTY COMMUNITY ACTION PROGRAM Box 167 Indiana, PA 15701 (412) 465-2657 I' f I Armstrong, Cambria, Clearfleld, Indiana, Jefferson & Westmoreland Counties 12) HOUSING COUNCIL OF YORK 116 North George Street YOri<, PA 17401 (717) 654-1541 Yori< County 19) HOUSING ASSOCIATION OF DELAWARE VALLEY 1314 Chestnut Street, Suite 900 Philadelphia, PA 19107 (215) 545-6010 658 North Watts Street . Philadelphia, PA 19123 ~(215) 976-0224 20) HOUSING OPPORTUNITIES, INC. 133 Seventh Street, P.O. Box 9 McKeesport, PA 15132 (412) 664-1590 ': Allegheny, Beaver, Buller, WaShington & Westmoreland Counties ~N ~J~ v.. ' c! ~ ~ ~ ~ ~ ~ 2:! I 1 . . ~ ~ ~ ~~ \:::'. Merri R. Lane Merri R. Lane, Esquire Attorneyl.D. No, 37617 400 Market Street Twelflh Floor Attorney for Plaintiff GREEN TREE CONSUMER DISCOUNT COMPANY Philadelphia, Pennsylvania 19106 215-922-0066 GREEN TREE CONSUMER DISCOUNT COMPANY Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY v. TERM MICHAEL N. GRIFFIN ERIKA G. REED a/kIa ERIKA GRIFFIN Defendant(s) NO: 97-1938 PRAECIPE FOR ENTRY OF JUDGMENT UPON DEF AUL T TO THE OFFICE OF THE PROTHONOTARY: Kindly enter judgment in the within action in favor of Plaintiff, GREEN TREE CONSUMER DISCOUNT COMPANY, and against Defendant(s) Erika Reed a/kIa Erika Griffin, for failure to respond within the required time to plead to the Complaint for the following amounts with costs: Principal Balance Interest from $2,020.99 Attorney's Fee's (5% of Principal Balance) Escrow Deficiency Accrued Late Charges (@ Appraisal Costs $21,339.26 $1,066.96 $268.00 $20.00 $270.00 TOTAL $24,985.21 Plus interest from date of Judgment and all other sums advanced pursuant to said mortgage and attorney's costs as appropriate. DATED: 6/11/97 ME~~ -;/ MERRI R. LANE, ESQUIRE Merri R. Lane, P.C. Merri R. Lane, Esquire Attorney l.D. No. 37617 400 Market Street Twelflh Floor DISCOUNT COMPANY Philadelphia, Pennsylvania 19106 215-922-0066 Attorney for Plaintiff GREEN TREE CONSUMER GREEN TREE CONSUMER DISCOUNT COMPANY IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY Plaintiff v. : TERM MICHAEL N. GRIFFIN ERIKA G. REED a/kIa ERIKA GRIFFIN : NO: 97-1938 Defendant(s) CERTIFICATION I hereby certifY that a Notice of Intention to Take Default was served upon the Defendant Erika Reed a/kIa Erika Griffin named herein on May 27. t 997 ,by First Class mail, postage prepaid. A copy of said Notice and postal form is attached hereto, made a part hereof and marked Exhibit" A" . The Complaint was served upon Erika Griffin on April 24. t 997 by Sheriff of Cumberland County. A copy of said service is attached hereto, made a part hereof and marked Exhibit "B". DATED: 6/11/97 2~-z~ Merri R. Lane, Esquire Attorney for Plaintiff , ....--....~ ,'j r~ MERRI R. LANE, P.C. MERRI R. LANE, ESQUffiE ATTORNEY I.D. # 37617 400 MARKET STREET TIVELFI'H FLOOR PHILADELPmA, PA 19106 (215) 922-0066 GREEN TREE CONSUMER D1<iCOUNT COMPANY Plain/iff ATTORNEY FOR PLAINTIFF : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY vs. TERM MICHAEL N. GRIFFIN ERIKA G. REED aJkJa ERIKA GRIFFIN Defendant NO. 97-1938 NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA : Erika Griffin, 4703 East Trindle Rd. Mechanicsburg, PA 17055 DATE OF NOTICE : May 27, 1997 FECHA DEL A VISO : IMPORTANT NOTICE You are in default because you have failed to take action required of you in this case. Unless you act within ten (10) days from the date of this notice as set forth above, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephonl: the following office to find out where you can get legal help: .' LAWYER REFERRAL SERVICE Cumberland County Courthouse, 4th Floor 1 Courthouse Square Carlisle, PA 17013-3387 Telephone 717-240-6200 EXHIBIT I /} f\\' ..,.".,.,'", - :.:;',:~;:~' ;:- . , " i .' '.:.,... ."...;;--.."0 :-.-, . '.. ...........-- . - .... -...-..- ... "j - .~: .:', ..,/~~~~" ~,-~ > ~ - " .' "- ,.' "--::"~': " A "VI ... USlO fOft DOMUnc AHa lHTlI\HAnOMAL MAIL.JJOU HOT OlfOftINSUAAHCI-rOSTMASTtR ANi. 1M __In II-.mO' ~"orn: .. '......... - . . ~..... -, ., ! ",~i~' Iii;;:''':; l,:i:~1 400 MarketStretl .~" ,ili:~g. PhUadeJpbla, PA 19lb~ 'g" ~r-r ~ ~~~'::i'<:~:') , :cJ ') r.'.'. .... "i:l t \ ~ .(h, ? ;:? ,'. :'~.: ~ \. . ~ J;f ,: .. I ~ " ~l i " .\. 0" /" /1.'.... --. '. ,1 ~.......-:. ,''''' . , I\\f.''''?' ~. " .. I ...'?" ",,', l4./ ". ~l IlilCl ~ .:: 1\,... %. . w1i-,j H -3.../ , .' ! I ". MERRI R. LANE ES . .. '. \.IJ , . u.s. lJ'O,1m-2'Q.51\ill5:1Jl\ -.... . - '.---'-. .......,-- .... ...... / .. .. :~:' .~~:..~.~-.!....::- ":'..: , ", . ,.j.:,,,.;,,, .....'~.:.;.'...'...'.....':,...,:..,..',..' .',....:,. !.;~.~..\:. -~ . . '.'" .' -. ,,"' ",' .,-, :./:.....:....... ~ '..~. . ,_.. . ~. ....:. .:-~.:..-.. , ............ ........ . .~ '.". . .. i.. 'j'I,_, ". , . -- .; ... .',. ....;\"......:.., .:,' ~ . ,: 'R '.~.\..;j.ht -:,' l~:..lt~~..~t' ili'~ .. ";r' ;.(.;~~I ;,,:. :.~,.",j~ .": ....:~ ..h.r~', ..;... .:~ ':..;.~,_. 'I '.,' J ~;.;':,:,'~,~;i.t.lt. "'-'II ~l,;/~i~!.::~ .~.~.!.~:~q~~~.!~t~~!~:;\~it!,'7~(.1:JU~~ulmNhll~J1~~~~~~{Hi!h ~'~ ", ,ir..I-"~:'..., ..~,.-,., ~., ',' : ': "'<< I., "',';'. ",' i. ';.. I' " ,"'j I. ,I. \, 14':.",;. , l, .......~-.. : l:.t.-.,~, .,'1 {il. ,Jfll;/,' ~I' ~\ t'rl ~ '.fih~' ~~~~ ~t"~ !1M notf" ..~ ~ ~ .::, ;N~' l~'~:'~'~;. .:i!""":,": ,i~,: ;j~;-: l~;...;-t (...:. ::';'~' '.i.~.:~lf:':'I; ~~l' I. :~\.:.;'!~ .:~.i\'~:":. :J"I ~:':~Itllr ~,~i :::1.0"1' ..~ 4.' ., ~, ''','' ~1: \ . :~~:~~:\, .l~. ,:.~~ ,I ':1 \',"r,\:.t:t't;l!,}/..,. !1.1fl,;~ Iftonti:1 ,,,.,\;r::,;.~...\~'..'1: ;',i\' ."'::':.', ~ .'..;.' "':, ~-".r ::" ;':';" "-, '~r 'I I', I:," :',.. . ,....".. :,"" ,:.';"...~ CJ.j"'~'~lt:"flt h1j'vll\'lU, {I,j .;, i 1~j {J " , . '.... .. ;, l' ~ " .': ", I ,',:: ::;"', : .. ::', ''';;':'''I~';:;.::,:::''.,',~111,~:j;:i:;~..;lir?:,~'i';;..f''Jt1'~~. . "" , "'n .... ," . ',.. ," :,1".7 h l,~' ~ I ~ ,\~.t,n:;::jl::Y~~li>I:~{,l~'" i'\,1~1~',.::':~};:5!Q;'I,I,: . . . '~',. '. . " .--.;., ~':'~'~.:.:.:. .:' ,'~', :"Y;" .'.:'-:: :':.:~:~,:::>:~,,-~,:~}~,\~ -. 'f" ~',' .,', .... ',. ~.. ,- , .. " SHERIFF'S RETURN - REGULAR CASE NOI 1991-01938 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GREEN TREE CONS DISC CO VS. GRIFFIN MICHAEL N ET AL ETC KATHY J CARPER -J Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within ~OMPLAINT - MORT FORE was served upon RFFn FRTKA r, A~/A FRTKA_GRIFFTN defendant, at 1023100 HOURS, on the 24th day of April 1991 at 4103 EAST TRINDLE ROAD MECHANICSBURG.. PA 11055 . CUMBERLAND County, Pennsylvania, by handing to ERIKA GRIFFIN a true and attested copy of the COMPLAINT - MORT FORE and at the same time directing Her attention to the contents thereof. the Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 2.00 So answers: '~~~~a H. Thomas K11ne, ~her1:fx $8.0~ MERRI LANE OS/22/1991 by t:. J.1 Dot4! e~1or Sworn and subscribed to before me this day of 19 A. D. I'rothonotary "~' ~EXH Ian' '", 'v, ~I,.-.:I'."', 1'_~{(t21{~~~{~~~ , .,.:,..,.._,Q",,-,;,~:,_,-:,'>-"t';~i"~-' .,' -~"<<~-r(~~:Y!~'~~fit~~; ! , , ! ." I, I I I f I Merri R. Lane, P.c. Merri R. Lane, Esquire Attorney I.D. No. 37617 400 Market Street Attorney ror Plaintiff GREEN TREE CONSUMER GREEN TREE CONSUMER TwelRh floor Philadelphia, Pennsylvania 19106 215-922-0066 GREEN TREE CONSUMER DISCOUNT COMPANY IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY I'lalllliff : TERM v, MICHAEL N. GRIFFIN : NO: 97-1938 ERIKA G. REED a/kIa ERIKA GRIFFIN Defelldall/(.v} CERTIFICATION OF ADDRESSES I hereby certifY that the within Plaintiffs address is: 332 MINNESOTA ST. SUITE 610 ST. PAUL, MN 55101 And that the last known address ofDefendant(s) is : 4703 East Trindle Road, Mechanicsburg, Pa. 17055 DATED: June 10, 1997 ~ c::: .I //Z:; J ( Merri R. Lane, Esquire A /lomey for Plalllliff SWORN AND SUBSCRIBED BEFORE ME THIS //"'DA Y OF .),. _ .'- ,1997 . r 7J7:~r(1 Ill-{;/!I- NOTARY SEAL NOT ARIA!. SEAL FRANCIS A. HILT. NOIIty PublIC Crty 01 Phrlade!phil, Phlla. County -_!~L9~T!~::.~(:~ E_x ires 5 ,. ,~ ~~ f: .0 (') ~ -..I -n (Bb. t_ :1 50(,. c::: "- .7; ;;g )\ .::r, - -'co ~,~ tn.:" - ';f ;:s .'. W "'.1 _t.1 J~ w~ ~ ~ ~~ .-Co ~~ 5;0 N C ~ ;!': .. ~ I\) i -. w I SHERIFF'S RETURN - REGUI.AR CASE NOI 1997-01938 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUKBERLAND GREEN TREE CONB DISC CO VS. !3R In'I!i M IG.IJ,AEk..1i ~L~I._~J'_C_ ___ --'il\THY J C^~__ ...___. Shll'riff or Deputy Shvriff of CUMBERLAND County, PennBylvania, who bll'ing duly Bworn according to law, Bays, thll' within ~OMPLAIK~QHI-EOB~_ was served upon RF.F.O F.RTKA r. A/,]{I A F.RTKA._GRlmH_._ the defendant, at 1023100 HOURS, on the ~~.Q day of April 1997 at 4703 EAST TRINDLE ROAD MECHANICSBURG.. PA 170~~ . CUMBERLAND County, Pennsylvania, by handing to ERIKA GRIFFIN a true and attested copy of the COMPLAINT - MORT FORE and at the same time directing [~~ attention to the contents thereof. . ( Sheriff's Costs I Docketing Service Affidavit Surcharge 6.00 .00 .00 2.00 $B.IIH/! So answers I H. ThomC:~::;.~ "ERRI LANE 0~/22/1997 ~ by ~J..r.~ Sworn and subscribed to before me this ....d3"...( day of ~.. I 19 'i7.A.D. q~~raho~ ,-~ l I '. SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NOI 1997-01938 P COMMONWEALTH OF PENNSYLVANIA I COUNTY OF CUMBERLAND GREF.N TREE CONS DISC CO VS. GRIFFIN MICHAEL N ET AL ETC R.. Thomas Kline -J Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, snrved the within named DF.FENDANT. G~IFFIN MICHAEL N by United States Certified Mail postage prepaid, on the __~9th day of ~pril , 1997. at 1500~~0 HOURS, at 70W6 PROUT ROAD FRIENDSHIP. MD 20758-9744 a true and attested copy of the attached _C~~~_~A!NT - MORT FORE The returned receipt card was signed by on 0/0P.J/0000. Additional Comments I LETTER RETURNED TO OFFICE OF SHERIFF ON MAY 22, 1997 WITH REASON CHECKED UNCLAIMED OR REFUSED. Sheriff's Coatsl Docketing Service Affidavit Surcharge CERTIFIED MAIL R/ 18.00 8.06 .00 2.00 3.75 $31.81 So anawera I, / ~ . ~?>;ni~:":~%~:ri%% I1ERR! LANE OS/22/1997 Sworn and subscribed to before me this .l,1.....{ day of 111...... 19 q7 1i. D. "7 11;'<1''- fI nA.tfP;\ .i..~' ':=f ~ono'&a.y , .' ~., , ..~, ._..I..,_....UI...t~H.III.S'.I.If:I:1._~ '* , ., - .' CERTIFIED' -,: . '.' " ....~-nll .--~ P 1192 348 452 ii , I COUNTY OF CUMBERLAND Olflce of The Sheriff 1 Courthouse Square Carlisle, Pennsylvania 17013 ^O... ' . v... "'1"0 I," . ""~. 'It, 40~ J' _~~., 'a"" ,+n, " If)> ~ ,~/'r lP ^ .''"' "'. ~rcs' ~. .t,ft. .y, .> ^o:+u;:' .~.: "'+ 2: \ ~') W';''VlII', "'",. '0 . 0. ""~ ':"') ... '., "'''t ' ~,'7Q;.,So!oq~.... J .~ ~ ;~:; .' MAIL;. f ". I' . : . . . . . . . . . . . ~ET\mN \l.tr.n~1 l\t~\W.S1f.1' .,_..~ ~. ~- ',. " ~ ... It I I \ ! , g IJ Ii : 97-1938 Civil ~erm _Comptltllteml 1 ~<<2 forlddlllonll MMc:e'. _CornpIet, 1t1ml3. .... and "b. .Prtnl your name and .dd..... on ChI,."""" ollhit form 10 IhIt M can rIC\I11lh1. _I.~. -Anach 1hI. form to the frort of IhI maIIP'eOs. CN'(lf1 the bac::* It IpICe doll not ,*",1. .Wrtt,'RIlum R<<>>IpI R<<lUHtld"on the mal,*- below She IItldt n&.rrbIt. aThe RetLm RapC oMlshow to whom thllllIda wu dI~ end the d&1, ...-. 3. Ar1lcIe Addr.ssed to: Michael N. Griffin 7006 Prout Road Friendship, MD 20758-9744 5. Received By: (Pltnr N/lIrHI) I e100 wish to receive the following ..Nlcea (lor an axtra f.e): i ',', 1. [J Addr.....'. Add".. 2. [J R.strlc\ed Delivery Consult poslmaSler for lae. t ' 48. A/1lCI. Numbsr I P 492 348 452 4b. S.rvlce Type ~ o Reglst.red ~ Cel1lned i o Exp"" Mall 0 lnoured f o RslumR.celllUorMetdlsrdsa 0 COD . ~, l: e. Addr....... Addr... (Only" requested tl:: end IH Is paJd) ~ 7. D.t. 01 DallVlry !l 6. Signature: (AddrrlU/Je 0( Agent) ~ X .!I PS Fonn 3811, December 1994 .<. '" '. "~-"" -., . , , MERRI R. LANE Attorney 1.0. No. 37617 400 Market Street Twelfth Floor Philadelphia, Pennsylvania 19106 216.922.0066 15725642 (' . ' Attorney for Plaintiff GREEN TREE CONSUMER DISc6uNT COMPANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY GREEN TREE CONSUMER DISCOUNT COMPANY 332 Minnesota Street SI. Paul, Minnesota 55101 Plaintiff NO. v. MICHAEL N. GRIFFIN ERIKA G. REED a1kla ERIKA GRIFFIN 196 Willow Mill Park Road Mechanicsburg, Pa. 17055 Defendant( s) TERM 1'7- /tjif (1~ COMPLAINT IN MORTGAGE FORECLOSURE NOTICE TO DEFEND NOTICE' Yo. haft btea s.... Ia COIISt. It yo. wisb 10 clefa!chpiasl !!Ie dIl8 at fortlr ta 1'- followier pqa. ra..._ lib acliOD .rIIIa IWllltJ' (201 cla" I/br Ibis co"'" aad .odco ... wr'IOd. by acariD. .. wriraa I\IPIIlIIIClI \lftIllO&IIr or by ISUIIDIl' IlIlI fIIla. la writlai .,b 1'- co,," ro.... dar..... Of ab~ 10 1'- daiJnI SIt fonll aplasl yo... you.... .......d Ibu If )'OIl ClllIO do 10 ,''' ... mar IlI'O<Zt1I wilhoUI rOU IIId . ~I nar be alllml 'IIlns1 Ylltl br lbe COlin ,,'bour lllnbtr .olleo ror IIIl' _ cla.imad I. lho .:ompWnI 01 ra. ..r albtr claim a. rdlof ~..d br lho \lIIiDarf. You mar 1o?i ......, or ""'l'ITIr o. a..... richlS 1I"1lO"1II'10 you. YOU SIIOULD TAKE 1ll1S PAPER TO YOUR LAWYER AT ONCE-IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. CO TO OR TELUIIONE 1llE OmCE SET FOR1ll BELOW TO FIND 0l1t' WHERE YOU CAN GET LECAL IIELP. SEE ATTACHED AVISD lA. baa'dnwIado .. _ III 1& oam. $I IIIlad qalm cII(auImo" do ...... I ... ,.1;1 CD IU pipos' .......... - - willie CUll clIa dI'pIam >I pudr da 1& l'Icba da 1& dnIIDda r 1& IIO\ll\C&dOII. /fam (aISa """"at _ CD...... ~ acrIaI 0 III __ 0 ..... l8I.bopdo r......... II CO~ .. fa.- tserill I. dal...... 0 S.. abjldllMl I 101 damlllciII ... ......11 do, SIII'IfJQ1I&. Sea lrisado qua s1llS1a4 no . d.rfkndI. 11 CDrtI la...n IIIIdJdu r I*da CIlIIliJIlIII 1& dI_ CD coma "'" sla pmlo lriIo 0 .adftcadlia. AdtmU. II CD'" ~ doddIr . f.",. dtl damanda," Y ,.q..... qua ...rd cu"""" _ ladu III "",risioM. da .... da.....da. llslld putda pmII. dlntlO 0 'III ptOl'\CcWIa U alIOS dam:llor 1"""'"11I1" 17111 url<d. LLEVt ESTA DEMANDA A UN ABOCADO IN. MEDIA T.ulENTE. SI NO T1ENE ABOCADO 0 SI SO T1ENE EL DINERO SUFlOEHTE DE PACAR TAL SERVIOO. VAYA EN PERSONA 0 LLAME PaR TELEr-ONO A LA OFlONA CUY A DIRECCON SE ENCUENTRA ESCRITA ABAJO PARA AVERICUAR DON DE SE PUEDE CONSEGUJR ASlSTENOA LEGAL. , .I Where arc lawyer rcferrnl servic~ available? . , .~. At the prcscnttime, there arc nineteen local referral services in Pennsylvania, and they serve twenty counties, U you live in on~ of those counties or need an attorney there, you should conlact that county refeml service. Each loCal service is operated by the county bar association. Uyou live in a county that docs not have a local service, telephone the Pennsylvania Lawyer Rcfeml Service oPerated by the Pcnnsylv;Wa Bar Association. You should also phone the Pennsylvania Lawyer Rcfeml Service if you need a 13~cr in a county without a locnl service, even if you don't live there, Uyou need an attorney in a sute other than PCDDSylvanin, conl.1ct tbnt SUte's bar association by calling directory Information and requesting the telephone number. Most sutes have locnl or SUte rcfeml services, lII1d the SUte bar lISSOCintion will be able to direct you to them. RUFERAL SERVICES IN PENNSYLVANIA For C~' Wilhoutllocal smi", PCDDI)'I laW)'<< IW'cml Scrvi", too SouIh S Harrisl>ur& PA 7108 717.231k17U( . ....andOUl.rJU..e&llcn) t400.692-73" 1m in PA. oultide 1IarriJburi....) ALLEGHENY CO .PITrSBURGll Allegheny Ilu As>ociatioa 3100nnlSL 4.0 0nnI Buildinl I'iUsburgh. PA 1"19-:120] 41.-261~1l8 BEAVER COUNTY-BEAVER Tl54tbSlr<d Beaver, PA 15009 412.72l104318 BERKS COUNTY.READING BcrIts Coumy Ilu ADociIlioa 544 CO<lr\ Slr<d P.O..Box 1058 Il<ading, PA 19603 610-]7'-4591 BLAIR COUNTY HOUlDAYSaURO, Blair Cotmly Ilu ADociIlioa Courtb..... u'bnry H.llidaysburg, PA 16648 81~95.SS41.... 418 BUCKS COUNTY. DOYLESTOWN Bucks County Ilu ADociIlioa 1]5 EastS....Slr<d Doylcsw.n. PA 18901 215-]48-941]/s36-843m" CHEsrER COUNTY. WEST CIlES1'ER Cbcst.cr Ilu atioo UWcstOal . W... . PA 19310 610-696-5094 / ERIE COwrY-ERIE Eli. Cowlly Bar ~oa 50IS_S_ Eli., PA 16107 814-459-3111 DAUPH[NCOUNTY-~SBURO Dauphin <;9WllY Bar As>ociati... 2IJNor1lfFroalS_ Harrisl>ur& P A 1710 I 717.232."]6 DELAWARE COUNTY-MEDIA Delaware Cowlly Bar AsIcciIlioo From 01: I=on SIRclJ Modi.. PA 1906] 610-566-6625 LUZERI'/E COUNTY- WlLKES-BARRO W'lIkcs-Buro La... u'bnry A.ssoci.Il.ion Room 23 Courtbowo WiIk...Buro. PA 18711 717-822-671. MOl'ITOOME NO . MO MERY COUNTY BAR OClATION 100 WEST AIRY STREET P.O. Box .61 Norrislowa, PA 19404 0268 610-270-9660 NORTIIA.\lPTON COUNl'Y. EASTON Nortb=ptou Ilu Association I" South!ltb Strccl E.u<ou. PA IS04. 2U.25Ik1]]] LEIlIGH COUNTY-A!lmrOWN LdUsb COWlfyIlu A>socWioo Old Courthouse, Room]04 f'llIh 01: IbmiIIoa S..." A1J....wn,PA ISI05 215-1]].7094 PIIIUIlELPIllA COUNTY. PIIIUIlELPIllA 000 IW<ilils C<lll<t . IplW, PA 19107 2 -138-1701 OTON COUNTY WAS ON Wuhinaum Ilu AsIcciIlion 523 Wuhin8100 run Buildinl WuhinSlOOoPAI I 412-255-6710 YORKCOUNTY.YORK York Cowlly Ilu ^-iIlioa CouItbowo Yorl<.PAI70C01 . 717-85447" COURT ADMINISTRAT~R C1UMBERLAND CO COURTHOUSE COURTHOUSE SQUARE 4th FLOOR CARLISLE PA 17013 (717) 240 6200 3387 Escrow Deficit Credit TOTAL 5. The attorney's fees, set forth above are in comformity with the Mortgage documents and Pennsylvania law, and will be collected in the event judgment is entered against the defendants. If the Mortgage is reinsJated prior to judgment being entered, reasonable attorney's fee will be chargeC:t: 6, If required, Notice of Intention to Foreclose has been sent to Defendant{s) by Certified Mail as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the date set forth in the true and correct copy of such notice attached hereto as Fxhibit "C". 7. Notice required by Pennsylvania Act 91 has been sent to each defendant and is attached hereto and marked Exhibit "0" and each Defendant has either failed to proceed thereunder within the prescribed time limit, or has been determined ineligible or Plaintiff has not been notified of Defendant's eligibility in a timely manner. If this Mortgage is insured by the Federal Housing Administration (FHA) under Title II of the National Housing Act, by the FHA as above described, then the notice described in this paragraph is not required and has not been sent and therefore no copy is attached. WHEREFORE, the Plaintiff demands judgment against each defendant herein, jointly, severally in the total sum stated in paragraph 4 plus interest from July 15, 1996 at the rate of $7.22 to the date of judgment and other costs and charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged property. DATE: March 25,1997 z~ L-- MERRI R. LANE Attorney for Plaintiff FAIR DEBT COLLECTION ACT NOTICE Pursuant to 15 U.S,C. Section 1601 as Amended This is an attempt to collect a debt. 1. The amount of the debt is stated in paragraph 4 of the Complaint attached hereto. t. , - 2. The name of the creditor to whom the debt is owed is <<plaintiff>> <<plaintiff211 <<plaintiff3>>. 3. The debt described in the complaint attached hereto and evidenced by the copy of the mortgage note will be assumed to be valid by the creditor's law firm unless the debtor(s), within thirty (30) days after receipt of this notice, dispute, in writing, the validity of the debt or some portion thereof. 4. If the debtor(s) notifies the creditor's law firm in writing within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the creditor's law firm will obtain verification of the debt and a copy of the verification will be mailed to the debtor by the creditor's law firm. 5. If the creditor named herein is not the original creditor and if the debtor(s) makes written request to the creditor's law firm within thirty (30) days from the receipt of this notice, the name and address of the original creditor will be mailed to the debtor by the creditor's law firm. 6. Written request should be addressed to Fair Debt Collection Clerk, Merri R. Lane, P.C., 400 Market Street, Philadelphia, Pennsylvania 19106. 15725642 MERRI R. LANE . Attorney 1.0, No. 37617 400 Market Street Twelfth Floor Philadelphia, Pennsylvania 9106 215-922-0066 Attorney for PlaIntiff GREE TREE CONSUMER DISCOUNT COMPANY .I' , GREEN TREE CONSUMER DISCOUNT COMPANY 332 Minnesota Street St. Paul, Mlnne80ta 55101 Plaintiff : NO. v. MICHAEL N. GRIFFIN, at al . : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY Dafandant(s) TERM VERIFICATION I, the undersigned he eby verify that I am a repre8entatlve of the plaintiff and' am authorized to mak~lthl8 Verification. I hereby verify that the facts set forth In the foregoing comp,llnt are !rue and correct to the best of my Information and belief and th t this statement Is made subject to the penalties of 18 Pa. C,SA 4904 relating unsworn falsification to the authorities. Date:3-t5lS-CJ7 f)?jr.vuH{}-U~ I , r. . U"c'.u lIallllU UIl IHH l'I(NN:lVI,V" /{", .1,;' "';'/;1 1'lul'''I'"'' "y "1111 Ih,tul'u tn. Urdun 1'rult CnlUHllnUl' 1)IMlHHlnt: COlTll'''''Y 1I0mu Illlt'rovulllUlIl: Illv lu lUll JJ2 Hlnnuuuta St., Suite Ato St. raul HII 55101 Commonwealth or Penn.ylvanla c;r U 19 090 .9/''') Space Above Thl. LIne For RecordIng Dala OPEN.END MORTGACi: This Mortgage secures future advances 1. DATE AND PARTIES. The date of this Mortgage (Security Instrument) Is "'ff,;::....I.t.:.1.p..:t?..................... and the parties, their addresses and tax Identification numbers, If required, are as follows: MORTGAGOR: Hichaol N Griffin and Erika G Rood" 196 Willow Hill Park Rd Hechanlcoburg PA 17055 ......If checked, refer to the attached Addendum Incorporated herein, for additional Mortgagors, their signatures and acknowledgments. LENDER: VINYL EXTERIORS INC SUITE BBBB GREENTREE SQ HARLTON NJ OB053 2. CONVEYANCE. For good and valuable consideration, the receipt and sufficiency of which Is acknowledged, and to secure the Secured Debt (defined below) and Mortgagor's performance under this Security Instrument, Mortgagor grants, bargains, conveys and mortgages to Lender the following described property: parcol 10' 3'6- h; -/0'0 . OG I (Boe attached 10gal) "AKA ERIKA GRIFFIN The property Is' located In .......................9.W:l.l!!!!!f<l\!lp.............................. at ............................................. (County) 196 If.tJJ.'?.':'..111U..r.!\F.LI,l.c;I......................., ...........!1!!!;h!\!\~~~.I;>.~."g............... , Pennsylvania ....E9.~.L......... (Add",,) (CIty) (ZIP Cod.) Together with all rights, easements, appurtenances, royalties, minerai rights, 011 and gas rights, all water and riparian rights, ditches, and water stock and all existing and future Improvements, structures, fixtures, and replacements that may now, or at any time In the future, be part of the real estate described above (all referred to as "Property"). EXHIBIT PENNSYLVANIA. MORTCACE {NOT mR rNMA. rIll.Me, rJlA OR VA usn ~ o 1994 flAnkers SyIl'rT", 'n(., 51. Cloud, M~ (1 11001972).41) form tTlI MTCLAZP^ 10lt 1/9 ~ () CT 1J.)9 09(1 (q/94) (pd" f af ~J I \ t (' III. 1'f1111'~11I Y . f 111111111111, AI 11'IlA 11I1t1'! AIIII 111'1'1:' 11014. MIlIluaUl1I will ~""I' Ih.. I'III\IIIIIV '" \11111I1 '"'" 11111I1 ~IIIllll"I", ~1I1"IIo.I.. 111011 '"I/'II'UllII'IIIIV 1111111 U ,II V MIII'II'IUIII ~Ilalllllll 1:1I1111111 III r"IllY Ally VI,"'U l"II'~IIIII""I,," '" '"1111,.1111" II 11111 1""I'"nV Mlllll\'IUIII wi h""II'"'I""I1""V '"'' II III1Nhll" '., 'l/u,"I, ~IIII UI,,~~II~, 1~II"HI/"' ~Illllll~ 110,11 Ihll 11,1111111 III 1111 "" "1',1111 V """ 11\1' will 11111 ",h'I,ll1l1AIIV dl~"Uu wIIIII'"1 IIIllIlu.', l"lll wlllI'"1 "11""111' MIIII\"'UIII will 11111 1'''"1111 AIIV l.h""I1" '" AIIV IIcallr'" ;u."\lIIYU .IIYUII,.II' '" II" 1111111111 wlllll'"1 111111.11'. II' '" wlllIIIII ""''''"'' MII'IIl"1l1ll will IIl1l1fV "rill 1" III ~lt 'IIU'II~,"h, 1'''" ,,",III1U" .1.1111" ,11111 ,II lillII' .IU,IIII,I MII,IU,Ium, 011111 of .IIlV luu "' cJ.111101,'1l 10 Ihl! "fllpUfIV. t ollder or '-","lm', ,"JllIlIO III~y, 01' IUIIIIIl'" "\"11111, 1'1111" Ih" "rorellY n. nny renson,1bfe Ihn" for Ihe . ur ose nl Insl'ucIIII!! Ihll "flllllllly. '-ulldur s 1.111 IIlve Mort!lngur nollce n. the lime of or before nn rns&ectlnn sreclfylll!! d ru.,nn.hle lI11fllOSIl for the Ins pHilo I n. ~nlY IndsP,ecllon of the Property shall be entirely for lencJer's hllnufll nncJ Mnrtgnllor will In no wny re y Oil en er s Inspecllon. , 11 AUTHORITY TO PERFOI\M.1I Mortgngor fnlls to perform any duty or any of the covenants cOnla'ned In . this Security Instrumen., tender may, wllhout nollce, perfor')1 or cause them to be performed. Mortgagor appoints lender as attorney In fact to sign Mortgagor s name or paV any amounl necessary for performance. lender's right to perform for Mortgagor shall not create an obllg~tlon to perform, and Lender's failure to perform will not preclude Lender from exercising any of Lender s other rights under the law or this Securltv Instrument. If any construction on the Property Is discontinued or not carried on In a reasonable manner, Lender may take all steps necessary to protect Lender's security Interest In the Property, Including completion of the construction. '2. ASSIGNMENT OF LEASES AND RENTS. Mortgagor Irrevocablv grants, bargains, conveys and mortgages to Lender as additional securltV all the right, title and Interest In and to any and all existing or future leases, subleases, and any other written or verbal agreements for the use and occupancy of any portion of the Property. Including any extensions, renewals, modifications or substitutions of such agreements (all referred to as "Leases") and rents, Issues and profits (all referred to as "Rents'). Mortgagor will promptlv provide Lender with true and correct copIes of all existing and future Leases. Mortgagor may collect, receive, enjoy and use the Rents so long as Mortgagor Is not In default under the terms of this Securltv Instrument. Mortgagor agrees that this assignment Is Immedlatelv effective between the parties to this Securltv Instrument. Mortgagor agrees that this assignment Is eFfective as to third parties when Lender takes affirmative action prescribed bV law, and that this assignment will remain In effect during any redemption period until the Secured Debt Is satisfied. Mortgagor agrees that Lender may take actual possession of the property wIthout the necessity of commencing legal action and that actual possession Is deemed to occur when Lender, or Its agent, notifies Mortgagor of default and demands that any tenant pay all future Rents dlrectlv to Lender. On recelvln9 notice of default, Mortgagor will endorse and deliver to Lender an'l payment of Rents In Mortgagor s possession and will receive any Rents In trust for Lender and WIll not commingle the Rents with any other funds. Anv amounts collected will be applied as provided In this Security Instrument. Mortgagor warrants that no default exists under the Leases or any applicable landlord/tenant law. Mortgagor also agrees to maintain and require any tenant to complv with the terms of the Leases and applicable law. 13. LEASEHOLDS: CONDOMINIUMS: PLANNED UNIT DEVELOPMENTS. Mortgagor agrees to complv with the provisions of any lease If this Securltv Instrument Is on a leasehold. If the Property Includes a unit In a condominium or a planned unit development, Mortgagor will perform all of Mortgagor's duties under the covenants, by.laws, or regulations of the condominium or planned unit development. 14. DEFAULT. Mortgagor will be In default If any party obligated on the Secured Debt falls to make payment when due. Mortgagor will be In deFault If a breach occurs under the terms of this Securltv Instrument or any other document executed for the purpose of creating, securing or guarantvlng the Secured Debt. A good faith belief bV Lender that Lender at any time Is Insecure with respect to any person or entltv obligated on the Secured Debt or that the prospect of any payment or the value of the Property Is Impaired shall also constitute an event of deFault. 1 S. REMEDIES ON DEFAULT. In scme Instances, federal and state law will requIre Lender to provide Mortgagor wIth notice of the right to cure or other notices and may establish time schedules for foreclosure actions. Subject to these limitations, If anYbLender may accelerate the Secured Debt and foreclose this Securltv Instrument In a manner provided V law If Mortgagor Is In default. At the option of Lender, all or any part of the agreed fees and charges, accrued Interest and principal shall become Immedlatelv due and pavable, after giving notice If required by law, upon the occurrence of a default or anvtlme thereafter. In addition, Lender shall be entitled to 011 the remedies provided bV law, the terms of the Secured Debt, this Security Instrument and any related documents. All remedies are distinct, cumulative and not exclusive, and the Lender Is entitled to all remedies provided at law or equity, whether or not ex press IV set forth. The acceptance bV Lender of any sum In payment or partial o 1194 !I"n~'n ~yll."'I. Inr. Sl. (Iou(t. UN '1 ..... l07l)"') rn,," GTII MfGUlrA 10/11/94 C1 . ~ 190110 10/94' (f"lt,.. 'tt(~' , ,. .." ..~ ....... ......,., ," ...-...........1 ......' .-.....-.......-. , " (~ r Unless otherwise agreed In writing, all Insurance proceeds shall be applied to the restoration or repair of the Property or to the Secured Debt, whether or not then due, at lender's option. Any application of '.,. proceeds to principal shall not extend or postpone the due date of the scheduled payment nor change .the amount of any payment. Any excess will be paid to the Mortgagor. If the Property Is acquired by .... Lender, Mortgagor's right to any Insurance policies and proceeds resulting from damage to the Property before the acquisition shall pass to Lender to the extent of the Secured Debt Immediately before the acquisition. 20. ESCROW FOR TAXES AND INSURANCE. Unless otherwise provided In a separate agreement, Mortgagor will not be required to pay to Lender funds for taxes and In~urance In escrow. 21. FINANCIAL REPORTS AND ADDITIONAL DOCUMENTS. Mortgagor will provide to lender upon request, any financial statement or Information lender may deem reasonably necessary, Mortgagor agrees to sign, deliver, and file any additional documents or certifications that Lender may consider necessary to perfect, continue, and preserve Mortgagor's obligations under this Security Instrument and Lender's lien status on the Property. 22. JOINT AND INDIVIDUAL LIABILITY; CO.SIGNERS: SUCCESSORS AND ASSIGNS BOUND. All dutIes under this Security Instrument are Joint and Individual. If Mortgagor signs this Security Instrument but does not sign an evidence of debt, Mortgagor does so only to mortgage Mortgagor's Interest In the Property to secure payment of the Securea Debt and Mortgagor does not agree to be personally liable on the Secured Debt. If this Security Instrument secures a guaranty between lender and Mortgagor, Mortgagor agrees to waive any rights that may prevent lender from bringing any action or claim against Mortgagor or any, party Indebted under the obligation. These rights may Include, but are not limited to, any antl.deflc ency or one.actlon laws. Mortga.or agrees that lender and any party to this SecurIty Instrument may extend, modify or make any change In the terms of this Security Instrument or any evidence of debt without Mortgagor's consent. Such a change will not release Mortgagor from the terms of this Security Instrument. Tne duties and benefits of this Security Instrument shall bind and benefit the successors and assigns of Mortgagor and lender. 23. APPLICABLE LAW: SEVERABILITY: INTERPRETATION. This Security Instrument Is governed by the laws of the Jurisdiction In which lender Is located, except to the extent otherwise required by the laws of the Jurisdiction where the Property Is located. This Security Instrument Is complete and fully Integrated, This Security Instrument may not be' amended or modified by oral agreement. Any section in this Security Instrument, attachments, or any agreement related to the Secured Debt that conflicts with applicable law will not be effective, unless that law expressly or Impliedly permits the variations by written agreement. If any section of this Security Instrument cannot be enforced according to Its terms, that section will be severed and will not affect the enforceability of the remainder of this Security Instrument. Whenever used, the singular shall Include the plural and the plural the sIngular. The captions and headings of the sections of this Security Instrument are for convenience only and are not to be used to Interpret or define the terms of this Security Instrument. Time Is of the essence In this Security Instrument. 24. NOTICE. Unless otherwise required by law, any notice shall be given by delivering It or by mailing It by first class mall to the appropriate party's address on page 1 of this Security Instrument, or to any other address designated In writing. Notice to one mortgagor will be deemed to be notice to all mortgagors. 25. WAIVERS. Except to the extent prohibited by law, Mortgagor waives any right io appraisement relating to the Property. 26. OTHER TERMS. If checked, the following are applicable to this Security Instrume~t: ...... Line of Credit. The Secured Debt Includes a revolving line of credit provision, Although the Secured Debt may be reduced to a zero balance this Security Instrument will remain In effect until released. " .X... Construction Loan. This Security Instrument secures an obligation Incurred for the construction of an Improvement on the Property. ...... Fixture Filing. Mortgagor grants to lender a security Interest In all goods that Mortgagor owns now or in the future and that are or will become fixtures related to the Property. This Security Instrument suffices as a financing statement and any carbon, photographic or other reproduction may be filed of record for purposes of Article 9 of the Uniform Commercial Code. ...... Purchase Money. This Security Instrument secures advances by lender used In whole or In part to acquire the Property. Accordingly, this Security Instrument, and the lien hereunder, Is and shall be construed as a purchase money mortgage With all of the rights, priorities and benefits thereof under the laws of the Commonwealth of Pennsylvania. 01 !J!H II"~'" Ciru,m1. ,... SI. Cloud. MN 11 linn 197 n"lI ron'"' GTIl Mrr.t^lrl\ 10/1'/tH roT lCj l!lnO(! {''I941 '...."e Sf" fCI (' r GTFC 15 1721819 320 13534 '.. " '.' 1<)/ :1.\,.6!/l- Prepared by and Return tOI Green Tree Consumer Diecount Company I hereby certify that the pr~cise addresB of the aesignee is 332 HinneBota St" suite 610 St, Paul HN 55101 " Signed. r<--- Home Improvement Divieion 332 Hinnesota St.,. Suite 610 st. Paul HN 55101" PENNSYLVANIA HORTGAGE ASSIGNMENT For value received, Vinyl Exterioro Inc a Corporation ("Asoignor") organized and exieting under the 1awo of tho state of New Jeroey aeoigno to Green Tree Consumer Discount Company and aeoigns, its succossors, whose addreoB io 1istsd above, a certain mortgage dated .' , ' / /" ,?tJ , 19 9':5"'. wherein Hichae1 N GritHn and Erika G Reed" ("Hortgagor(s)") granted a mortgage to Aseignor as mortgagee, recorded concurrently with this Hortgage Aesignment in the office of the Recorder, Cumberland County, Psnnsy1vania, together with the retail installment contract or note secured by such mortgage on the following described real property situated in Cumberland county, Pennoy1vania. (aee attached legal) "AKA ERIKA GRIFFIN Parcel No. 3g'- '6-I()i(}~CXJI Consideration amount on assignment is The above referenced Hortgage was recorded in Book _____, on Page _____. Date. .. 1/-?D-7.5- . Vinyl Exteriors Inc .. kDIL By: ''', /J- aC o/~\~'\,"'<Il "IIJ(c",,,~ Its: "\,' n', '. (\(, ,. ;' r ,) -. .'-........-_....-_...~.'..;,..""..... ...1.,.......,... ....:............ ... ..;,. _._...... .. '" ... ,.".............. "--~ ...._...._J';;.l."""'~....__.......... ... .....,...........H".'''.~. I-i I.-RIC r.C 15 1721819 320 13534 Sell~r N Griffin, Erika G Reed> VINYL EXTERIORS INC HIRIC rJyer(s) Hichael CT-I5.lI 010 19/'14) HOME IMPROVEMENT RETAIL INSTALLMENT ',CONTRACT AND SECURITY AGREEMENT Account No. I j 77. )(,'('1- SUITE 8888 GREENTREE SQ HARLTON NJ 08053 196 Willow Hill Park Rd Hechaniceburg PA 17055 "You' and 'your' means each Buyer above "We,' 'ours,' and 'us' means the Seller and any guaranlor, Jointly and severally. above, Its successors and assigns. SALE: You agree to purchase the property (and/or services) described below according to the following terms, Including those on pages 2 and 3. You agree to pay us the principal sum of twenty-one thousand,. five hundred and No/100 dollars ($ 21500.00 ) plus Interest from the disbursement date at the rate of 12.340 " per year until paid In full. You agree to pay this contract according to the payment schedule and 'ale charge prOVisions shown In the TRUTH IN LENDING DISCLOSURES, and pay any additional amounts according to the terms and conditions of this contract. DESCRIPTION OF COODS AND/OR SERVICES AND SECURITY AGREEMENT. Here Is a description of the goods and/or services you are purchasing. To secure the payment of this contract, you give us a security Interest In the goods plus all accessions, allachments, accessories and equipment, plus all proceeds arising from all of these. ~ If checked, you also agree to 91ve us a separate mortgage (or deed of trust) on the real property described below. The goods and services Installed will be located at the real property address listed below. DESCRIPTION OF GOODS/SERVICES Interior remodeling & finish in g, Windows, Roofing WARRANTIES: WARRANTY INFORMATION IS SUPPLIED TO YOU SEPARATELY. ANNUAL PERCENTAGE RATE The cost of your credit as a yearly rate. TRUTH IN LENDING DISCLOSURES AMOUNT FINANCED TOTAL OF PAYMENTS The amount of credit The amount you will have provided to you or paid when you have made on your behalf. all scheduled payments. FINANCE CHARGE The dollar amount the credit will cost you. TOTAL SALE PRICE The total cost of your purchase on credit. Including your down payment of $ 12.34 % S 25796.80 S 21500.00 Number of Pa ments Amount of Payments 180 S 262.76 s 47296.80 S 47296.80 When Payments Are Due Honth1y Beginning Apprx 30 Days from Disburemn Date "s". First payment may be slightly larger/ emaller due to a longer/ehorter paymsnt period. Your Payment Schedule will be: SecurIty: You are giving a ~ecurlty Interest In: _'brl., doserlpllon 0' olhtr prop.ny) -! the goods or property being purchased. -! the real property located at 196 Willow Hill Park Rd, Hechanicsburg PA 17055 -! Late Charge: You will be charged 5.000 " of the unpaid amount of an Installment that Is late by more than 10 days after It Is due up to a maximum of S 5.00 , but not less than $ .00 Prepayment: If you payoff this contract early, you will not have to pay a penalty. Filing fees $ You can see your contract documents for any additional Information about nonpavmont. default, any req'Jlred repayment before the scheduled date, and prepayment refunds and pellaltles. 'e" means an estimate. If you do not meet your contract obligations you may lose your house, or the property that you bought with this loan. . fl19112. 1994 tt-'n"tn h,l'!m,. II1C., 5t. (It)url. '-IN II e"" )972]411 r"rm elll n(LAZ r^ 10/111/94 (("tIft' flf 41 c;r 1\ 1901nllJ/1)41 If the property Is foreclosed upon because of your default, notlte will' be provided to you of~'e Intended sale or disposition of the property. This no. will be provided by mall (certlned or registered mall when required by law) lIddressed to you at the address listed on page 1, and will be mailed to you at least 10 days before the date of the Intended disposition (or such other period of time as 15 required by law). EXCEPTIONS. After you default, we must provide you with written ",otlce (by certified mal/) of your default and r~ht to cure sucH pefau/t. You have 30 days from receIpt 0 such notice to cure your default. We may exercise our remedIes only If you fall to cure your default wIthin the time allowed after the notIce. However, we need not provide such notice to you more than once In any /2 month period. COSTS AND ATTORNEYS' FEES. You agree to pay all Cp5ls of collectlnn, If you default, Including reasonable anorneys fees. ARBITRATION. All disputes, claims, or controversies arising from or relating to this contract or the relationships which result from this contract, or the validity of this arbitration clause or the entire contract, shall be resolved by binding arbitration by one arbitrator selected by us with consent of you. This arbitration contract Is made pursuant to a transaction In Interstate commerce, and shall be governed by the Federal Arbitration Act at 9 U.S.C. Section 1. judgment upon the award rendered may be entered In any court having Jurisdiction. The parties agree and understand that they choose arbitration Instead of litigation to resolve disputes. The parties understand that they have a right or opportunity to litigate disputes through a court, but that they prefer to resolve their disputes through arbitration, except as provided herein. THE PARTIES VOLUNTARILY AND KNOWINGLY WAIVE ANY RIGHT THEY HAVE TO A JURY TRIAL, EITHER PURSUANT TO ARBITRATION UNDER THIS CLAUSE OR PURSUANT TO A COURT ACTION BY US (AS PROVIDED HEREIN). The parties agree and understand that all disputes arising under case law, statutory law, and all other laws Including, but not limited to, all contract, tort, and property disputes, will be subject to binding arbitration In accord with this contract. The parties agree and understand that the arbitrator shall have all powers provided by the law and the contract. These powers shall Include all legal and equitable remedies, Including, but not limited to, money damages, declaratory relief, and Injunctive relief. Notwithstanding anything hereunto the contrary, we retain an option to use Judicial or non.judlclal relief to enforce a mortgage, deed of trust, or other security agreement relating to the real property secured In a transaction underlying this arbitration agreement, or to enforce the monetary obligation secured by the rea property, or to foreclose on the real property. Such Judicial relief would take the form of a lawsuit. The Institution and maintenance of an action for Judicial relief In a court to foreclose upon any collateral, to obtain a monetary judgment or to enforce the mortgage or deed of trust, shall not constitute a waiver of the right of any party to compel arbitration regarding any other dispute or remedy subject to arbitration In this contract, Including the filing of a counterclaim In a suit brought by us pursuant to this provision. OBLlCATIONS INDEPENDENT . Each buyer who signs this contract agrees Jointly and severally to pay It according to Its terms. This means that: A. You must pay this contract even If someone else has signed It; B. We may release any, co.slgner and you will stili be obligated to pay the contract; C. We may release any security and you will stili be obligated to pay the contract; D. Waiver by us of any of our rights will not affect your duty to pay this contract; and E. Extending new credit or renewing this contract will not affect your duty to pay this contract. NOTICE OF PROPOSED INSURANCE . Group credit life Insurance coverage will be applicable to this contract If so marked on page 2 of this contract and each type of coverage will be written by the Insurance company named. This Insurance, subject to acceptance by the Insurer, covers only the person signing the request for such Insurance (or each a IQlU, I'lQ4 SInh,. s.,IIfml, Inr., lil Clnul'l, M"O 8001912)41) F'olm GTII ACLAl PA 10118/94 person signing thrquest for Joint credit life Insurance). The amount of the Je 15 Indicated for each type of credit Insurance to be purchased. The term of Insurance will commence as of the date the Indebtedness Is Incurred and will expire on the originally scheduled maturity date of the Indebtedness. Subject to acceptance by the Insurer and within 30 days1 there will be delivered to you a certlncate of Insurance more fu Iy describing the Insurance. In the event of prepayment of the Indebtedness, a refund of Insurance charges will be made when due. INSURANCE. You agree to purchase Insurance on the property against such risks and In such amounts as we may reasonably require. In addition, you agree as follows: A. You will arrange for us to be named as mortgagee or benenclary under a standard loss payable clause on any such policy so that any benenu arising from the Insured risks will nrst be paid to us for application toward the secured obllg~tlons; B, You agree 'that we may, In the event of a loss, require additional security or assurances of payment of the secured obligations as a condition of permitting any Insurance benents to be used for repair or replacement of the property; C. You agree to purchase Insurance from a company authorized to do business In this state and which Is reasonably acceptable to us; D. You will maintain this Insurance until all the secured obligations are paid In full; and E. If you fall to obtain or maintain this Insurance, or you fall to arrange for us to be named as mortgagee or benenclary under a standard loss payable clause. we may (but In no event are required to) purchase such Insurance to secure only our Interest In the property. The cost of such Insurance may be added to the principal balance and shall earn Interest from that dale until paid at the rate In effect from time to time. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSF.S WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. (PIlI" Jot., r.T J'II )9 010 (9/94) .' ...... n n GREEN TREE FINANCIAL CORPORATION 332 Minnesota street St. Paul, Minnesota 55101 612-292-2589 January 13, 1997 t _I' ERIKA GRIFFIN 196 Willow Mill Park Road Mechanicsburg, Pennsylvania 17055 Re: Loan No. 15725642 ERIKA GRIFFIN 196 Willow Mill Park Road, Mechanicsburg, Pa. NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear Ms. Griffin: The mortgage held by Green Tree Financial Corporation on your property localed at 196 Willow Mill Park Road, Mechanicsburg, Pa. IS IN SERIOUS DEFAULT because you have not made the monthly payments of $262.76 for the months 8/15/96 thru 1/13/97. Late charges andlor other charges have also accrued to this date, in the amount of. The total amount now required to cure this default, or in other words, get caught up on your payments, as of the date of this letter is $1,367.40. You may cure this default within THIRTY (30) DAYS of the date of this leller by paying to us the above amount of $1 ,367.40, plus any additional monthly payrnent and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made to: GREEN TREE FINANCIAL CORPORATION 332 Minnesota Street St. Paul, Minnesota 55101 612.292. 2589 EXHIBIT I - '/ "C .- '01 (1 n; " ERIKA GRIFFIN January 13, 1997 Page Two If you do not cure the default within THIRTY (30) DAYS, 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 due immediately and you may lose the chance to payoff the original mortgage in monthly installments. ' ,(' If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorney to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff (or other similar official) to payoff the mortgage debt. if you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attorney fees actually incurred, up to $50.00. Any attorney fee s will be added to whatever you owe us, which may also include our reasonable costs. if you cure the default within the thirty day period you will not be required to pay any attorney fees. We as lender may also sue you personally for the unpaid principal balance and all other sums due under the Mortgage. If you 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 (or other similar official foreclosure sale.) You may do so by paying the total due, as well as the reasonable attorney 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 Sheriff's (or similar official) sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriff's (or similar officials sale will be sent to you before the sale. of course the amount needed to cured the default will increase the longer you wait. you may find out at any time exactly what the required payment will be by calling us at 612-292- 2589 This payment must be cash, cashier's check, certified check or money order and may payable to us at the address stated above. You should realize that a Sheriff's (or other similar official) sale will end the ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's (or other similar official) sale, a lawsuit could be started to evict you. YOU SHALL HAVE THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDINGS THE NONEXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE THAT YOU MAY HAVE TO ACCELERATION OR FORECLOSURE. . , , I .. .d' ..:.,'....,....-'000... .~....,',._. .;....".".,."".._,.-'..,.,.."lo..Il;,....!tlJl.............,I........;.;.h...;......'....L. .................._..............._.."..-.....,~...',\........'" ......1....." ",,,,,' ~."., """_' _~. . .___ _ . ,. ). c, r> , ERIKA GRIFFIN January 13, 1997 Page Three You have additional rights 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 LENDING INSTITUTION 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 THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THE 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 the default, the 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 yours, (;~L~Cr~L GREEN TREE FINANCIAL CORPORATION 612-292-2589 - . ,..- .-, -.-....4__.._..__.. --_..._-.-...:._::.:.:.::-.:,:::.-:....-._.~.:......::.;.......r.... .I I GREEN TREE FINANCIAL CORPORATION 332 Minnesota Street St. Paul, Minnesota 55101 612-292- 2589 January 13, 1997 .' ,~~. , MICHAEL GRIFFIN 196 Willow Mill Park Road Mechanicsburg, Pennsylvania 17055 Re: Loan No. 15725642 MICHAEL GRIFFIN 196 Willow Mill Park Road, Mechanicsburg, Pa. NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear Mr. Griffin: " . The mortgage held by Green Tree Financial Corporation on your property located at 196 Willow Mill Park Road, Mechanicsburg, Pa. IS IN SERIOUS DEFAULT because you have not made the monthly payments of $262.76 for the months 8/15/96 thru 1/13/97. Late charges and/or other charges have also accrued to this date, in the amount of. The total amount now required to cure this default, or in olherwords, get caught up on your payments, as of the date of this letter is $1,367.40. You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the above amount of $1 ,367.40, plus any additional monthly payment and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made to:. . '';", :".....~~...... GREEN TREE FINANCIAL CORPORATION .. 332 Minnesota Street St Paul,. Minnesota 55101 612-292- 2589 .. ~ . oM::; ..:':1 . . .... . ," '. ~.. '. ;~ , . MICHAEL GRIFFIN January 13, 1997 Page Two If YOiJ do not cure the default within THI.RTY (30) DAYS, 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 due immediately and you may lo~e.the chance to payoff the original..mortgage in monthly installments. , ~ If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorney to start a lawsuit t? foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property Will be sold by the Sheriff (or other similar official) to payoff the mortgage debt. if you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attomey fees actually incurred, up to $50.00. Any attorney fee s will be added to whatever you owe us, which may also include our reasonable costs. if you cure the default within the thirty day period you will not be required to pay any attorney fees. We as lender may also sue you personally for the unpaid prinCipal balance and all other sums due under the Mortgage. If you 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 Sheritrs (or other similar official foreclosure sale.) You may do so by paying the total due, as well as the reasonable attorney 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 Sheriffs (or similar official) sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheritrs (or similar officials sale will be sent to you before the sale. of course the amount needed to cured the default will increase the longer you wait. you may find out at any time exactly what the required payment will be by calling us at 612-292. 2589 This payment must be cash, cashier's check, certified check or rnoney order and may payable to us at the address stated above. You should realize that a Sheritrs (or other similar official) sale will end the ownership of the mortgaged property and your right to remain in it If you continue to live in the property after the Sh.E!riff's (or other similar official) sale, a lawsuit could be started to e~Ict you. ", ~:. - .~. . "';. YOU SHALL HAVE THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDINGS THE NONEXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE THAT YOU MAY HAVE TO ACCELERATION OR FORECLOSURE. . '. . f~' r . , i ~ , . ~- ' . .,"_.~w:.-...\---..._.. ""'_. ...._..._._........ .. .._.. ",.. ". ~... . " ........ ........-..-...,. ....1...._ n () Date: January 15, 1997 Re: Michael Griffin & Erika Griffin 196 Willow Mill Park Road, Mechanicsburg, Pal Loan#15725642 To: .' ERIKA GRIFFIN From: Merri R. Lane, Esquire (' You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. 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 a representative of the lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative ;s: Merri R. Lane, P.C. 400 Market Street Philadelphia, Pennsylvania 215-922-0066 The names and addresses of designated consumer credit counseling agencies are ~hown on the attached sheet. It is only necessary to schedule one face-to-face meellng. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $1,367.40. That sum includes the following: monthly payments of $262.76, monthly late Charges of $5.00, plus previous, unpaid late charges of N/A, If you have tried and are unable to resolve this problem at or after your face-to- face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and .h..___....... , r I I -' _..~'.~~~~..:,.:......._............ _._..-M..._...........~..._......\..- ...._.... ._...._.~,,_._. ",H',' . ...__.._.......,__ -..., .. .-'....-.-.. -..; ;1.._-.'.....1... "~"':"-~ nO ......~...........-!~j..;;.. 'ui.il.i. n '. , r'~ file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out the application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow other time periods set forth in !Pis letter, foreclosure may pro~eed against your home immediately. ' Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional 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 Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1 (800) 342-2397 (toll free number). Persons with impaired hearing can call 1(800) 342-2397. In addition, you may receive another notice from this lender under Act 6 of 1974. This notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania Law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. GREEN TREE FINANCIAL CORPORATION ~ BY:~~ MERRI R. LANE n o 18) WARREN. FORREST COUNTIES ECONOMIC OPPORTUNITY COUNCIL 204 Liberty Street P.O. Box 547 VVarren,PA 16365 (814) 726-2400 Forest & Warren Counties 29) YWCA OF CARLISLE 311 South West Street Carilsle, PA 17013 (717) 243-3816 Curn.beriand, Frenklln & Perry Counties ,. ,I! 30) NORTHWEST COUNSELING SERVICES 5601 North Broad Street, Suite 209 Philadelphia, PA 19141 (215) 549-2344 Philadelphia County only 22) PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 1701 Arch Street, Suite 304 Philadelphia, PA 19103 (215) 567-7803 Chester, Delaware, Montgomery & Philadelphia Counties 15) SHENANGO VALLEY URBAN LEAGUE, INC. HousIng Counseling Services 39 Chestnut Street Sharon, PA 16146 (412) 961-5310 Mercer, Crawford and Lawrence Counties 23) SOUTHWEST GERMANTOWN COMMUNITY DEVELOPMENT CORPORATION 5002 Wayne Avenue Philadelphia, PA 19144 (215) 843-2000 Philadelphia County only 18) TABOR COMMUNITY SERVICES, INC. 320 South Duke Street Lancaster, PA 17802 (717) 397-5162 Chester, Lebanon & Lancaster Counties 13) GUIDELINE Doane Center, ManSfield University Mansfield, PA 16933 1-800-332-6718 or (717) 662-4214 Bradford, Potter, Sullivan & Tioga Counties (' (~ II t.;.I~lIl.lll/oI,11 1.1'1:1/11 l.l /II111.1;llIlli IlIVllilllllllt- I'''MII Y ul:IiVII ;1=1.> l1Q Y1~:J lIillll.IJ~~1 I:Jill, I'/-, 1l<f)i1 1#14) 41;.1;4/11 1;lijllllll, 1;llmlll/'I,I:I~,I:IIU, ,JuIIUI~III1, M"'(UIIII, MUI"u!. VUII,1I1111l1l. W'"IIlIlI:lllllliuh Il) l;fJIltiIJMI:t1 Ct11:1l11 C/llllltit-llllfJ tit-INlCt-. ot- Ilr III 111t-AUI t-IlN I't:NNUYIVANIA C;1l/IIIUIl HuIlIIlIlO, 61111u 4111/HII~ 11I1I 61;/111111111, f'A lllblll ('/H) l\Il!i.1l627 Brodford, COIDon. Columblo, Lockowonno, Luzornu, Lycornlng. Monro~. Monlour, Norlhurnborlond, Plko, sullivan, Susquohanna, Tioga, Woyno & Wyoming Countlos 9) ECONOMIC OPPORTUNITY COUNCIL OF READING-BERKS COUNrf. INC. 227.229 North 4th Street Reading, PA 19601 (215) 376-6571 Berks. Cheslor, Montgomery & Schuylkill Counties 10) FAYETTE COUNTY COMMUNITY ACTION AGENCY, INC. 48 East Church Street Unlonlown, PA 15401 (412) 437-8050 or (412) 437-'!400 Fayette County only 3) CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 1031 West Linden Street Allentown, PA 19102-3903 (610) 821-4011 Berks, Bucks, Carbon, Lancaster, Lehigh, Monroe, Northampton & Schuylkill Counties m COMMISSION ON ECONOMIC OPPORTUNITY OF LUZERNE COUNTY 211.213 Soulh Main Streel Wilkes-Barre, PA 18701 (117) 826-0510 Carbon, Columbia. Luzeme, Monroe. Schuylkill & Wyoming Counties 4) CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PA.. INC. 309 Smithfield Street-Suite 2000 Pittsburgh, PA 15222 (412) 471-7584 662 North Main Street Greensburg, PA 15601 (412) 838.1290 500-02 3rd Avenue P.O. Box 278 Duncansvllle, PA (814) 696-3546 1 st Federal Plaza-Suite 406 North Mill Street New Castle, PA 16101 (412) 652-6074 Allegheny, Armstrong, Beaver, Bedford, Blair, Bull~i, C;"r,L,id, Cd,r'd"""', CdllloiJ, Cldli'JI), CI"d,r."IJ, Fayette, Franklin, Fulton, Greene, Hunllngdon, Indiana, Jefferson, Juniata, Lawrence, Mercer, Mifflin, Snyder, Somerset, Union, Venango, Washington & Wesl",r,iol,i.-.d cr,,,,,:,o,," . '. . . ,; , " . ] Merri R. Lane, P.C. I 400 Market Street Twelfth Floor Philadelphia, PA 19106 215-922-0066 Fax 215-625-2501 ,..f~ -- , ' J,tnoJM"O- ) J( 1"7-1' J . ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information, call the Pennsylvania Housing Finance Agency at 1-(800) 342-2397. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. 81 NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMADO ESTA AGENCIA [ PENNSYLVANIA HOUSING FINANCE AGENCY] SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELIGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS' EMERGENCY ASSISTANCE PROGRAM" AL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL OERECHO A REDIMIR SU HIPOTECA. J ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE ~ .., ..'.' 'YOU MAY BE ELIGIBLE FOR FINANCIAL .;" . . ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MO~TGAGE PAYMENTS '" 'i j!l '.: . , ...". .t.,: .~ , .:j Date: January 15,1997 J I Re: Michael Griffin & Erika Griffin 196 Willow Mill Park Road, Mechanicsburg, Pal Loan#15725642 To: MICHAEL GRIFFIN " From: Merri R. Lane, Esquire You may be eligible for financial assistance that wilL prellent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage pay~ents, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. 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 a representative of the lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: Merri R. Lane, P.C. 400 Market Street Philadelphia, Pennsylvania 215-922-0066 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. .,,1 \ ....,,; "I \' ....... . ~l . . ~ .1.',. ,','. ::,,;;rc:!~r mortgage is in default because you have faile~:l.to pay promptly ,installments of principal and interest, as required, for' a period of at least sixty, (60) days. The total" amount of the delinquency is $1,367.40. That sum includes the following: monthly payments' of $262.76, monthly late charges of $5.00, plus previous, unpaid late charges of N/A, If you have tried and are unable to resolve this problem at or after your face-to- face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and -, file a cornpleted Homeowners' Emergency Assistance Application ~~ith one of the designated consumer credit counseling agencies listed on the' attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out the application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not fol/ow other time periods set forth in th~s letter, foreclosure may proceed against your home immediately. {F . . Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. , . It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional 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 Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1 (800) 342-2397 (toll free number). Persons with impaired hearing can call 1(800) 342-2397. In addition, you may receive another notice from this lender under Act 6 of 1974. This notice is called a "Notice of Intention to Foreclose". You must read both notices , since they both explain rights that you now have under Pennsylvania Law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. GREEN TREE FINANCIAL CORPORAT~y~~ L- MERRI R. LANE ". .~ .\ .,; .1 , . . ,. . .I I PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAMS CONSUMER CREDIT COUNSELING AGENCIES 1) ACTION HOUSING, INC. Number Two Gateway Center 9th Floor Pittsburgh, PA 15222 (412) 391-1956 Allegheny, Beaver, Buller, Fayette, Greene, Washington & Westmorel~n.~Countles 27) AMERICAN RED CROSS. HANOVER CHAPTER 529 Carilsle Street Hanover, PA 17331 (717) 637-3768 Adams, Franklin & Yori< Counties 5) BUCKS COUNTY HOUSING GROUP, INC. 140 East Richardson Avenue Langhome, PA 19047 (215) 750-4310 Bucks County only 2) CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1211 Chestnut Street - Suite 411 Philadelphia, PA 19107 (215) 563-5665 Bucks, Chester, Delaware, Montgomery & Philadelphia Counties 24) URBAN LEAGUE OF METROPOLITAN HARRISBURG 28 North 2nd Street Harrisburg, PA 17101 (717) 234-5925 .j Cumberiand, Dauphin and Perry Counties 17) URBAN LEAGUE OF PHILADELPHIA Urban Education Foundation 4601 Mari<et StreeU 2nd Floor, South WIng Philadelphia, PA 19139 (215) 476-4040 , Philadelphia C<lunly only ....... . ~-...... .- 25) URBAN LeAGUE OF PITTSBURGH, INC. Building for Equal Opportunity 200 Ross Street Pittsburgh, PA 15219 (412) 261-1130 ,. II .: '"! Allegheny County only . .. 21) JOHN F. KENNEDY CENTER,INC. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 Crawford & Erie Counties 14) L YCOMING.CLlNTON COUNTIES COMMISSION FOR COMMUNITY ACTION (STEP) 1221 West 3rd Street, P.O. Box 1328 W1l1lamsport, PA 17703 (717) 326-0567 Clinton & Lycomlng Counties " J.,'u' , " 26) MON.VALLEY UNEMPLOYED COMMITTEE 116 Fifth Street McKeesport, PA 15132 (412) 678-1409 Allegheny, Beaver, Butler, Fayette, Greene, Washington & Westmoreland Counties 28) NEIGHBORHOOD DEVELOPMENT ALLIANCE 5935 Ogontz Avenue PhiladelphIa, PA 19141 (215) 424-1111 Bucks, Chester, Delaware, Montgomery & Philadelphia Counties 31) INDIANA COUNTY COMMUNITY ACTION PROGRAM Box 187 Indiana, PA 15701 (412) 485-2657 Armstrong, Cambria, Clearfleld, Indiana, Jefferson & Westmoreland Counties 12) HOUSING COUNCIL OF YORK 116 North George Street Yorl<, PA 17401 (717) 854-1541 Vorl< county 19) HOUSING ASSOCIATION OF DELAWARE VALLEY 1314 Chestnut Street, Suite 900 Philadelphia, PA 19107 (215) 545-6010 658 North Watts Street PhiladelphIa, PA 19123 P'(215) 97s.:o224 ; 20) HOUSING OPPORTUNITIES, INC. 133 Seventh Street, P.O. Box 9 McKeesport, PA 15132 (412) 664-1590 .. .' i Allegheny, Beaver, Butler, Washington & Westmoreland Counties ~ . .. . 18) WARREN. FORREST COUNTIES ECONOMIC OPPORTUNITY COUNCIL 204 Liberty Street . P.O. Box 547 Warren, PA 16365 (814) 726-2400 Forest & Warren Counties 29) YWCA OF CARLISLE 311 South West Street Carilsle, PA 17013 (717) 243-3818 Cumberiand, Franklin & Perry Counties 30) NORTHWEST COUNSELING SERVICES 5601 North Broad Street, Suite 209 Philadelphia, PA 19141 (215) 549-2344 ".f; . -, Philadelphia County only 22) PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 1701 Arch Street, Suite 304 Philadelphia, PA 19103 (215) 567-7803 Chester, Delaware, Montgomery & PhiladelphIa Counties 15) SHENANGO VALLEY URBAN LEAGUE, INC. Housing Counseling Services 39 Chestnut Street Sharon, PA 16146 (412) 961-5310 Mercer, Crawford and I_awrence Counties 23) SOUTHWEST GERMANTOWN COMMUNITY DEVELOPMENT CORPORATION 5002 Wayne Avenue Philadelphia, PA 19144 (215) 843-2000 Philadelphia County only 16) TABOR COMMUNITY SERVICES, INC. 320 South Duke Street Lancaster, PA 17602 (717) 397-5182 Chester, L~banon & Lancaster counties 13) GUIDELINE Doane Center, Mansfield University Mansfield, PA 16933 1-S00-332-6718 or (717) 662-4214 Bradford, Potter, Sullivan & Tioga Counties " 'k p '. ~.:.:... .... .' . '-' 7) CONSUMER CREDIT COUNSELING [)IVISION OF FAMILY SERVICES 1 to Wtlst lOlh Street Erie. PA t6501 (814) 454-6476 Clarion, Crawford, Elk, Erie, Jefferson, McKean, Mercer, Venango & Warren Counlles 8) CONSUMER CREDIT COUNSELING SERVICE OF NORTHEASTERN PENNSYLVANIA Connell Building, Suite 401/Box 168 Scranton, PA 18501 (717) 855-9527 Bradford, Carbon, Columbia, Lackawanna, Luzeme, Lycomlng, Monroe, ~ontour, Northumberland, Pike, Sulllv.~~, susquehanna, TIoga, Wayne & WyomIng Counlles ' .. .f' 9) ECONOMIC OPPORTUNITY COUNCIL OF READING-BERKS COUNW.INC. 227.229 North 4th Street Reading, PA 19601 (215) 376-6571 BerkS. Chester, Montgomery & Schuylkill Counties 10) FAYETTE COUNTY COMMUNITY ACTION AGENCY, INC. 48 East Church Street Unlontown, PA 15401 (412) 437-6050 or (412) 437-4400 Fayette County only 3) CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALlEY 1031 West Unden Street Allentown, PA 19102-3903 (810) 821-4011 Berks, Bucks, Carbon, Lancaster, Lehigh, Monroe, Northampton & Schuylkill Counties 8, COMMISSION ON ECONOMIC OPPORTUNITY OF LUZERNE COUNTY 211-213 South Main Street WIlkes-Barre, PA 18701 (717) 826-0510 Carbon, Columbia, Luzeme. Monroe, Schuylkill & Wyoming Counties 4) CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PA., INC. 309 Smithfield Street-Suite 2000 Pittsburgh, PA 15222 (412) 471-7584 662 North Main street Greensburg, PA 15601 (412) 838-1290 500-02 3rd Avenue P.O. Box 276 Duncansville, PA (814) 696-3546 1st Federal Plaza-Sulte 406 North Mill Street New Castle. PA 16101 (412) 652-8074 Allegheny, Armstrong, Beaver, Bedford, BlaIr, Butl,;r, Cambria, Ca,)),;r(JI), C,;ntr,;, Clari(JI), CI,;arr,,,ld, Fayette, Franklin, Fullon, Greene, Huntingdon, Indiana, Jefferson, Juniata, Lawrence, Mercer, Mifflin, Snyder, Somerset, Union, Venango, Washington & Westmuiciund CuunUcs.