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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACfION - LAW
No. 1'.7- - .~ Jj zJ
(P.~
ADAMS COUNTY NATIONAL DANK.
Plaintiff.
v.
AClion In Morlgage
Foreclosure
" I!.I.I!ROY DI!PUTY. JR.. aka I!ARJ.. L. DI!PUTY,
JR. and ROXANNI! II. DI!PUTY. his wife,
and ADAM L. DRlJAM and CYNTIIIA C.
DRlJAM, his wife.
Defendants.
To - E. LEROY DEPUTY. JR... aka EARL L DEPUTY. JR. and ROXANNE H. DEPUTY.
his wife, and ADAM L BREAM and CYNTHIA C. BREAM. his wife. Defendants:
NOTICE
You have beeo sued In courl. If you wish to dcfend against the claims set forth in Ihe following pages,
you must lake action within lwenly (20) days after this complaint and nOlice are served. by entering a wrillcn
appearance personally or by allorncy, and filing in writing with the court your defcnscs or objeclions to thc claims
set forth againsl you. You arc warned lhat if you fail to do so. the case may proceed without you and a judgmcnt
may be entered againsl you by the courl without further notice for any money claimed In the complaint nr for any
olher e1alm or relief requcsted by the Plaintiff. You may lose money or property or other rights impOrlantlo you.
YOU SHOUW TAKE THIS PAPER TO YOUR U.WYER AT ONCE. IF YOU DO NOT HAVE A
U. WYER. OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE Sf.7' FORTH BELOW 7'0
FIND OUT WHERE YOU CAN Gf.'T LEGAL HEll'.
Court Administrator
Cumberland County COUrlhouse
Fourth Floor
Carlisle, PA 17013
Telephone Number: 717-240-6200
A VISO
USTED HA SIDO DEMANDADO EN U. CORTE. 5i uSled desea defendersce de las quejas expueslas en
las p4glnas slguienlcs, debe tomar accl6n dentro de velnle (20) dlas a partir de la fccha en que rccibi61a demanda
yel aviso. Usled debe prcsentar comparccencla escrita en persona 0 por abogado y presentar en la Corte pnr
cscrito sus dcfensas 0 sus objccloncs a las demandas en su eontra.
,!
5e Ie avisa que si no se deliende. el caso puede procedcr sin usted y la Cone puede dccidir en su eonlra
sin mas aviso 0 notllicaci6n por cualquicr dinero rcelamadn en la demanda 0 por cualquier Olra queja 0
compensaci6n rcclamados por el Dcmandante. USTED PUEDE PERDER DINHRO. 0 PROPIEDADES U
OTROS DERECHOS IMPORTANl'ES PARA U!J'TED.
UEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMEN/'E. SI U.\TED NO TlENE 0 NO
CONOCE UN ABOGADO. VAYA 0 UAMEA U. OFICINA EN U. D1RECCION ESCRTfA ABAJO PARA
A VERIGUAR DONDE PUEDE OBTENf.'R ASISTENCIA I.EGAL
Court Admlnistralor
Cumberland County Courthouse
Fourth Floor
Carlisle. PA 17013
Telephone Numbcr: 717.240.6200
"
.
.,
"
I
'! 4. Defendants are not in the military or naval service of the United States or its allies
'i within the provisions of the Soldiers' and Sailors' Civil Relicf Act of the Congress of 1940
!
and il~ amendmenl~.
5. On January 27, 1995, the Defendants executed and delivered a mortgage upon real
estate hereinafter described to Plaintiff a.~ Mortgagcc, which mortgage is recorded in thc
oflice of the Recorder of Dccds of Cumberland County, Pennsylvania, in Mortgagc Book
:1
1251 at pagc 26, a copy of said mortgagc bcing attached hcrcto and marked Exhibit A.
6. Said mortgage has not been assigned.
7. The description of the real estate is as describcd as follows:
ALL that certain tract of land with the improvements thereon crectcd situate in South
Middleton Township, Cumberland County, Pennsylvania, bounded and described in
accordancc with a survcy prcpared by Eugcne A. Hockensmith, R.S.. datcd October 20, 1983,
a.~ follows:
BEGINNING at a nail and cap set in the centerlinc of PA Routc 94 at corner of lands
of Charlcs G. Mycrs; thencc along thc ccnterlinc of PA Routc 94, South 13 degrecs 12
minutes 57 seconds East 864.73 fectto a nail and cap in the centerline of PA Routc 94 at
lands of Keith R. Tuckcy; thcncc along lands of Kcith R. Tuckey, North 54 degrecs 44
minutes 05 seconds Wcst 574.35 feet to an iron pin in Chcstnut stump and along Whitc Rock;
thence still along lands of Kcith R. Tuckcy, North 19 degrees 30 minutes ()() seconds West
194.35 fect to an iron pipe; thencc along lands of Charles G. Mycrs, North 45 dcgrccs 47
minutes 12 seconds East 468.96 fcct through an iron pin set on the line to a nail and cap in thc
centerline ofPA Route 94, the placc of BEGINNING. CONTAINING 4.7293 acrcs and being
improved with a two story framc and aluminum siding house. framc barn and other
outbuildings.
BEING the samc which Kenneth M. Bream, Exccutor of the last will and tcstamcnt of
Adam E. Brcam. by dccd dated June I, 1984, and recorded in thc officc ofthc Rccorder of
Dccds of Cumberland County, Pennsylvania, in Dccd Book S, Volumc 30. at pagc 156,
grantcd and convcycd unto Earl L. Dcputy, Jr. and Roxannc H. Dcputy. his wifc, two of thc
Defendants hcrein.
TRACT NO. I: ALL that certain tract of land situatc in South Middleton Township,
Cumberland County, Pennsylvania, boundcd and dcscribed as follows:
BEGiNNING at a point in the ccntcr linc of Pcnnsylvania Statc Highway Routc No.
94, said road leading from Carlisle to Hanovcr, which point is thc corncr of land of Gary
2
Prosscr; thcncc along land of Gary Prosser, North 37 dcgrccs 10 minutes. a distancc of 253
fcctto a point (iron pin> in Iinc of land of Adam E. Bream; thence along land of Adam E.
Brcam, South 21 degrees East, a distancc of 150 feet to a point (iron pin> in Iinc of said Adam
E. Brcam; thencc along line of land of said Adam E. Bream. South 41 3/4 degrecs Wcst. a
distance of 276 fcctto a point in the centcr of said Pennsylvania Statc Highway Routc No. 94,
North 9 1/4 dcgrecs Wcst. a distancc of 147 fcetto a point and placc of BEGINNING.
BEING improvcd with a dwelling housc. CONTAlNING.7 acre, morc or less, according to
survey of Thomas O. Bietsch. Registcred Survcyor. datcd May, 1966.
BEING thc samc which Adam E. Bream and Helcn M. Brcam. husband and wifc, by
dced dated June 13, 19'66, and recorded in thc officc of thc Rccordcr of Deeds of Cumbcrland
County, Pennsylvania, in Dced Book "Z," Volume 21, at pagc 870, granted and conveycd
unto Adam L. Brcam and Cynthia C. Bream, husband and wifc, two of the DcfendanL~ hcrein.
TRACT NO.2: ALL that certain tract of land situatc in South Middlcton Township.
Cumbcrland County, Pcnnsylvania, boundcd and dcscribed as follows:
BEGINNING at a point in the center of a public road (Carlislc-Hanovcr Turnpike),
known as State Highway Routc No. 94, at lands of Alonzo A. Hcberlig; thcncc along lands of
the said Alonzo A. Heberlig. North 31 degrecs 25 minutes East, a distancc of 764 fcct 4
inches, more or less, to a point, (iron pin>; thence along othcr land of Adam F. Brcam. South
24 degrecs East a distance of 1140 feet, more or less, to a point (iron pin>; thencc along thc
center of a public road known as thc "Old Town Road", South 48 1h degrccs West, 230 feet,
more or less, to a point in Iinc of land of Russcll Brcam; thcncc along land of the said RusscH
Bream. North 19 degrees Wcst, a distancc of 671 fcct. more or less, to a point, (iron pin>;
thence along lands of thc said RusscH Bream. South 31 degrecs Wcst. 557 fcct, morc or less.
to a point in the ccnter of Statc Highway Route No. 94; thencc along thc ccntcr of said Statc
Highway Routc No. 94, North 9 3/4 degrces Wcst, a distancc of 304.5 fcct. more or Icss, to a
point, thc placc of BEGINNING.
LESS, HOWEVER, all thosc certain tracts or pareels of land which wcre conveycd by
Adam E. Bream and Hclen M. Bream, his wifc, as foHows:
1. To Theodore S, Fahnestock, by deed dated June I, 1964, and rccorded in the
Officc of the Recorder of Deeds of Cumberland County in Decd Book "F." Volumc 21, Pagc
631, containing 5.77 acres, rnore orIess;
2. To Gary Prosscr, by decd datcd September 9, 1964, and recorded in thc Officc of
the Recorder of Deeds of Cumberland County in Decd Book "I," Volumc 21, Pagc 757,
containing 0.4 acrc, more or less;
3. To Gary Prosser, by deed datcd June 13. 1966. and recorded in thc Officc of the
Rccordcr of Deeds ofCumbcrland County in Dccd Book "Z." Volumc 21, Pagc 867;
3
4. To Adam L. Brcam and Cynthia C. Brcam, by decd datcd Junc 13, 1966, and
recorded in the Officc of the Recordcr of Deeds of Cumbcrland County in Dccd Book "Z."
Volumc 21. Pagc 870.
BEING thc samc which Adam E. Brcam, widower. by dced daled Dccembcr 22. 19HO,
and recordcd in the office of lhe Rccorder of Deeds of Cumberland County, Pennsylvania, in
Deed Book "G," Volume 29, at pagc 250, grantcd and conveycd unto Adam L. Bream and
Cynthia C. Bream, his wifc, two of the DcfendanL~ hercln.
8. Thc said mortgage is in default in thatthc monthly paymenl of principal and
interesl amounling to $2.349.26. which has becomc due and payable on December 1, 1996,
and the monlhly paymenls of principal and interest amounling to $2,376.26 each. which have
become duc and payable on January I, 1997, and on thc 1st day of cvery month thereaftcr
have not bccn made, and by thc tenns of said mortgage upon default in such monlhly
paymenL~ for a spacc of 5 days after any such paymcnt is duc. thc whole of the said mortgagc
debt and interest shall, althe option of the Plaintiff, bccome due and payable forthwith.
9. Thc present owners of the real estate arc the DefendanL~ herein.
10. The amount due the mortgagee on the rnortgage is computed as follows:
(a) Balancc of principal $39.665.32
(b) Intcrest from November 2,
1996. to May 8,1997 1,815.94
(c) Attorney's commissions 2.074.06
TOTAL $43,555.32
II. In accordance with provisions of Act 91 of 1983 and Act6 of 1974, Plaintiff has
sent to Defendanls Notices of Homcowners' Emergency Mortgage Assistance and Notices of
Intention to Foreclose prior to the commcncement of the within proceedings. Copies of said
Notices and mailing reccipL~ arc auached hereto and marked ExhibiL~ B through I,
respectively.
4
,
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~&L1L\
THIS
"2(",.; f"'I
COLLATERAL MORTGAGE mado this ~ day of
LEROY DEPUTY , JR. AlKI A EARl. I.. DEI'UTY JR. & ROXANN. I .
COLLATERAL MORTGAGE
between E.
ADAM L. BREAM & CYNTIIIA C. BREAM 1115 WI FE
who reside at 828 BAI,TlMORE PIKE; AND 811 BALTIMORE PIKE, GARDNERS,
Mortgagor, and ADAMS COUNTY NATIONAL BANK, with an office at Gettysburg,
Pennsylvania, Mortgagee.
WITNESSETH, that the Mortgagor and the Mortgagee have this date en to red
into a written agreement whereby the Mortgagee is obligated to make future
advances to the Mortgagor not to exceed in the aggregate the sum of '7S.DOO.OO
(hereinafter referred to as the Debt!, and as ovidence of said indebtedness, the
MortgAgor will, at the time each advance 1s made, execute and deliver to the
MortgAgee a note for the amount so advanced, and as security for the paymont of
all of the notes so given by the Mortgagor to the Mortgagee, tho terms,
covenants and conditions of which are incorporated herein by reference, and in
consideration of One Dollar paid to the Mortgagor by tho Mortgagee, the
MortgAgor docs hereby grant, bargain, sell, release, convey and confirm unto
Mortgagee, ALL THAT REAL ESTATE with the improvements located thereon situate in
SOUTH MIDDLETON TOWNSIIlP , County of CUMBERLAND
Township or Borough EXIIlBIT A
Pennsylvania, identified as 828 BALTIMORE PIKE IN DEED BOOK S, YOLo lO, PAGE 156
EXHIBIT B
877 BALTIMORE PIKE IN DEED BOOK G, YOl.. 29, PAGE 250 & DEED BOOK Z, YOLo 21, PAGE 870
and more particularly described in the deedls) to one or more of the Mortgagor
recorded in the Office of the Recorder of Deeds of said County in Deed Book____,
Page _____ IInsert additional Deed Books and Pages, if applicable!
The descriptions contained in such deed (s! are by this refeL.,ce thereto
incorporated herein and made a part hereof.
TOGETHER with all buildings, improvements, righ~s of w~y, rights and
privileges, hereditaments and appurtenances, and the reversions, remainders,
rents, issues and profits thereof.
MORTGAGOR COVENANTS AND AGREES THAT.
1. Mortgagor will make all payments on the respective due dates thereof
and perform all other obligations as required or provided herein and in said
notes.
2. Mortgagor will keep the buildings on said real estate insured aqainst
loss by fire or other casualty for benefit of Mortgagee in amounts satisfactory
to Mortgagee with standard mortgagee clause. and Mortgagor will pay all taxes
and asqessments levied or asacsDcd Against said real estate or any part thereof
when they respectively become due, and will deliver rec~ipts therefor to the
Mortgagee upon request. MortgAgor will pay all taxes and/or charges in the
nature thereof, together with any interest or penalty thereon which may be or
become owing by the Mortgagor to Pennsylvania or any other state, the federal
government or any political subdivision of any theroof, when they respectively
become due.
3. If the Mortgagor fails to maintain such insurance coverage or fails to
pay any of the taxes and/or charges in the nature thereof or assessments
hereinbefore mentioned, then Mortgagee shall have the option of paying the same
or any thereof, and upon any such payment by the Mortgagee, the amount thereof
shall automatically be added to and become a part of the Debt and shall bear
interest at the rate provided for in each of the aforesaid notes from the time
the same is so added to the Debt.
4. If Mortgagor fails to make any payment required by any of said notes
when the same shall fall due or fails to pay any taxes and/or charges in the
nature thereof or assessments on or before the due date thereof or Cails to
prOVide insurance coverage as provided above or fails t9 comp)y with. all of the
covenants contained in this Collateral Mortgage, then and in ~ny of said events,
the Debt and all sums added thereto, together with interest to date at the rate
provided for in said note and together also with 10\ attorneys' commissions on
said Debt and interest, shall become due and payable, at the option oC the
Mortgagee, and such remedy or remedies as the law may now or hcrcaCtr.r provide
may forthwith be invoked and prosecuted by the Mortgagee against the Mortgagor,
including, but not limited to, an act ton of mortgage foreclosure.
tOQ~ t::!51 1m 26
EXlIlIIlT ^
'mAar NO.1: ALL that cer'ta1n tract of land situate in South Middleton 'lbwnship, CUrrberland
County, Pennsylvania, bounded and described as follows:
BEGUn/IlIG at n point in the center line of Pemsylvan.ln State Ilighway Route No. 94, said
road lead1ng fran carlisle to Hanover, which point is the comer of land of Gary Prosser;
thence alcng land of Gary Prosser, North 37 degrees 10 minutes, a distance of 253 feet to a
point (ircn pin) in llne of land of Adam E, Bream; thence along land of Adam E. Bream, South
21 degrees East, a d1stance of 150 feet to a point (iron pin) in line of said Adam E. Bream;
. thence along llne of land of said Adam E, Bream, South 41 3/4 degrees West, a distance of
276 feet to a point in the center of said Pemsylvan.la State Ilighway Route No. 94, North
9 1/4 degrees West, a d1stance of 147 feet to a point and Place of BEGINNING; BEING inproved
with a dwelling house.
CmTAINING .7 acre, I1Pre or less, according to survey of'lhanas O. Bietsch, Registered
Surveyor, dated May 1966.
AND BElNG the sane prqJerty which Adam E. Bream and Helen M. Bream, his wife, granted
and conveyed to Adam L, Bream and Cynthia C. Bream, his wife, Mortgagors herein, by deed datet
June 13, 1966 and recorded in the Office of the Recorder of D:!eels for Cunberland County in
D:!ed Book "Z", Volume 21, Page 870.
'lRAal' NO.2: AIL that certain tract of land situate in South Middleton Township, CUnberland
County, Pennsylvania, bounded and described as follows:
BEGlNNINO at a point in the center of a publlc road (Carlisle-Hanover 'l\1mpike), known
as State Higl1<lay Route No, 94, at lanels of Alcnzo A. Heberllg; thence along lanels of the said
Alonzo A, Heberllg, North 31 degrees 25 minutes East, a distance of 764 feet 4 inches, rwre OJ
less, to a point, (ircn pin); thence along other land of Adam F. Bream, South 24 degrees East
a distance of 1140 feet, I1Pre or less, to a point (iral pin); thence alcng the center of a
publlc road known as the "Old Town Road", South 48 1/2 degrees West, 230 feet, I1Pre or less,
to a point in llne of land of ~sellBream; thence along land of the said ~se11 Bream. Nort)
19 degrees West, a distance of 671 feet. rwre or less, to a point, (iron pin); thence along
lanels of the said ~se11 Bream, South 31 degrees West, 557 feet, I1Pre or less. to a point in
the center of State Hil!t1wa.Y Ibute No. 94; thence alcng the center of said State llil!t1way Route
No. 94, North 9 3/4 degrees West, a distance of 304.5 feet, I1Pre or less, to a point, the
Place of BEGINNING.
IESS, HGIEVER, all those certain tracts or. parce 15 of land which were conveyed by Adam
E. Bream and Helen M. Bream, his wife, as follows:
1. 'lb 'lheoclore S. Fahnestock, by deed dated June 1, 1964 and recorded in Office of
Recorder of [);!eels for CUrrberland County in D:!ed Book "F", Volume 21, Page 631, ccnta1n1ng
5.71 acres, I1Pre or less;
2. 'lb Gary Pros~er, by deed dated Septerrber 9, 1964 and recorued in Office aforesaid
in D:!ed Book "I", Volume 21, Page 757, ccnta1ning 0.4 acre, rwre or less;
3. 'lb Gary Prosser by deed dated June 13, 1966 in Office aforesaid in D:!ed Book "Z".
Volume 21, Page 867; and
4. 'lb Adam L, Bream and Cynthia C. Bream by deed dated June 13, 1966 and recorded in
Office aforesaid in [);!ed Book "Z", Volume 21, Page 870.
BEING th~ same property which Adam E. Bream. wodower, granted and conveyed to Adam
L. Bream and Cynthia C. Bream, his wife, Mortgagor herein, by deed dated December 22, 1980
and recorded in the Office aforesaid in Deed Book "G" Volume 29, Page 250.
EXHIBIT B
~OOK 1251 PACE 29
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonweahh of Pennsylv3llia's Homeowner's Emergency Mortgage Assisl3llce Progl"3lllll13Y be able 10 help you. Read
the following notice to find out how the progr:un work.!.
If you need more Infonna1ion c3llthe PennsylY3llia Housing Fin3llce Agency at 1-800.342-2397.
La notlficacion en adjunto es de suma Import3llcla, pues :uecla su derecho a conlinual ylviendo en su casa. Si no comprende
el conlenldo de esla nOlilic3Cion oblenga una traduccion immediatamenle lIamanda esla agencia (Pennsylv:tnla Housing Finance
Agency) sin cargos 31 numero menclonado arriba. Puedes ser elegible para un prcslamo por el programa lIamado "Homeowner's
Emergency Mortgage Assist3llce Progl"3lll" el cual puede s3!Y3l" su casa de la penllda del derecbo a redlmir su blpolcca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELlGmLE FOR FINANCIAL ASSISI'ANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE rorURE MORTGAGE PAYMENTS
TO:
E. Lerov Deputy
Dale:
February 18. 1997
FROM:
Adams County National Bank
Re: Account No: 612210802671
You may be eligible for linancIal asslslance tbat will prevent foreclosure on your mortgage If you comply with the
provisIons of tbe Homeowners' Emergency Mot1gage Assistance Act of 1983 (tbe "Act"). You may be eUglble for emergency
temporary assistance If your default bas been caused by cln:umstances beyond your control, you have a reasonable prospect
of resuming your mot1gage payments, and If you meet otber eligibility requirements establlsbed by tbe Pennsylvania Housing
Finance Agency. Please read all of tbis Notice. It contains an explanation of your rlgbts.
Under the Act, you are entitled 10 a lemporary Slay of foreclosure on your mortgage for thlny (30) days from the dale of this
Notice. During that time you must arrange 3Ild allend a "f3Ce-lo-face" meeting with a representaliYe of this lender, or with a
deslgoaled consumer credit counseling agency, The purpose of this meeting Is to alIempt to work out a repaymenl plan, or to
otherwise settle your delinquency. This meeting must occur In the next (30) days.
If you alIend a face-lo-face meeting with this lender, or with a coOSUlDCr credit counseling agency identified In this notice. no
funher proceeding In mortgage foreclosure may take place for tbi.rty (30) days after the date of this meeting. The name, address and
telepbone number of our representative Is:
Ronald L. Hoffman. Vice President
Adams County National Bank
York Sprtngs. PA 17372
Telepbone Number: (7 17) 528- 1604
The names and addresses of designaled consumer credit counseling agencies arc sbown on thc anacbed sheet. It Is only ncccswy
10 scbedule onc f3Ce.to-f3Cc meeting. You should adyise this lender immcdialely of your intentions.
Your mortgage is in default because you baye failed to pay promptly iostallmenlS of principal 3Ild Inlerest, as required, for a
period of atlcast sixty (60) days. The 10131 amount of the delinquency Is S 7. 10 1 . 78 . ThaI sum Inc10dcs
the following:
A partial payment of $2.349.26 due for December 1996 and the monthly payments
of $2.376.26 due for January and February 1997
Your mortgage Is also in default for the following reasons:
(use this paragrapb only if applicable)
EXHIBIT 11
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonweallll of Pennsylyania's HomeowDer's EmergeDcy Mongage Assislance Program may be able to help you. Read
lIle following notice to lind out how lIle program works.
/( you need more infolmallon call the Pennsylvania Housing Finance Agency at 1.800-342-2397.
La nOlllicacion en adjuOlo es de suma Imponancla, pues al'ctta su derctho a conlinuar vlYiendo en su casa. Si no comprende
el conlenido de esta nOlilicacion oblenga una traduccion immedialamenle lIamanda esla agenda (Pennsylyania Housing Finance
Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prcstamo por el programa Uamado "Homeowner's
Emergency Mongage Asslslance Program" el cual puede salyar su casa de la perdida del derctho a redlmlr su hipotec.a.
ACT 91 NOTICE
IMPORTANT; NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISfANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELlGmLE FOR FINANCIAL ASSISfANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
TO:
Roxanne H. Deputy
Date:
February 18. 1997
FROM:
Adams County National Bank
Re: ACCOUDl No: 612210802671
You may he eligible for nnanclal assistance that will prevent foreclosure on your mortgage Il you comply with the
provisions of the HomeolfDers' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency
temporary assistance Il your default bas been caused by circumstances beyond your control, you have a reasonable prospect
of resumIng your mortgage payments, and if you meet other e1lgiblUly requirements established by the Pennsylvania Honslng
FInance Agency. Please read all of tbls Notice. It contains an explanation of your rights,
UDder the Act, you are eOlilled to a tempor:uy stay of forctlosure on your mongage for thirty (30) days from the dale of this
NOlice. During thai time you must arrange and alteod a "face.to.face" meeting with a rcprcsenlaliye of this lender, or with a
designaled consumer credit counseling ageocy. The purpose of this meeting is to altempt to work out a repayment plan, or to
otherwise settle your delinquency. This meeting must occur in the next (30) days.
/( you altend a face.to-face meeting with this lender, or with a consumer credit coUIUCling agency identified in this notice, no
funher proceeding in mongage foreclosure may take place for thirty (30) days after the dale of this meeting. The name, address and
telephone number of our reprcsentatiye is:
Ronald L. Hoffman. Vice President
Adams County National Bank
York SprIngs. PA Inll
Telephone Number: (7 In n8- 1604
The names and addresses of designaled consumer credit counseling agencies arc shown 00 the altacl1ed sheet. It Is only ncceswy
10 schedule one face'lo-face meeting. You should adyise this lender lmmedialely of your intentions.
Your mongage is in default because you haye failed 10 pay promptly installments of principal and interest, as required, for a
period of atlenst sixty (60) days, The 10131 amount of the delinquency is S 7. 10 1 . 78 . Thai sum includes
the following:
A partial payment of $2.349.26 due for December 1996 and the monthly payments
of $2.376.26 due for January and February 1997
Your mongage is 31so in default for the following reasons:
(use this paragraph only if applicable)
1;XlflU IT D
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonwealth of Pennsylvania's HomeowDer's Emergency Mongage Assislance Program may be able to help you. Read
the following notice to fiDd out how the program works.
If you need more informalion call the PennsylYania Housing Finance Agency at 1.800.342.2397.
La notifieacion en adjunto es de suma imponancia, pues afecta su derecho a conlinuar yivleodo en su casa. 51 no comprende
el conteoido de em notilicaclon obtenga una traduccion immediatameote Ilamanda esta agencia (PennsylYania Housing Finance
Agency) sin cargos al numero mencionado arriba. Puedes ser elegible pm un prestamo por el programa lIamado "Homeowner's
Emergency Mongage Assistance Program" el cual puede salyar su casa de la perdida del derecho a redimir su hlpoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISfANCE PROGRAM
PLEASE READ TInS NOTICE.
YOU MAY BE ELlGmLE FOR FINANCIAL ASSISfANCE WIDCH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
TO:
Adam L. Bream
Date:
February 18, 1997
FROM:
Adams County National Bank
Re: Account No: 612210802671
You may be eligible for Onancial assistance tbat will preyent foreclosure on your mortgage If you comply wltb the
provisions of tbe Homeowners' Emergency Mortgage Assistance Act of 1983 (tbe "Act"). You may be eUglble for emergency
temporary assistance If your default bas been caused by circumstances beyond your control, you bave a reasonable prospect
of resuming your mortgage payments, and If you meet otber ellglblllty requirements esIlIbllsbed by tbe Pennsylvania Housing
Flnsnce Agency. Please read all of tbls Notice. It contains an explanallon of your rlgbts.
Under the Act, you are entitled to a temporary stay of foreclosure on your mongage for thiny (30) days from the date of Ibis
NOlice. During thaI time you must arrange and attend a "face.to.face" meeting wilh a represeDtatiye of this leDder, or with a
designated consumer credit counseling ageDcy. The purpose of tbis meeting Is to attempt to worle out a repayment plan, or to
otherwise setlle your delinquency. This meeting must occur in the next (30) days.
If you alleod a face-to.face meeting with this lender, or with a consumer credit counseling agency identilied in this notice, no
funher proceeding in mongage foreclosure may take place for thiny (30) days after the dale of this meeting. The name. address and
telepbone number of our representatiye is:
Ronald L. Hoffman, Vice President
Adams County Natlonal Bank
'fork Spnngs. PA 17372
Telephone Number: (717l 528- 1604
The names and addresses of designated consumer credit counseling agencies are sbown on the Bitacbed sheet. It is only necessary
to schedule one face.to.face meeting. You sbould adyise this lender immediBiely of your intentions.
Your mongage is in default because you baye 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 S 7. 10 I . 78 . That sum includes
the following:
A partial payment of 52.349.26 due for December 1996 and the monthly payments
of 52.376.26 due for January and February 1997
Your mortgage is also in default for the following reasons:
(use this paragrapb only if applicable)
(,XIIIIlIT F
.2.
If you have tried am arc unable to rCJolve this problem at or after your face.to-face meeting, you haye lhe right 10 apply for financial
assistux:e from !be H~ownen' Emergency Mortgage AssislaDCe Fund. In order to do this, you must fill OUl, sign llIIlI file a completed
HolllCOWllm' Emergency Assistux:e Application wilh one of Ihe dCJlgnated consumer credit counseling ageoclCJ Usted on the attachment
An appllca1iOl1 fur assistux:e may only be obttincd from a consumer credll counseling agency. The consumer credit counseling ageocy will
assist you in filling out your application llIIlI will submit your compleled application to the Pennsylvania HOlUing Finance Agency . Your
application must be filed or postmarked, within thirty (30) days of your face-to-Cace meeting.
Ills o:trentdy Imporranz tho1 you Jlk your application promptly. /fyou do nol do so, or if you do nol follow 1M olMr Ii~ periods Set
forth In IhIs /mer, foreclosure may proceed againsl your ho~ l=dJarely.
Availahle rums Cor cmergency mortgage assistux:e arc very limited. They will be disbursed by lhe Agency under the eligibility criteria
CJtabUslted by the Act.
II is eX1raDeIy 4>wLwlWt your application is accurate and complete in every respect. The PennsylYania Housing Flnaocc Agency
has sixty (60) days to make a decision after it receivCJ your application. During Wt additional time, no Coreclosure PI'O(''''''';"g~ will be
pumled agaimt you if you haye mel the time requiremenlS set Corth aboye. You will be nolilied directly by WI Agency oC its decision on
your application.
The PennsylYania HOlUing Finance Agency is located at 2101 North Front Sueer, Post Office Box 8029, Harrisburg, PennsylYania
1710S, Telephone No. (717) 780-3800 or 1.800-342-2397 (toli free number). Penons wilh impaired hearing can call 1-800-342.2397.
In addition you may receiye anolher notice from this lender under ACI 6 oC 1974. Thar notice is called a .Notice or In1enIion to
Foreclosure.. You musr read bolh DOtiees, since they bolh explain rights thai you now haye under Pennsylvania Jaw. Howeyer. if you
choose to exercl.sc your rights dCJCribed in this notice, you cannel be Coreclosed upon while you are receiving thai assistux:e.
ADAMS COUNTY NATIONAL BANK
By:
Susan M. Saylor
Delinquenlloan and Foreclosure Administrator
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonweallh o( Pennsyly:mia's Homeowner's Emergency Mongage AsSist:mce Program may be able to help you. Read
the (ollowing nOllce 10 find out how the program work.!,
If you need more In(onnadon call the Pennsylyania Housing Finance Agency at 1-800-342-2397.
La nOlifIcaclon en adjunto es de suma Impon:mcia, pues afecta su derecbo a continuar vlylendo en su casa. SI no comprende
el conlenldo de esla notlfIcacion obtenga una traducclon lmmedlalamenle lIamanda esta agencia (Pennsylvania Housing Finance
Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un pre.stamo por el programa lIamado 'Homeowner's
Emergency Mongage Assistance Program' el cual puede salyar su casa de la perdida del derecho a redlmlr su blpoleca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELlGmLE FOR FINANCIAL ASSISl'ANCE WlDCR CAN SAVE YOUR ROME
FROM FORECLOSURE AND HELP YOU MAKE FVTlIRE MORTGAGE PAYMENTS
TO:
Cvnthia C. Bream
Date:
February 18. 1997
FROM:
Adams County National Bank
Re: AccountNo: 612210802671
You may be eligible Cor financial assistance tbat wllJ prevent Coreclosure on your mortgage IC you comply with the
provisions oC the Homeowners' Emergency Mortgage Assistance Act or 1983 (the "Act''), You may be eligible Cor emergeucy
temporary assistance It your default bas been caused by circumstances beyond your control, you bave a reasonable prospect
oC resuming your mortgage payments, and IC you meet other ellglbUlty requirements establlshed by the Pennsylvanla Ronslng
FInance Agency. Please read all oC Ibis Nollce. It cootains an explanallon oC your rights.
Under the Act, you are entilled to a temporary Slay o( (oreclosure on your mongage (or lhiny (30) days from the date o( Ibis
NOlice. During that lime you must arrange and aneod a '(ace-to-race' meeting with a repre.sentatiye o( Ibis lender, or wilb a
designated consumer credit counseling ageocy, The pwpose o( Ibis meeting is to atlempt 10 work out a rcpa)'DlClll plan, or to
otherwise senle your delinquency. This meeting must occur in the next (30) days.
If you atlend a face-to-face meeling wllb tbis lender, or wilb a consumer credit counseling agency identified in tbis notice, 110
funber proceeding in mongage foreclosure may take place for 1blny (30) days after the date of tbis mccling. The name, address aod
telephone number of our rcprescntatiye is:
Ronald L. Hoffman. Vice President
Adams County Natlonal Bank
York Springs. PA 11JIl
Telephone Number: (7 17) 528- 1604
The names and addre.sscs of designated consumer credit counseling agencies arc shown on the anacl1ed sheet. It is only ncc:csmy
to schedule one face.to-face IDCCting. You should adyisc tbis lender immediately of your intentions.
Your mongage is In deFault because you haye failed to pay promplly installments of principal and interest, as rcqulrcd. for a
period of at least sixly (60) days. The tOlal amount of lbe delinquency is S 7. 10 1 . 78 . ThaI sum includes
the (ollowlng:
A partial payment of $2.349.26 due for December 1996 and the monthly payments
of $2.376.26 due for January and February 1997
Your mongage is also in deFault for the (allowing reasons:
(use Ibis P~i'/N~' ~i'Pplicable)
To: E. Ll'roy Dl'put y
828 Baltimnrl' Pike
Da~: February 18. 1997
RE: Mongage Loan No. 612210802671
G..rdnl'rs. PA 17124
NOTICE OF lNfENr10N TO FOREa.OSE MORTGAGE
The MORTGAGE beld by Adams County Natiooal Bank Chereinafu:r we, us or ours) on your propeny located al
828 Baltimore P~ke, Gardners, South H~ddleton Township, Cumberland County.
877 Baltimore Pike. Gardners. South Middleton Township. Cumberland County.
IS IN SERIOUS DEFAULT btC/JUS~ you hav~ MI mod~ 1M monthl'lraynunts olt 2376.26
December 1996. January and February 199
laIC charges or om charges have also accroed 10 litis da~ in the amount of t .00 . The total amount now required 10 cure
litis deraull, or in other words, gel caughl up in your paymcnu, :u of the da~ of litis leacr, !.I t 7. 10 I . 78 .
PA
PA
.
lor 1M months 01
You may cur~ lhis tUfaull wilhin THIRTY (30) DAYS OI'M dOle ollhis wttr.11y paying 10 us 1M oboy~ amoUlll 01$ 7. 10 I. 78
plus f!1l'I odditional monthly paymm1J and Iot~ chargu which moy lall diu during lhis p~riod, Sucb paymom mu.sl be made ciIbcr by cash;
cashier's checlc, ccniJied cbeclc or money order, and made al any office of Adams Coumy Natiooal Bank.
U you do nol cure the deCauJl wilhin TIllRTY (30) DA YS, W~ Int~nd 10 o;~rcls~ our righllo Ol:c~leratt 1M morrgag~ paytrImlS. This
means lhat wbalcvcr !.I owing 1II1bc original amount borrowed will be considered due immediately and you may lose 1hc chance 10 payoff
1bc original mortgage in momhly lns!:lJl"""",. U full paymcDl of the amowu of deCauJI is nol made wilbin TIllRTY (30) DAYS, we also
Int~nd 10 Instrua our 01l0~S 10 starr a IawsuillO 10rtClos~ your morrgag~d prop~rry. If 1M morrgag~ Is lor~c/Qud your morrgaged
prcpmy \<ill be sold I1y 1M SMriJ!1O pay cUw mongag~ tUbl. U we refer your case 10 our aaomcys, bu1 you cure the dehu1t before they
begin legal procccdlngs aga!nsl you, you will still haye 10 pay lIIe reasonable aaorncy's fees, acWally incurred, up 10 SSO,OO. However.
if legal ~"l!' m slaltl:d agaiml you, you wiD haye to pay thc reasonable aaomcy's rccs eYen if lIIey moyer SSO.OO. Any aIIOrncy's
rccs wiD be added to whatever you owe us, whicb may also include our reasonable COSIl. If you cur~ 1M tkf(1JJ1I wilhin 1M lhirry day p~riod.
you willMI b~ r~quirtd 10 pay O1lo~'s/~u.
We may also sue you personally ror the unpaid principal balance and all other sums due under the mongage. U you have nol cured 1bc
dcfmIl wiIhin 1bc Ihiny day period and foreclosure procccrl;"gl haye begun, you stili hav~ 1M righllo cur~ 1M tUfaull and prevDII the soJe
01 any a-lq11O OM hour before tire ShulJ!'s loreclosur~ sole. You moy do so I1y paying 1M 10lal O1TIDUlII of 1M unpaid monzhly paymorlS
plus any Iot~ or am chargu then~, as ~II at 1M rtasonoble 01l0~'S I~u and coro connect~d wilh 1M lor~c/Qsur~ sale and p~rform
any olMr r~quirCMnu UJUkr 1M morrgag~. [I is e.llimated thaI the earUc.l1 date Iha1 such a Sberilrs sale could be held would be
approximately May 1997 . A notice or lIIe date or lIIe Sbcrilrs sale will be seDlIO you berolC lIIe sale. Of
course, lIIe amounl needed 10 cure lIIe defaull will increase the lODger you wait. You may find out at any time ellatlly wba1 thc required
p3ymc1l1 will be by calIiog us alllle foUowing munbcr: (7 In 528- 1604 . This paymcDl mu.sl be in cash, cashier's
cbeclc, ceniJied checlc or money order and made payable 10 us al any officc of Adams Coumy National Bank.
You silouId realize Ihat a Sbcrilrs sale will end your ownership of the mongaged propcny and your rigblto remain in il. U you contimc
10 Uye in 1hc propcny after thc Sheriff's sale, a Iawsuil could be started 10 evicI you.
You haye addltiooal rights 10 help protect your intcrcslin the propeny. YOU HAVE nm RIGlIT 1'0 SELL THE PROPERTY 1'0
OBTAIN MONEY 1'0 PAY OFFnm MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTIIER LENDING INS1ITU110N
TO PAYOFF TIllS DEBT. YOU MAY HAVE nm RIGlIT TO SELL OR nANSFER THE PROPERTY SUBJECT TO nm
MORTGAGE TO A BUYER OR TRANSFEREE WHO Wll.L ASSUME nm MORTGAGE DEBT, PROVIDED THAT ALL nm
OUTSTANDING PA YMEN1'S, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT nm SALE, AND
mAT THE 011lER REQUIREMENTS UNDER nm MORTGAGE ARE SATISFIED, CONTACT US TO DETERMINE UNDER
WHAT CIRCUMSTANCES nns RlGlIT MIGlIT EXIST. YOU HAVE nm RIGlIT 1'0 HAVE nns DEFAULT CURED BY ANY
11URD PARTY ACTING ON YOUR BEHALF.
If you cur~ 1M tUfaul1, 1M morrgag~ will be rtslortd 10 1M s= position at if no tkfaul1 hod OCCU"td, Howeyer, you arc nol cntiIIcd
10 litis righllO cure your defaull more than Ihrce times in any calendar year,
ADAMS COUNTY NATIONAL BANK
EXIIIIIIT J
By:
Susan M. Saylor
DcIinqucDl Loan and Foreclosure Administra1llr
\.
To: Rllx.mnt.' If. Dtl put y
828 Bdltimnre Pike
Dall:: February 18, 1997
RE: Mongage Loan No. 612210802671
Gardners. PA 17324
NonCE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by Adams COlInI)' National Bank !hereinafter we, lU or ours) on your propeny locall:d at
828 Baltimore PIke. Gardners. South Middleton Tnwnship, Cumberland County,
877 Bdltimnre Pike, Gardners. South Middleton Tnwnship, Cumberland Cnunty,
IS IN SERIOUS DEFAULT btCCllUe you have nor llUJdelM month]yraymelUs 01S. 2376,26
December 1996, January and February 199
LaIC charges or olha charses have also accrued to JhiJ dall: in the amoUnl of S. .00 . The total amoUnl now required 10 ClUe
JhiJ derault, or in other words, get caught up in your paymenu, as of the dall: of JhiJ letler, is So 7, 10 I . 78 .
PA
PA
.
lor 1M molUhs 01
You may auelhis tkfoull wilhin THIRTY (30) DAYS OIIM dare ollhis Imer. by paying 10 us 1M above amDUnI ofS 7,10 I. 78
plJJs any additIonoJ monthly payments and lau cluuges which may fall due during lhis period, Such paymeOl mlUt be made either by cash,
cashier's ched:, c:cnl1ied check or mooey order, and made a1 any office of Adams County National Bank.
U ynu do DOt cure the derault wilhln 1lIIRTY (30) DAYS, II'<! Intend 10 exerclse our righl 10 accelerau 1M mongage paymDJIS. This
means Iha1 wbalCver is owing 1I11be origina1 amoUnl borrowed will be considered due ill1TN',,"ll:ly and you may lose the clwx:e 10 payoff
1be origina1 mongage in molllhly instalImcms. U full payment of the amoum of defaullis 1lO1 made wilhln 1lIIRlY (30) DAYS, II'<! Dbo
Intend 10 Instruct our tll/oruys 10 SIan a lawsuil 10 foreclose your mongoged propeny. /f 1M mongoge is foreclosed your mongagtd
propmy MfU be sold by 1M ShnifflO pay offw man gage debl. U we refer your case to our attorneys, but you cure 1he derault before !bey
begin legal procerA;ng, against you, you will still haye to pay the reasonable attorney's fees, actuaJly iDcurred, up 10 $50,00. However,
iflegal (7i'O"""1i'lg' are stlrlod agaimt you, you wiD have to pay 1be reasonable attorney's fees eyen if they are OYer SSG.OO. Any aoorney's
fees wiD be added III whatever you owe lU, which may also iD:1udc our reasonable COSlS. /fyou cure 1M dtfoull wilhin 1M lhiny day period,
you will nol ~ required 10 pay tll/oruy'sfetJ.
We may a!.Io sue you penonally for the unpaid principal balance and all other sums due under the mongage. Uyou haye IlOt cured 1be
defiwlt within die Ihiny day period and foreclosure proceedings haye begun. you slill have 1M righllo cure 1M tkfou1t and prtl'tTIS 1M Silk
or any lime up 10 OM hour before die Shci.f/'s foreclosure salt. You may do so by paying 1M 10lal I111IIJUnI oflM unpaid I1Uinthly paymmrs
plus arry fare or ahu charges /hen due. as wtU Of die reasonable tll/oruy 's fees and COSIS cOMtcred wilh 1M foreclosure salt and perform
any OIMr requiremenlS under 1M mongage, It is estimated that the earliesl dall: that such a Sberilfs sale could be bold would be
approximall:ly May 1997 . A IlOtic:c of the dall: of the Sberilfs sale will be seOlIO you before the sale. Of
course, the amount needed to cure the default will increase the longer you walt. You may find out at any time exactly whai the required
paymenl will be by cal1iog lU a1 the foUowing nwnbc:r: (7 In 528- 1604 . This paymeOllIll1St be in cash, cashier's
check, cenl1ied check or money order and made payable to lU al any office of Adams Coumy National Bank.
Yau sbou1d rca1ize Iha1 a Sheriff's sale will end your ownership of the mongaged property and your riglu to remain in it, U you con1inue
to live in the property a1ll:r the Sborift's sale, a lawsuit could be sraned to evicl you.
You have additional righu to bolp protect your in1eresl in the property. YOU HAVE TIlE RIGHT TO SELL THE PROPERTY TO
OBTAIN MONEY TO PAY OFF TIlE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTIiER LENDING lNS1Tl1lTION
TO PAY OFF THIS DEBT. YOU MAY HAVE TIlE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO TIm
MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL TIm
OUTSTANDING PAYMENTS, CHARGES AND AlTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND
THAT THE OTHER REQUIREMENTS UNDER TIlE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER
WHAT CIRCUMSTANCES TIiIS RIGHT MIGHT EXIST. YOU HAVE TIlE RIGHT TO HAVE THIS DEFAULT CURED BY ANY
THIRD PARTY ACTING ON YOUR BEHALF.
/fyou cure 1M tkfou1t, 1M I1Uingage wiU be rwored 10 1M same pas/lion as If no dtfou1t had occurred. However, you are not en1i1kd
10 JhiJ right 10 cure your deraull more than three times in any calendar year,
ADAMS COUNTY NATIONAL BANK
EXIIIIIIT L
By:
Susan M. Saylol
Delinquenl Loan and Foreclosure AdminlstnlDr
\. '
To: RllXannl' II. Ot1put y
Dale:
February 18, 1997
828 H.llt im.'rL' Pik,'
RE: Mongage Loan No. 612210802671
G", dOl'r s, I'A 17124
NonCE OF INTENflON TO FORECLOSE MORTGAGE
The MORTGAGE held by Adams County National Bank (bcreinafler we, us or ours) on your propeny located at
828 Baltimore Pike. Gardners. South Middleton Township. Cumberland County.
877 Baltimnre Pike. Gardners. South Middleton Township. Cumberland County.
IS IN SERIOUS DEFAULT buause you have IUJI nwde lhe mol1lh/Yraymel1lS of~ 2376.26
December 1996. January and February 199
Lale charges or other charges have also accrued 10 this dale in Ihe amount of ~ .00 . The IOta! amount now required 10 cure
this default, or in other word5, get caught up in your paymeJltS, aJ of Ihe dale of this leller, is ~ 7. 10 I . 78 .
PA
PA
for lhe mol1lhs of
You may cure lhis defaull within 11lIRTY (30) DAYS oflhe dau oflhis Imer, by paying 10 us lhe above l11IUJunI ofS 7. 10 1.78
plus any additional momhly paymmlS and /au charges which may fall due during this period, Such payment must be made eilher by cash,
cashier's check, certified check or money order, and made at any office of Adams County National Bank.
If you do DOt cure the default within THIRTY (30) DAYS, we Imend 10 exercise our righllo tUcekrate lhe mortgage paymerl1S. 'IbIs
means that whalcvcr is owing Olllbe original amount borrowed will be considered due irnnvotli'lCly and you may lose the chance to pay oil
the original mortgage in momhly installmcDlS. If full payment of the amount of default is DOl made within THIRTY (30) DAYS, we also
Inund 10 InstrUct our anomeys 10 start a lawsuillo foreclose your mortgaged property. If lhe mortgage Is foru/ased your mortgaged
property Kill be sold by /he SherifflO pay off/he mortgage debl, If we refer your case 10 our atlOrncys, but you cure Ihe default before they
begin legal proceedings against you, you will still haye to pay Ihe reasonable atlOrncy's fees, acntally incurred, up to $50,00. However,
if legal proceedings are started against yro, yro will have 10 pay the reasonable anorncy's fees even if Ihey are over $50,00, Any attorney's
fees will be added 10 whalever yro owe us, which may also ia:1ude our reasonable costs. If you cure lhe defaull wilhin lhe lhirty day period,
you willlUJl be required 10 pay anomey's fus,
We may also sue you persooa1ly for the unpaid principal balance and all olher sums due under Ihe mortgage. If you haye not cured the
defiwlt wilhin the thiny day period and foreclosure proceedings haye begun, you still have lhe righllo cure /he defaull and prevent lhe sale
at any dme up 10 one haW' before /he Sheriff's forulosure sale, You may do so by paying lhe 10lall11lUJunI oflhe unpaid mol1lhly paymen1S
plus any late or aher charges then~. os well os /he reosonabk anomey 's fees and COSIS cOfIMaed wilh lhe foreclosure sak and per/onn
any olher requirt1MrI1S UJUkr lhe mortgage, It is estimalCd !hat the earliest dale !hat such a Sheriffs sale could be held would be
approximately May 1997 . A notice oflhc dale oflhe Sheriffs sale will be sent to you before Ihe sale, Of
course, Ihe amount needed 10 cure Ihe default will increase Ihe longer you wait. You may find out at any time exactly whatlhe required
paymenl will be by calling us atlhe foUowing oumber: (7 17) 528- 1604 . 'IbIs payment must be in cash, cashier's
check, certified check or money order and made payable to us at any office of Adams County National Bank.
You should realize !hat a Shcritrs sale will end your ownership of Ihe mongaged property and your right 10 remain in it. If you continue
to liye in Ihe property after Ihe Sheriffs sale, a lawsuit could be started 10 evict you,
You have additional rights to help protect your inleresl in Ihe 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 TIllS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE
MORTGAGE TO A BUYER OR TRANSFEREE WHO WD..L ASSUME THE MORTGAGE DEBT, PROVIDED TIlAT ALL THE
OUI'STANDING PA YMENl'S, CHARGl'S AND ATTORNEY'S FEFS AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND
TIlAT THE OTHER REQUIREMENTS UNDER TIlE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER
WHAT CIRCUMSTANCES TIllS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE TIllS DEFAULT CURED BY ANY
TIURD PARTY ACTING ON YOUR BEHALF. .
If you cure the defaull, lhe mortgag~ will be reslored 10 lhe same position os ifIUJ defaull hod occurred, Howeyer, you are not eo1ided
10 this right to cure your default more !ban three times in any calendar year.
ADAMS COUNTY NATIONAL B,ANK
( (
By: /fc '" ,,1h ~tl ~I (,."
Susan M. Saylor
Delinquent Loan and Foreclosure AdministralOr
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To:
Adam L. Brl',lm
Da~: February 18. 1997
RE: Mongage Loan No. 612210802671
877 Baltimore Pike
Gardners, PA 17324
NOTICE OF INTENrlON TO FORECLOSE MORTGAGE
The MORTGA9E beld by Adams County National Bank ll!ereinaf~r we. 1IJ or o\!l's) on your property localed at
B28 Balt~more Pike. Gardners. South Middleton TownshIp. Cumberland County.
877 Baltimore Pike. Gardners. South Middleton Township. Cumberland County.
IS IN SERIOUS DEFAULT btcaJlSt yau have nal lMde 1M nwnlhlvraynunls ofS. 2376.26
December 1996. January and February 199
I.a~ charges or olber charges bave also accrued 10 !his da~ in the amoUOl of So .00 . The lOW amoUOl now lequired 10 cure
this defaull, or In t\her words, get caught up in your paymenlS, as of the dste of this letter, b s. 7. 10 I . 78 .
PA
PA
for 1M tnanlhs of
You may cure lhis dt/auu wilhin THIRTY (3D) DAYS of 1M dare oflhis ItIler, by paying 10 us 1M above cunaUnl ofS 7. 10 I. 78
plus arry additional tnanllr/y paymtnIS and laIe charges which may fall due during lhis period, Such paymeDl mllJt be made either by cam,
cashier's check, certified check or money order, and made at any office of Adams County National Bank.
If you do DOt cure the default within TIllRTY (30) DAYS, we inlend to aerdse our right to acceitrale tM nwngage paymtnlS. This
means that wha1ever iJ owin& 011 dJc original aDlOUOI borrowed will be considered due immcdia~ly and you may lose the cbancc 10 payoff
lhc original mongage in monthly lnstallmeDtS, If full paymeDl of the amounl of defaull b DOl made within TIllRTY (30) DAYS, we also
Inlend to instruct our a/tomeys to stan a lawsuit to forecloSt your mongoged property. q tM nwngoge Is foreclosed your mongoged
property \<ill be sold by the Sheriff to pay afflM mongage debt, If we refer your ta.!e to our anorneys, but you cure the default before they
begin legal proceedings against you, you will still bave 10 pay the reasonable attorney's fees, actua1ly incurred, up to $50,00. Howeyer,
if legal ptn.......Ung, arc statted ag;Umt you, you will baye 10 pay lhc reasonable attorney's fces even if they are over S50.00, Any altorney's
fees will be added 10 wbareyer you owe lIJ, which may also Iocludc our reasonable COSIS. If you cure the defauil within 1M lhirty day period,
you will not be required to pay a/tomey's fees,
We may wo sue you personally for the unpaid principal balance and all olhcr sums due under the mongage. If you baye nOl cured lhc
defiwlt wilhin lhc Ihirty day period and foreclosure proceedings baye begun. you still have 1M right 10 cure the dt/auu and prcvenl the salt
all1ll)' time up to one hour before the Sheriffs foreclosure salt. You may do so by paying lhe tOlal cunaUnl of tM unpald momhly paymmts
plus l1ll)' laIe or other charges then due, lIS wtllllS the rellSanabit a/tomey 's fces and COSIS Cofllltcted with the foreclosure salt and perform
oay olMr requiremtnlS under 1M mongoge, It is e.!timalcd that the earUest dale that such a Sheriffs sale could be held would be
approximately May 1997 , A notire of the da~ of the Sheriffs sale will be seOlto you before the sale. Of
course, the amounl needed to cure the default will inclcale the longer you wail. You may find out at any lime exactly wbat the required
paymcDl will be by calling 1IJ at the following munbcr: ( 7 1 7) 528- 1604 . This paymenl mUll be in ta.!h, cashier's
cbeck, certified check or money order and made payable 10 1IJ al any office of Adams Coumy National Bank.
You should rea1izc that a Sheriffs sale will eoo your ownership of the mongaged plOpeny and your righllO remain in iI. If you coD1iwc
10 liye in the propeny aIll:r the Sheriffs sale, a lawsuit could be slartcd 10 evict you.
You baye additional righlS to help protect your interest in the propeny. YOU HAVE TIlE RIGHT TO SELL TIlE PROPERTY TO
OBTAIN MONEY TO PAY OFF TIlE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTIIER LENDING INS1TfU110N
TO PAY OFF TIllS DEBT. YOU MAY HAVE THE RIGHT TO SEll. OR TRANSFER THE PROPERTY SUBJECf TO THE
MORTGAGE TO A BUYER OR TRANSFEREE WHO Wll.L ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE
OUTSTANDING PA YMENrS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT TIlE SALE, AND
THAT THE OrnER REQUIREMENTS UNDER TIlE MORTGAGE ARE SATISFIED. CONTACf US TO DETERMINE UNDER
WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE TIlE RIGHT TO HAVE THIS DEFAULT CURED BY ANY
11IIRD PARTY ACTING ON YOUR BEHALF.
If you cure the defoulJ. lhe tnangage will be restored to lhe same position as If no defoulJ had occurred. Howeyer, you arc DOl eD1idl:d
to !his right to cure your defaull more than three times in any calendar year,
ADAMS COUNTY NATIONAL BANK
EXHIBIT N
By:
SlISaII M. Saylor
DeIinqueOl Loan and Foreclosure Adminislt1llDt
\.
To:
Cynthi.J c. Bn.111m
Date:
February 18. 1997
877 Baltimore Pike
RE: Mongage loan No, 6 122 1080267 I
Gardners. PA 17324
NonCE OF lNTE~ON TO FORECLOSE MORTGAGE
lbe MORTGAGE beld by Adams Coumy NatiooaJ Bank lbereinaftcr we. UJ or ours) 00 your propeny localed at
828 Baltimore Plke. Gardners. South Middleton Township. Cumberland County.
877 Baltimore Pike. Gardners. South Middleton Township. Cumberland County.
IS IN SERIOUS DEFAULT becl1JlSe you have IlQr nuufe the monrhlYfayTlltIllS oft 2376.26
December 1996. January and February 199
laIC charges or oilier charges have also lICCIUed to this date in the amount of t . 00 , lbe IOta! amount now required to cure
this defaull, Gr in other wordJ, gel caughl up in your paymenu, as of the date of this leltcr, is t 7. 10 I . 7 B .
PA
PA
for the mo1ll1u of
You may aue lhis defau/J wilhin 17lIRTY (30) DA l'S oflhe dare oflhis Ittter. by paying 10 ILl the above amount of S 7. 10 I . 78
pbu II1lJ additional monthly JX1YTIlt1IlS and lalt charges which may fall d~ during lhis period. Such paymcDl musl be made either by cash,
cashier's check, cenified check or money order, aDd made al any office of Adams Coumy NatiooaJ Bank.
If you do 1101 cure the defaull within TIlIRTY (30) DAYS, we inrtnd to t:.cercise our righz to lUCeUralt the mongage paymmtS. TbiJ
IllCaDS that wbalever is owing en !be origiDaI amount borrowed will be considered due i"'""'dlately aDd you may lose the chaDcc to payoff
the origiDaI mortgage in moDlhly ins",lIlTv""l. If full payment of the amount of defaull is DOl made within TIlIRTY (30) DAYS, we olso
Intend 10 i1lSrTlla our attorneys to starr a lawsuit to foreclose your mangaged propmy. If the mongage Is foreclosed YOUI' mangllgtd
propmy ....a be sold by tht SMrijfro pay offlhe mongllgc debl. If we refer your case to our a1IDmcys, bu1 you cure the defaull before Ihcy
begin legal proceedings againsl you, you will still haye to pay the reasonable attorney's fces, actualJy incurred, up 10 $50,00. However,
if legal ~nv are started agalml you, you will have to pay the reasonable attomcy's fees eYen if they arc oyer SSO,oo. Arly a1IDrney's
fees will be added to whatever yoo owe UJ, wblcb may also in:1udc our rcasooable cosu. If you cure the defau/J wilhin the thirry day perWd,
you wia IlQt be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the mongage. If you haye llOl cured !be
dcf:wh wilbin !be thiny day period and foreclosure proce...Hng' have begun.. you sliU have the righz to aue tht defaull and prtvDrl tht Silk
at II1lJ ti= up ro OM hour before 1M Sheriff's foreclosure sale. You may do so by paying the toral amount of tht unpaid monthly paymmlS
pbu II1lJ /are or other charges then due, ar wtlJ ar 1M rtaronabu attorney's fees and casu connected wilh tht foreclosure sale and perfomt
aay olher requir~1llS llIUkr the mongage. II is estimated that the earliesl date thai sucb a Sheriff's sale could be held would be
approximately May 1997 , A notice of the date of the Sberiff's sale will be seDlto you before the sale. Of
course, the amount needed to cure the defaull will increase the longer you wail. You may find OUl al any time exactly what the required
pa}'lllClll will be by calling w al the following munbcr: ( 7 17) 528- 1604 . TbiJ payment musl be in cash, casbler's
cbeck, cenified cbeck or money order and made payable to UJ al any office of Adams County National Bank.
Yoo sbauld realize thai a Sbcrifrs sale will end your ownership of the mongaged property and your righlto remain in 11, If you contimc
to liye in the property after the Sheriff's sale, a lawsuil could be slai1Cd to evicl you.
You baye additional righIs to help prolCCl your interesl in the properry. YOU HAVE TIlE RIGHT TO SEll.. TIlE PROPERTY TO
OBTAIN MONEY TO PAY OFF TIlE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTIIER LENDING INSnnmON
TO PAYOFF TIllS DEBT. YOU MAY HAVE TIlE RIGHT TO SEll.. OR TRANSFER TIlE PROPERTY SUBJECT TO THE
MORTGAGE TO A BUYER OR TRANSFEREE WHO wn.L ASSUME TIlE MORTGAGE DEBT, PROVIDED TIlAT ALL THE
OlITSTANDING PA YMENI'S, CHARGES AND ATIORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT TIlE SALE, AND
TIlAT TIlE OTIIER REQUIREMENTS UNDER TIlE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER
WHAT CIRCUMSTANCES TInS RIGHT MIGHT EXIST. YOU HAVE TIlE RIGHT TO HAVE TInS DEFAULT CURED BY ANY
TIIIRD PARTY ACTING ON YOUR BEHALF.
If you cure the defaull. tht mongage wiU be rutored to tht SI11M position ar if IlQ defaull hDd occurred. Howeyer, you arc 1101 cmdcd
to this righlto cure your defaulllllOre than three times in any calendar year.
ADAMS COUNTY NATIONAL BANK
EXHIBIT P
By:
Susan M. Saylor
Delinquent Loan and Foreclosure AdministraJJr