HomeMy WebLinkAbout03-2781MeCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(2~5) 790-~010
Centex Home Equity Company, LLC
P.O. Box 199111
Mail Stop AK7
Dallas, TX 75219
Kathie Gmcz
2605 Market Street
Camp Hill, PA 17011
Attorney for Plaintiff
Cumberland County
Court of Common Pleas
_CIVIL ACTION/MORTGAGE FORECLOSURE
NOTICE
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by
attorney and filing in writing with the court your dcfenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without furlher
notice for any money claimed in the complaint or for any other
claim or relief requested by the plaintiff. You may lose money
or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA, 17013
800-990-9108
AVISO
Le ben demandado a usted en la torte, Si usted quiere defenderse
d.e esta~ demandas ex-puestas en las paginas sigulentes, usted
tiene vemte (20) dias de plazo al partir de la fecha de la demanda
y la notificacion. Hace falta ascntar una comparencia escrita o
en persona o con un abogado y entrcgar a la cur~e en fonna
eserita sns defensas o sns objeciones a las demandas en contra de
su persona. Sea avisedo que si usted no se defiende, la corte
ton~ra m~didas y puede continuar la demanda en contra suya sin
pre'no avlso o notificacion. Ademas, ia corte puede decidir a
favo~ d. el dernandante y requierc que nsted cumpla con todas las
prowsiones de asta demanda. Usted puede perder dinero o sns
propiedades u o~os dcrechns impormntcs para nsted.
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE. SI NO TIENE ABOGADO O
SI NO TIENE EL DINERO SUFICIENTE DE
PAGAR TAL SERVICO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFIC1NA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABA JO
PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA, 17013
800-990-9108
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Centex Home Equity Company, LLC
P.O. Box 199111
Mail Stop AK7
Dallas, TX 75219
Kathie Gmcz
2605 Market Street
Camp Hill, PA 17011
Attorney for Plaintiff
Cumberland County
Court of Common Pleas
Number t~3 - 2/.7.OI
CML ACTION/MORTGAGE FORECLOSURE
1. Plaintiffis Centex Home Equity Company, LLC, a corporation duly organized and doing
business at the above captioned address.
2. The Defendant is Kathie Gruez, who is the mortgagor and real owner of the mortgaged
property hereinafter described, and her last-known address is 2605 Market Street, Camp Hill, PA 17011.
3. On 03/18/2002, mortgagor made, executed and delivered a mortgage upon the premises
hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland
County in Mortgage Book 1753, Page 2968.
4. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A"
and is known as 2605 Market Street, Camp Hill, PA 17011.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 01/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage,
upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
$ 121,549.86
VERIFICATION
The undersigned, Terrence J. McCabe, Esquire, hereby certifies
that he is the Attorney for the Plaintiff in the within action, and
that he is authorized to make this verification and that the
foregoing facts are true and correct to the best of his knowledge,
information and belief and further states that false statements
herein are made subject to the penalties of 18 PA.C.S. §4904
relating to unsworn falsification to authorities.
CERTIFIED
COPY
RemmTo:
CRNTEX HOME EQUITY COMPANY, LLC
P.O. BOX 199111, FINAL DOCS
Dallas, TX 79219
Panel Number:
01210271508
249214952
MORTGAGE
DEFINITIONS
Words u~ed in multiple sections of this document are defined below and other words =e defined in Sections
3/18/2002
(C) "Lender" is
PENNSYLVANIA . S~n~e Farr~y - Fannie Mae'Freddie Mac UNIFORM INSTRUMENT Fomt 3039
(~-6(PA)
ExhibitA
249214952
Lender is the mortgagee under this Security Instrument.
(D) "Note" means the promisso~ note signed by Borrower and dated
(U.S. $ 121, S 00.00 ) plus interest. Borrower has promised tn pay th/s debt in regular Periodic
(E) "Property" means the properi3, that is described below under the heading 'Transfer of Rights in thc
Riders are to be executed by Borrower [check box as applicable]:
[] Adjustable Rate Rider [] Condominium Rider [] Second Home Rider
[] Balloon Rider [] Planned Unit Development Rider [] 1-4 Family Rider
[] VA Rider [] Biweekly Payment Rider / I Other(s) [spec/fy]
tr~.acuons, mmsfer~ xmthted by telephone, wn'e transfers, and automated clearinghouse tnmsfers.
the Loan.
Form3039 1~1
De ~1 No:ea. Fo:: 20-01355720
;LLL THAT CERTAIN LOT OR PIECE OF GROUND SITIFATED IN THE BOROUGH OF CAMp HILL, COUN~ OF
CUMBERLA~ A~ STATE OF PENNSYLVANIA, BEING MOP~ PANTICULARLy BOUNDED AND DESCRIBED A~
FOLLOWS:
BEGINNING AT A FOINT ON T~ SOU~ SIDE OF F~T STREET, EIGHt-THREE AND FIVE-TENT~S
(83.$) FEET WEST OF THE SOUTHWEST COP. NER OF MARKET STREET AND BOWMAN AVENUE; THENCE AT
RIGHT ANGLES IN A SOUTH-ONLy DIRECTIONALONG ~S NOW OR FORMERLy OF A/~NA I WOLF THO
HUNDRED (200) FEET TO A 15-FOOT PUBLIC ALLEY; THENCE AT THE RIGHT ANGLES IN A WESTERLY
DIRECTION ;~LONG THE NORTH SIDE OF SAID 15-FOOT ALLEy FORTY-ONCE (41) FEET TO A POINT;
THENCE AT RIGHT ANGLES IN A NORTHERLY DIRECTION TWO HUNDRED (200) FEET TO MARKET STREET;
THENCE AT RIGHT ANGLES IN AN ~ASTERLY DIRECTIONALONG THE SOUTH SIDE OF ~L~RF, ET STREET
FORe'Y-ONE (41) FEET TO THE PIECE OF BEGINNING; CONTAINING FORTY-ONE (41) FEET IN FRONT ON
MARKET STREET AND EXPOUNDING EACK AN EVEN WIDTH THO HUNDRED (200) FEET TO THE AFORESAID
15-FOOT PUBLIC ALLEY, A~ PQ%VING THEREON ERECTED A TWO ;%ND ONE-HALF STORY BRICK DWELLING
HOUSE NO. 2605 ~L~RRET STREET.
Page 1 of i
249214952
(O) "RESPA" means the Real Estate Sediement Procedures Act (12 U.S.C. Section 2~01 et seq.) and its
implementing regulation, Reguhtion X (24 C.F.R. Pan 3500), as they rdight be amended from time to time,
or any additional or successor legislation or regulation that governs the s~me subject matter, As used ia this
,S~u~ty lastsument, 'RESPA" refers to al~ requirements and restrictiom that ar~ ~'nposed ia regard to a
edetally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan'
unde~ R~PA.
(P) "Successor in Interest of Borrower" means any patty that ~a$ taken title to thc Proparty, wbe~er or not
that party bes assumed Borrower's obligations under the Note and/or ~his Security Instrument.
TRANSFER OF RI~HTS IN THE P~OPERTY
This Security Instnuncnt secures to Lender: (i) the ~payment of the Loaa, and all reaewals, extensions and
modlficatlona of thc Note; and (fi) the performance of Bo~ower's covenants and agreements u~et this
Security Ins~nunent and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to
Lender the following described pC?C?C?C?C?Ci~]~21~I~ted in the COO~q~,
of [Typo of Recording Ju~Jlcflon]
[N~ra~ of Recordtsi Jurisdic~ion]:
t:h&t: t:=acb or p&raeZ of land as sho~n on l~chedule "A" at:t:&ched heret:o
vthtch t~ tncorpor&bed herein and made a part: hereof.
TOGETHER WITH ali the improvements now or hereafter erected on the property, and ali easements,
appurtenances, and fixtures now or hereafter a pm of the proparty. All repayments and additions shall also
be covered by this Security l~sm~ment. AB of the foregoing is referred to ia this Security l~muue~t as the
249214952
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed a~d has
the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all
claims and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform
covenants with liimt~d variations by jurisdiction to constitute a uniform security insmunent covering real
property.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment of Principal, Int,~r~t, Escrow Items, Prepayment Chorge~, and Late Chorg~.
Borrower shall gay when due the principal of, and interest on, the debt evidenced by the Note and any
prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Imms
pursuant to Section 3. Payments doe under the Note entl this Security Imtmm~ shall be made in U.S.
currency. However, if any cheek or other instrament received by Lender as payment under the Note or this
Security Insmament ia rntumed to Lender unpaid, Lender may require that any or all subsequent payments
due under the Note and this Security Instrument be made in one or more of the following forms, as selected
by Lender: (a) cash; Co) mon*y order; (e) certified check, bank check, treasurer's check or cashier's check,
provided any such ebeek ia drawn upon an imfitution whose deposits are insured by a federai agency,
immnnentality, or entity; or (d) Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location deaignated in the Note or at
such other location as may be de$igmtetl by Lender in aceordenee with the node* provisions in Section 15.
Lender may return any paym~t or partial payment if the payment or partial payments are insufficient to bring
the Loan ~t. l~nder may accept any payment or partial payment insufficient to bring the Loan ~,
without waiver of any rights hereunder or prejudice to its righia to refuse such payment or partial payments in
the futom, but Lender ia not obligated to apply such payments at the time such payments are accepted, ff each
Pariodie Payment is applied as of it~ scheduled due date, then Lender need not pay interest on unepplied
funds. Lender may hold auch unappliad funds until Borrower makes payment to bring the Loan current. If
Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return
fu~n to Borrower. If not apptied earlier, such funds will be applied to the outstanding principal balance under
the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the
future against Lender shall relieve Borrower from making payments doe uader the Note and this Security
Imminent or performing the covenanta and agreements secured by this Security lmtrament.
2. Application of Payments or Proceeds. Except as otherwiae described in this Section 2, all payments
accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the
Note; {b) principal doe tulder the Note; (c) amounts due under Section 3. Such payments shall be applied to
each Periodic Payment In tbe order in which it became due, Any remaining amounts shall be applied first to
late charges, secoml to any other mounts due under this Security Instrument, and then to reduce the principal
balance of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a
sufficient amount to gay any late charge doe, the payment may be applied to the delinquent payment and the
late charge. If mom than one Periodic Payment is outstanding, Lender may apply any payment received from
Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in
Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the
3. Funds for Escrow Items. Borrower ~aall pay to Lender on the day PelSndic Payments are d~e under
the Note, un~ the Note is paid th full, a sum (the 'Fuads') to provide for payment of amounts due for: (a)
encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (e) p~nx~ms
for any and all insurar~e r~quised by Lender under Se¢llon 5; and (d) Mortgage/nsuranee preminms, if any,
accordance with the provisions of Section 10. These items are called 'Escrow Iterm.' At origination or at any
Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such
The F~mds shall be held in an institution whose deposits are insured by a federal agency, instrumentality,
RESPA. Lender shall not charge Borrower for holding and applying the I~m~ds. annually analyzing the
Applicable Law permits Le~der to make such a charge. Unless an agreement is made in writing or Applicable
249214952
Funds. Lender shall give to Borrower, without charge, an annual accounting of the ~nds as required by
RESPA.
If there is a sm'plus of l~mds held in escrow, as dsfmcd under RESPA, Lender shall accou.~t to
Borrower for the exce~s funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as
defined under RF~PA, Lender shall notify Borrower as reqinred by I~SPA, a~cl Borrower shell pay to
Lender the amount necessa~ to make up the shortage in accordance with RESPA, but in no more than 12
monthly payments. If there is a deficiency of [~unds held in escrow, as defined under RESPA, Lender shall
notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to m~ke up
the deficiency in accordance with RF~?A, but in no more than 12 monthly payments.
2492].4952
If Borrower fails to maiatain any of the coverages described above, Lender may obtain insurance
coverage, at Lender's option and Borrower's expense. Lender is under no obligation ~o purchase any
particular P~pe or aroount of coverage, Therefore, such coverage shall cover Lender, but might or might not
protect Borrower, Borrower's equity in the Property, or the content~ of the Property, agaiust any risk, hazard
or liability and might provide greater or lesser coverage than was previously in effect. Borrower
rights (other than the right to auy refund of uu~amed premiuu~ paid by Borrower) under all msUmUce
249214952
6. Occu~tncy. Borrower shall Occupy, establish, and use the Property as Borrower's principal residence
Borrower's principal residence for at least one year after the date of Occupancy, unless Lender otherwise
agrees in writing, wlfich consent shall not be unreasonably witi~eld, or unless extenuating cu'cums~ances
exist which are beyond Borrower's control.
7. Preservation, Maintenance and Protection of the Property; Impectlons. Borrower shall not
destroy, damage or impair the P~operty, allow the Property to deteriorate or commit waste on the Property.
Whether or not Borrower is resallng in the Property, Borrower shall malntath the Property in ordur to prevent
the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to
Sectton $ that repatr or restoration is ~ot econormcally f~asthle, Borrower shall promptly repatr the Property if
damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in
connection with damage to, or the talcing of, the Properly, Borrower shall be respens~le for repairing or
restoring the Properly only if Lender has released proceeds for such purposes. Lender may disburse proceeds
for the repairs and restoration in a single payment or th a series of progress payments as the work is
completed. If the insurance or condenmation proceeds are not sufficient to repair Or restore the Properly,
Borrower is not relieved of Borrower's obligation for the completion of such repair or restoration.
Lender or its agent may make reasomble entries upon and inspectiom of the Property. If it has
reasonable cause, Lender may inspect the interior of the improvements on the Property. Lender shall give
Borrower notice at the time of or prior to such an interior impection specifying such reasonable caus6.
$. Borrower's Loan Application. Borrower shall be in default if, during the Loan application process,
Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or
consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed to
provide Lender with material information) in connection with the Lean. Material representations include, but
are not limited to, representations concerning Borrower's occupancy of the Property as Borrower's principal
residence.
9. Protection o1' Lender's Interest in the Property and Rights Under this Security Instrument. If
(a) Borrower fails to perform the covenants and agreements contained in this Security Instmmant, Co) there is
a legal proceeding that might significantly affect Lender's interest in the Property and/or rights under this
Security Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for
enforcement of a lien which may attsin priority over this Security Imtrument or to enforce laws or
regnlatiom), or (¢) Borrower has abandoned the Property, then Lender may do and pay for whatever is
reasonable or appropriate to protect Lender's interest in the Property and rights under this Security
Imtmment, including protecting and/or assessing the value of the Property, and securing and/or repairing
the Property. Lender's acfton~ can include, but are not limited to: (a) paying any sums secured by a lien which
has priority over ~ Seolrity Instrument; Co) appearing in couri; and (c) paying reasonable attorneys' fees to
protect its interest in the Property and/or rights under this Security lmh~nent, including its secarnd position
in a bankruptcy proceeding. Securing file Property includes, but is not limited to, entering the Property to
make repairs, change locks, replace or board up doors and windows, drain water from pipe~, eliminate
building or other code violations or dangerous conditions, and have utilities Rimed on or off. Although
Lender may take action under this Section 9, Lender does not have to do so and is not under any duty or
obligation to do so. It is agreed that Lender incurs no liability for not taking any or all actions authorized
Fomt 3039 1/01
If this Security lustraraent is on a leasehold, Borrower shall comply with all the provision~ of the lease.
previously provided such insurance and Borrower was required to make separately desigeated payments
reserve th lieu of Mortgage Insurance. Such loss reserve shall be non-refundahie, notwithstanding the fact that
the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower a~y interest or earnings
the amount and for the period that Lender requires) provided by an insurer selected by Lender agahl becomes
required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower
between Borrower and Lender providing for such tennmatthn or until termination is required by Applicable
on terms and conditions that are sailsfacto~ to the mortgage insult and ~.e other party (or parties) to these
that the mortgage insurer may have avatiab]e (which may include funds obtained from Morigage Insurance
premiums).
other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive
from (or might ha characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange
for sharing or modifythg the mortgage insurer's risk, or reducing losses. If such agreement provides that an
affl~te of Lender ~akes a share of the insurer's risk in exchange for a share of the premiums paid to the
Mortgage Insurance, or any other terms of the Loan. Such ageeements will not tho-ease the mount
Co) Any such agreements will not affect the rights Borrower has . if any - with respect to the
such repair ami restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until
restoration in a single disbursement or in a series of progress payments as the work is completed. Uuless an
agreemem Ls made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds,
Lender shall not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. ff the
restoration or repair is not economically feasible or Lender's security would be l~sseued, the Miscull~neous
Proceeds shall be applied to the sums secured by this Security Insmlmant, whether or not then due, with the
excess, if any, ~ to Borrower. Such Misceliananus Proceeds shall be applied in the order provided for in
In the event of a partial taking, desffuction, or loss in value of the Property in which the fair market
Security Insmunent shall be reduced by the amount of the Miscellaneous Proceeds muinphed by the
or loss in value divided by (b) the fair market value of the Property immediately before the pargal taking,
value of the Property immediately before the partial taking, destruction, or loss in value is le~s than the
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing
Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails
apply the Miscellaneous Proceede either to restoration or repair of the Property or to the sums secured by ~is
Security Insmunant, whether or not then due, 'Opposing Party" means the third party that owes Borrower
Miscellaneous Proceeds or the party agaimt whom Borrower has a right of action in regard to Miscellaneous
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begum that, in
in the Property or rights under this Security Instrument. Borrower c~u cure such a default and, if acceleration
has ocenned, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a
ruling that, in Lender's ~lldgment, precindes for~eitore of the Property or other material impairn~t of
for damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned
in the order provided for in Section 2.
of the sum~ secured by ~ Sectuity Inslrument by reason of any dem,~d made by the original Borrower or
agrees that Borrower's obligations and liability shall be joint ~ several. However, ally Borrower who
co-signs this Security Imtmmem but does not execute the Note (a ~co-signer'): (a) is cosigning this Security
Security Insmunent; (b) is not personally obligated to pay the sums secured by thLs Security Immunem; a~d
(¢) agrees that Lender and any other Borrower can agree to extend, modify, forbear or make any
20) and benefit the succesaors and assigns of Lender.
Security Instrument, including, but not limited to, attorneya' fees, propat~y inspection and valuation fees. In
that are expressly prohibited by this Security Imtrument or by Applicable Law.
pannitmd limits, then: (a) any such Ioan charge shall be reduced by the amount necessazy to reduce the charge
will be refunded to Borrower. Lender may ~oose to make this refund by reducing the principal owed uader
provided for under the Note). Bonower's acceptance of any such refund made by direct payment m Borrower
Applicable Law expressly requires otherwise. The notice address shall be the l~operty Address unless
Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change of
be given by delivering it or by mailing it by first class mail to Lander's address stated herein unless Lender
shall not be deemed to have been given to Lender until actually received by Lender. If any notice required by
~ Security lmmmlent is also required under Applicable Law, the Applicable Law requirement will satisfy
the corresponding requirement under ~ Security Instrument.
by federal law and the law of the jurisdiction in which the Property is lecatnd, All rights and obligatio~
contained in this Security instrument are subject to any requiremalts and limitations of Applicable Law.
Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent, but
provision or chuse of this Security Instalment or the Note conflicts with Applicable Law, such conflict shall
conflicting provision.
As used in ~ Secllrity lmh-umeot: (a) words of the masculine gender shall mean and include
¢Oll~Sl~ollding ~ words oF wordr Of th~ ~mini~. gender; (b) words in the singular shall mean and
If all or any ~ of
However, this option shall ~ot be exercised by Lender if such exercise is prohibited by Applicable Law.
swu~pX~.ohirCh~errOe~er' m}lst pa.y .al}. sums secured by ~ Security Insh-~u~lent. If Borrower fails to pay these
,_.~._P,_,, .... ~.uation .oI this period, Lender m~y invoke any remedies mltlted by ~ Se~urily
Security Insh-ument; (b) such other period as Applicable Law might specify for file telmination of Borrower's
righi to ~instata; or (c) envy of a ~dgment enforcing this Security Insmm~n~. Those conditions are that
Borrower: (a) pays Lender all sums which then would be due under this Security Insu-un~nt and lhe Note as
249214952
249214952
Bo~ower shall not cause or panult the presence, use, disposal, storage, or release of a~y Hazardous
Substances, or thraaten to release any Hazardous Substances, on or in the Property. Borrower shall not do,
nor allow anyone else to do. anything affecting the PropeRy (a) that is in violation of any Environmental
Law, Co) which creatas an Environmental Condition, or (c) which, due to the presence, use, or release of a
Hazardous Substance, creates a condition that adversely affects the value of the Propar~y. The preceding two
sentences shall not apply to the presence, use, or storage on the Propony of small quantifies of Hazardous
Substances , ·
that are generally recognized to be appropnata to normal residential uses and to maintenance of
the Property (including, but not limited to, hazardous substances in consumer products),
Borrower shall promptly give Lender written notice of (a) any investigat/on, claim, demand, lawsuit or
other action by any gavermnentsl or regulatory agency or private party involving the Property and any
Hazardous Sabstance or Environmental Law of which Borrower has actual knowledge, (b) any
Environmeotai Condition, including but not limited to, any spRling, leaking, discharge, release or threat of
release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a
Hazardous Substance which adversely affects the value of the Property. If Borrower learas, or la notified by
any governmental or regulatory authority, or any private paxty, that any removal or other remediation of an~
Hazardous Substance affecllag the Propolly is necessary, Borrower shall promlaly take all necessary remedial
actions in accordance with Enviromnental Law. Nothing herein shall create any obligation on Lender for an
Environmental Cleanup.
NON-UNIFORM COVENANTS. Bon'ower and Lender further covenant and agree a~ follows:
22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following
Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to
acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower
of, among other things: (a) the default; (b) the action required th cure the default; (c) when the default
must be cured; and (d) that failure to cure the default as specified may result in acceleration of the
sums secured by this $~curiry Instrument, forecloanre by Judlcinl proceeding and sale of the Property.
Lender shah further inform Borrower of the right to reinstate after acceleration and the right to assert
in the foreclosure proceeding the non-ex/stence of a default or any other defense of Borrower to
acceleration and foreelo~ure. If the default is not cured as spedfled, Lender at its option may require
immediate payment in full of all sums secured by this Security Instrument without further demand and
may focedose this Security Instrument by Judicial proceeding. Lender shall be entitled to collect all
aet,~o~s,l~.curred. In p.u~.....g the.remedies provided in this Section 22, including, but not limited to,
tees ann costs ol utle e-n~ence to the extent permitted by Applicable Law.
23. Release. Upon payment of ali sums secured by this Security Instrument, this Security Instrument
and the estate conveyed shah tenulnate and become void. After such cccur~nce, Lender shall discharge and
satisfy this Security instnunent. Borrower shah pay any recordation costs. Lender may charge Borrower a fee
for releasing this Security instrament, bet only if the fee is paid to a third party for services rendered and the
charging of the fee is permitted under Applicable Law.
25. Reinstotement Period. Borrower's time to reinstate provided in Section 19 shall extend to o~e hour
prior to the comm~cement of bidthng at a sheriff's sale or other sele put,ant to ~ Security insmunent.
26. Purchase Money Mortgage. If any of the debt secured by this Security In, raiment is lent to
Bor r °~vTe. r l~t earC~q~ir~.a~t:e itoe,?l_e ~..Pr o~ _pc_ r ty: th~s~ Sectlrity insh"tlment ~ be a purchase moaey mortgage.
entered on the Nota or in an action of mor~gaga foreclosure shall be the rate payable from time to time under
the Note.
BY SIGNING BELOW, Borrower accepts and agrees to ~he terms and covenants con)alned in this
Security Instrument ~md in any Rider executed by Borrower and recorded with it.
(Se~)
(Seal) (Seal)
(Seal) (Seal)
(Seal) (Seal)
Certific~to of Residence
1, JOSH VE.~ASQOH Z
the correct address of the within-nam=d Mortgagee is
249214952
;~, do hereby certify
COMMONSArEALTH OF P/EI~SYLVANIA,
On this, the /~4~ ~lay of
undersigned officer, pemomlly appeared
known to me (or
satisfactorily proven) to he the person(s) whose name(s) is/are subscribed to the within inslnlment and
acknowledged that he/she/they executed the same for the purposes herein contained.
Tide of Officer
ADJUSTABLE RATE RIDER
(LIBOR 6 Month Index (As Published In The Wall Street Journal) - Rate Caps)
THIS ADJUSTABLE RATE RIDER is nmde this 18th day of ~HCH
2002 , and is incoi'porated into and shall be deemed to amend '
Deed of 'I~ust or S~u~ity D ,, . . and suppleraent the Mortgage,
ced (the Security Instrument ) of the same date given by the undersigned (thc
"Borrower") to secure Borrower's Adjustable Rate Note (the "Note") to
CENTEX, HOM~ EQUITY COMPANY, LLC
(the "Lender") of ~e Same dmta and covering the PCope~y described in ~he Security inst-mlant and located
CAMP HILL, PA 17011
THE NOT~ CONTAINS PRO%qSION$ ALLO~G FOR CHANGES IN
I]~I'EREST RATE AND THE MONTI~,y PAYMENT. THE NOTE LIMITS TIiE
AMOUNT ll~ BORROWER'S IiNTEREST RATE CAN CHANGE AT ANY ONE
TIME AND THE MAXIMUM RATE THE BORROWER MUST PAY.
ADDITIONAL COVENANTS. In addition to the convenaats and agreements made In the Security
Instrument, Borrower and Leader further covenant z.nd agree as follows:
A. INTEREST RATE AND MONfltLy PAYMENT CHANGES
The Note provides for an Initial interest rate of 11.750 %. The Note provides for changes in
the interest rata and the monthly payments, as follows:
4. INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Dates
The interest rate I will pay may change on the lsd: day of OL~OBER , 2002
and on that day every 6TI~ month thereafter, ach date on which my interest rate could change
is called a "Change Date.'
(B) The Index
Beginning with the fa'st Change Date, my interest ra~e will be based on an Index. The "index" is the
average of interbank offered rates for 6 month U.S. dollar-denominated deposits in the London market
( LIBOR ), as publ shed tn The Wall Street Journal. The most recent Index figure available as of the first
Modified 8~9705 / F~MA 313s (6/oa~
249214952
business day of the month immediately preceding the month in which the Change Date occurs is called the
"Current Index. '
If the Index is no longer available, the Note Holder will choose a new Index that is based upon
comparable information. The Note Holder will give me notice of ~ choice.
(C) Calculation of Changes
Before each Cha~e Date, 'the Note Holder will calculate my new interest rate by adding
· LEV~N AND 750/10§0
percentage poim(s)
( 11.750 %) to the Current Index. The Note Holder wi// then round the result of this
addition to ~he nearest one-eighth of one pe~:entege point (0.12~%). Subject to the Umits stated m Section
4(D) heinw, ~ds rnoaded amount wi/! he my new inter~t rate uatil the next Change Date.
Thc Note Holder will then determine the amount of thc month/y payment that would be su.~cieat to
rc%oay the unpaid principal that I am expected to owe at the Change Date in full on the Maturity Date at my
abo shall not exercise ~s option if: (a) Borrower causes to b~ subm/tted m Le~¢x- infomg.~og, requa~l by
a ~rea~? ~XSo,~ea~nt ? agreement in this Security Instrument ts acc~tab
agreementa made ia tl~ Not~ and in th~ Security Ir~munent. Borrower will continue to be obligated under
~he N~)~e~aadnder~ Sec~ity .hls~. nt tm]es,,Lender rele,~es Borrower in writing.
~u (97o5)
(Seal)
(Seal)
(Seal)
(seal)
(Sea/)
(Sea])
Page 3 of 3
Form 313~
SHERIFF' S RETURN -
CASE NO: 2003-02781 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CENTEX HOME EQUITY COMPANY LLC
VS
GRUCZ KATHIE
REGULAR
VALERIE WEARY ,
Cumberland County, Pennsylvania, who being duly
says, the within COMPLAINT - MORT FORE was
GRUCZ KATHIE
DEFENDANT , at 2053:00 HOURS,
at 2605 MARKET STREET
CAMP HILL, PA 17011
KATHIE GRUCZ
a true
Sheriff or Deputy Sheriff of
sworn according to law,
served upon
the
on the 1st day of July , 2003
by handing to
and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.66
Affidavit .00
Surcharge 10.00
.00
37.66
Sworn and Subscribed to before
me this Y~ day of
,, j33~3 A.D.
//Prothonotary
So Answers:
R. Thomas Kline
07/03/2003
MCCABE WEISBERG CONWAY
McCABE, WEISBERG AND CONWAY, P.C.
BY= TERRENCE J. McCABE, ESQUIRE
Identification Nuznber 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
{215) 790-1010
Attorney
for Plaintiff
Centex Home Equity Company,
Kathie Grucz
Carmen Henriquez
John Doe, Occupant
Jane Doe, Occupant
LLC :
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 03-2781 CIVIL
QRDER TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above-captioned matter discontinued and
ended, without prejudice, upon payment of your costs only.
Attorney for Plaintiff