HomeMy WebLinkAbout99-02151
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McCABB, WEISBBRG AND CONWAY, P.C.
BY' TBRRENCE J. MCCABB, ESQUIRE
Identitication Number 16496
Pirat Union Building
123 South Broad Street, Suite 2080
Philadelphia, pennaylvania 19109
(215) 790-1010
Household Finance
Discount Company
961 Weigel Drive
P.O. Box 8632
Elmhurst, IL 60126
Consumer
v,
Fred D. Carbaugh
196 Lawrence Lane
Carlisle, PA 17013
and
Judy B. Carbaugh
196 Lawrence Lane
Carlisle, PA 17013
Attorney tor Plainti:t
Cumberland County
Court of Common Pleas
qtf- ~/Sl
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Number
CIVIL ACTION/MORTGAGE FORECLOSURE
NOTICE AVISO
You have been sued In court. If you wish to defend
against the claims set forth in the following
pages, you rrust take action within twenty (20) days
after this corrplaint and notice are served, by
entering 8 written appearance personally or by
attorney and filing in writing with the court your
defenses or objections to the claims set forth
against you. You are warned that if you fail to do
so the case may proceed without you and 8 Judgment
may be entered against you by the court without
further 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
LA WYER AT ONCE, IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET HELP,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Le han demandado a usted en la corte. Sf usted
qutere defenderse de estas demandas ex.puestas en
las paginas siguientes, usted tiene veinte (20)
dias de plazo al partir de la fecha de La demanda y
La notificacion. Hace falts asentar una
corrparencia escrita 0 en persona 0 con un abogado y
entregar a La corte en forma escrita sus defensas 0
sus objeciones alas demandss en contra de su
persona. Sea avisado que si usted no se deftende,
la corte tomsra medidas y puede continuar la
demands en contra suya sin prevlo avlso 0
notfficacion. Ademas, La corte puede decldir a
favor del demandante y requiere que usted curpla
con todes las provisiones de esta demanda. Usted
puede perder dinero 0 sus propiedades U otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO
fNMEDlA T AMENTE, SI NO TfENE ABOGADO 0
SI NO TIENE EL DINERO SUFfCIENTE DE PAGAR
TAL SERVICO, VAYA EN PERSONA 0 LLAME
POR TELEFONO A LA OFICINA CUY A
D1RECCION SE ENCUENTRA ESCRITA A8AJO
PARA A VERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
4. On March 13, 1998, mortgagors made, executed and
delivered a mortgage upon the premises hereinafter described to
Plaintiff which mortgage is recorded in the Office of the Recorder
of Cumberland County in Mortgage Book 1438, Page 280,
S. The premises subject to said mortgage is described in the
mortgage attached as Exhibit "A" and is known as 196 Lawrence Lane,
Carlisle, PA 17013,
6, The mortgage is in default because monthly payments of
principal and interest upon said mortgage due November 1998 and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
7. The following amounts are due on the mortgage:
Principal Balance
Interest 10/01/98 through 03/12/99
(Plus $37.85 per diem thereafter)
Attorney's Fee
Cost of Suit
Appraisal Fee
Title Search
$115,194.48
$ 7,441.78
$
$
$
s
5,759,72
225,00
125.00
200,00
GRAND TOTAL
$128,945,98
8. The attorney's fees set forth above are in conformity
with the mortgage documents and Pennsylvania Law and will be
collected in the event of a third party purchaser at Sheriff's
Sale, If the mortgage is reinstated prior to the Sale, reasonable
attorney's fees will be charged based on work actually performed.
9. Notice of Intention to Foreclose as required by Act 6 of
1974 (41 P,S. ~403) and notice required by the Emergency Mortgage
Assistance Act of 1983 have been sent to Defendants by certified
mail on the date set forth in the true and correct copies of such
notices attached hereto as Exhibit "B,"
r
WHEREFORE, Plaintiff demands Judgment against the Defendants
in the sum of $128,945,98, together with interest at the rate of
$37,85 per diem and other costs and charges collectible under the
mortgage and for the foreclosure and sale of the mortgage property,
"'~~. 7!/df.L1
Attorney for Plaintiff
, ~ '7s-f; C, " ~
lA' .:133~.3 l._,MORT~_A~~_1
o IF BOX IS CIIIlCKIlO, TillS MORTGAla! IS AN OI'UN.UNO MORTCJAGIJ ANIJ SI!CUIUlS I'UTURU ADVANCI!S
THIS MORTGAGBis made this 13nt day 01 MARCH 19 ~. between the Mortsasor,
FRED 0 CARBAUGH
JUDY B CARBAuc;ii
(herein "Borrower"), and Mortgagee ~~j;\(iUiRi:iiAlic~a:ONSlR.4ER DISCOUNT COMPANY ,
a corporation organized and exiating urllRrI'ffilll~SYL VAN I A ,whose addreas Is
26 GATEWAY DRIVE, GATEWAY SOUARE/SlJITE 101, MECHANICSDURG, PA 11066
(herein "Lender"),
The foUowins parasuph preceded by a cbecked box is Ippliclble,
m WHEREAS, Borrower i. indebted to Lender in the principal .um 01 $ 116,194, 4B ,
CVia'enced by Borrower's Loan Repayment and Security Agreement or Sccondai'y Mortgage Loan Agreement dated
MARCH 13, 199B and any extensions or renewal. thcreol (herein "Note"), providing for monthly installments
of prinCIpal and interest, including any adjustments to the amount 01 payments or the contract ute il that rate is
varisble, with the balance 01 tho indebtedness, il not sooner paid, due and payable on MARCH 13, 202B
o WHEREAS, Borrower is indebted to Lender in the principal Rum 01 $ , or so much thereol
as may be advanced pursuant to Borrower's Revolving Loan Agreement dated and
extensions and renewals thereol (herein "Notc'), providing lor monthly installments, and intcrcsl at the rate and under
the terms specilied in the Note, including any adjustments in the interest rate ilthat rate is variable, and providing for a
credit limit stated in the principal sum above and an initial advance 01 $
TO SECURE to Lender the repayment 01 (1) the indebtedness evidenced by the Note, with interest thereon,
including any increases ilthe contract rate is variable; (2) future advances under any Revolving Loan Agreement; (3) the
payment 01 all other sums, with interest thereon, advanced in accor&nce herewith to protect the security 01 this
Mortgage; and (4) the performance 01 the covenanlS and agreemcnts 0/ Borrower herein contained, Borrower does
hereby mortgage, grant and convey to Lender and Lender's successors snd assigns the lollowing described property
oj located in the County 01 CUMBERLAND Commonwealth
of Pennsyl vanis:
AI J thet certain property situated In the township of West
Pennsboro In the county of Cumberl~nd and Commonwo~lth of
Pennsylv8nl8, being more fully described In ~ fee sImple
deed deted 0312611996 end recorded 0312B/1996, among the
lend records of the county ~nd state set forth above, In
Volume 136 Page 764,
lex Parcel 10: 46-D8-D581-014A
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07~21-97 Mort9'ge PA
.Dood.438r~GE i280
pJ.\Ocn",
OHIGINAL
..1W:: 'lm~~lnhi~~I~'IID~I~IIOOlmlllumlll'~lllmmnIllUIIU
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TOGETHER with all the improvement. """ or 1",1..rt.. om:led on Ihe property, ~nd .11 "&cm~"Iu, ~ight"
appurtenane"" and renl", ftll of which th,1I \", deemed III he and re",.i" . p.rt of the property covered by'thift
Mortgage: and all of Ihe fureguing, lo~.Iher with r.aid property (or Ihe I....hold ealate if this Mortgage i. on a
leasehold) are hereinafter referred to as the .Pror"'rty:
, ,. Borrower cOvenanw that !Jorrower is lawfully vei.cd of the ..tate hereby conveyed and has the right to mortgage,
grant and convey tho Propert)', and t""t the p'operty i3 unencumbered, ueept for encumbrances of record, Borrower
co~cit8ii1s ihat Borrower warranlD and will dc!elld generally the title to the Property againet all claims and demands,
.. SUb!cc'ltO.',cncuiribranccs' of r<<ord, ., .
;' 'UNIFORM COVENANTS, Dorrower and Lender covenant and agree an C"llows:
I, Paymcnt of Principal and Inlcrest al Variable Rates, This mortg.ge secures sll paymenw of principal snd
inlerest due on s variable rate loan, The contract rale of interest and payment amoun13 may be subject to change as
provided in the Note, Horrowers chall promptly pay when due all amounts required by the Note,
2. Funds Cor Tales and Insurance, Subjoctto applicable law or waiver by Lender, Borrower shall pay to Lender
on the day monthly payments of principal and interest are payab:e under the Note, until the Note is paid in full, a
sum (herein .Punds") equal to one'we!rth of the yearly tales and assessments (including condominium and planned
unit development assessments, if sny) which may attain priority oVer this Mortgage snd ground rents on the Property,
if any. plus one-twelhh of yearly premium installments for hazard insurance, plus one1wel!th of yearly premium
" installments-for,mortgaze insurance,Jf,any, ,~l! AS r~""bly ~imated initially and from time to time by Lender on
the basis of assessments and bills and reasonable estimates thereal, Borrower sh.1l not be obligated to 'make. such
payments of Funds to Lender to the eltent that Borrower malcea such payments to the holder of a prior mortgage or
deed of trust if such holder is an institutional lender.
If Borrower pays Funds to Lender, the Funds shall be held in an institution the deposits or accounts of which are
insured or Guaranteed by a Federal or stale agency (including Lender if Lender is su<:h an institution). Lender shall
spply the Funds to 'pay said tales, assessments, insurance l'remiums and ground rents. Lender may not charge for so
holding: and applying'the Funds, analyzing said account or verifying and Compiling said IISSCS8ments and 'bills, unless
Lender pays Borrower interest on the Funds and applicable law, permits Lender to make such a charge, Borrower and
l.!:I1d,er ,m~y agree in writing at the time of elecution of this Mortgage that' interest on the Funds .shall be paid to
llOrrbwer, and unless suchagrccment is made Or applicable.law requires su<:h interest to, be paid, Lender shall not .be
r.;quiiiidi? iia/:ilorrower' any !nterest or earnings on' ~e Funds; Lender.shall give to Borrower, without charge, an,
annual.crountin): of the Funds sho\,!ingcredits and, debits to the Funds and the purpose for whieheach,debit,to,the
Funds was made; The Funds arc pledged as additioWlI security for the sums secured by this Mortgage" .
If the amount 'oC the Funds held by' Lender, togellitr with the future monthly installments of Funds'payable prior to.
the due dates of taxes; ..':scssments, insurance premiums and ground rents, shall elceed the amount required to pay'said
taxes, asseSsments, insurance premiums and ground rents as they fall due, such excess shall be, at Borrower's option,
either promptly repaid to Borrower or credited to Borrower on monthly installments oC Funds, If the amount of the
Funds held by Lender shall not be sufficient to pay taxes, assessment_, insurance premiums and ground rents as they
fall due, Borrower shall pay to Lender any amOUnt necessary to make up the deficiency in one or more payments as
Lender may req::ire.
Upon payment in full of all sums secured by this Mortga.c, Lender shall promptly relund to Borrower any funds
held by Lender"lf under paragraph 17 hereoC the Property is sold or the Property is otherwise acquired by Lender,
' '.Lcnd;'r shail:'apply;'no'laterthan 'immediately prior to,!he sale of the Property odt.s acquisitj,o!,. by l,c,nd~r,a,ny .Funds
held by Lender at the time of application as a credit against the sllms secured by this Mortgage, '
3. Application of Payments, Except Cor loans made pursuant to the Pennsylvania Consumer Discount Company
Act, all payments received by Lend"r under the Note and paragraphs 1 and 2 hereof shall be applied by Lender first in
payment of amounts payable to Lender by Borrower under paragraph 2 hereof, then to interest, and then to the
principal.
4. Prior Mortgages and Deed of Trust; Charges; Liens, Harrower shall perform all of Borrower's obligations
under any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage,
including Borrower's covenants to make payment!: when due. Borrolo'er shall pay or. cause to be paid aU, taxes,
assessments and 'other charges, fines and impositions attributable to the Property which may attain a priority over this
Morlgage, and leaschold'paymenw or ground rents, if any, ' .
.5; Hazard)nsurancc, Borrnwer shall k"'1> the improvements now existing or herealter erected on the' Property
. j.~.s~.r~ ag.~i~fit Io..<;s by fire, hazard'i ,included wi.thin the term "extended cove:rage," and such other hazards as Lender
.. may reqUJrc. . .
Tile .insuri:ince carrier providIng the insurance shall be chosen by the Borrower suhject to approval by Lender;
provided, that such approval shail not be unreasonably withheld. All insuraoce policies and renewals thereof shall be in
a form ac("~;)table tn J.I.~nd~r andrf~~V~\1 iQ~I.u.de:.3;.st;andat:'d mortgage clause in favnf ('~ hnd in Jt form acceptable to
Lender. I.'("1!der shali have the right to'hola the: 'polh:ies'.and renewals therr.::::of. suojt."Ct to the tt:rrns of any mortgage,
deed of tru....! or otile:- f:~curity l1grccment with a lien T,..,hich has priority Over this J"fort~i1gc.
07-21-97 Mort~.g. ,'A ';;'" :,i,.; ',' ' . . .BOOd438m~ a8t PA001242
CHIt INt...
IIUlI~ II ~mlll~~II~1 !IIIIIII~ ~~III~llmn milIa 1m 100 11118 ~~
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!n the hent nr Iwe:, Borrower ,h,1I give prompt notice 10 th. in,,,,.,,,. r,mi.r .nd Londer. Lerrder may make prool
or 1_ il nol m.,le I'lOmplly by lIorrower,
If the ProperlY i. abandoned by Borrower, or il lIorrower lail. In re::polld 10 Lender Wilhill 30 day. Irom the d.le
notieo is mailed by Lender to Ilorrower Ihatlhe insurance carrier oUem to IlCllle . claim lor iosunn:e bellelils, Lender ia
aothorized to oollect and apply lho Illlloranee proceed. all..cnder'" oplioll eilher 10 r..lonlion or rep.ir 01 the ProperlY or
to ,tho auma lII:C\lred by Ihi. Mortgage,
6, Preservition and Malnlenallce 01 Property; Leueholds; Condominioms; Plaoned, Unit Developments,
Ilorrower ohall keep the Property in good repair and ""ollllot commit waste or permil impairmenl or delet:ioration 01
Ihe Property and .hlll comply with the prnvitions 01 any lUGe ir this Mortgage is on a leasehold, IIthi. Mortgage is on
a unit in A condominiom or a planned unit development, Borrower nhall perlorm .all or Borrower'. obligations under
tho declaration or covenants crOll ling or governing tho eondominiom or plannod unit dovelopment, Ihe by-laws and
regulations 01 lh. condominium or plannod unit development, snd constituent doc:umenls,
7, Prolecllon 01 Lender', Security. If Ilorrower fails to perlorm the covenanls and agreements contained in this
Mortcace, or if Iny action or proc;eccling i. commenced which materially afleets Lender's interest in th. Property, then
Lender, at Lender's oplion, upon notice to Borrower, may make such appesrances, dioburse ouch sums, Including
reasonabte allomeys' ICC8, and talc. such action as is necessary to protect Lender's interest.
Any amoonl.. disbursed by Lender pursuanl to this paragraph 7, with interest thereon, al the contract rale, shall
become addi,tiona1. indebtodllCSS 01 Borrower secured by this Mortgag., Unless !Jorrower",and Lender agree, te;> other
term's 01 'payment,such'omoon18 shall be payabl. upon notic. Irom Lender to Borrower requesting payment thereof,
NOlhing contained in this paragraph 7 shall require Lender to incur any expense or take any action hereunder,
'8, Inspection, Lender moy take or cause to be mad. reasonable entries upon and inspections of the Property,
provided that Lend.r shall give Borrower nOlic. prior 10 any soch inspection specilying reasonable cause therelor
related to Lend.r's int.rest in Ihe Property,
9. Condenmotion, Th. proceeds 01 any award or claim lor damages, direct or consequentisl, in conneet,ion wilpany
condemnation or oth.r taking of th. ProperlY, or part thereof, or lor conv.yance in lieu 01 condemnation; are her.by
assigned snd shall be paid to Lend.r, sub~t to the .term. 01 any morlgage, dcedol trost or other security o~m.nt
with ..'lien which has priorily over'this Mortgag.. ' ," ' .. , ." ' " . . , . . ' .
. -'IO/Borrower ,Not Releas.d;Forbearance By Lender, Not a Waiver, Extension of the time lor 'paym.ent or
modilicatiOli' of amortization. 01 ,the' sums secured 'by,this Mortgage granted by Lender to any oUcCesSor in interest of
. Borrower 'sliaU:oot operate 10 release, in any mAM.r, the liability 01 the original Borrower and 'Bo,rrower's. su~c,essors
in interest. Lerider'shall not be required to, comm.ncc 'proc:cedings against such suecessor or r.luse tci:eitend time' Cor
. : p;;ym.ilt"or olherwise modily' amortizalion of Ih. sums secured by Ilus Mortgage by r.ason 01 any demand mad. by
th. 'o~iginal Borrower and Ilorrower's successors in inlerest, Any lorbearanc. by Lend.r in .xercising .ny right or
r.medy her.under, or olherwis. afCorded by applicable law, shall not be a waiver 01 or preclude the exercise 01 any
such right or renledy,
II. Successors and Assigns Bound; Joint aDd Several Liability; Co.signers, The covenants and agreements
herein containod shall bind, and the rights her.under shall inure to, the respective soccessors and assigns of Lender and
Borrower, subject to the provisions of paragraph 16 hereof. AlJ covenants and agreements of Borrower shall be joint
and sev.ral. Any Borrower who co'signs this Mortgage, but'does not execute the Note, (a) is co.signing this Murtgage
only to mort~ag', granl and convey that Ilorrow.r's interest in the Properly to L.nd.r under the terms, '01 this
Moi'lgage, (b) is not personally liable on the Not. or ,und.rthis Mortgag., and (c) agrees thaI Lend.r and .sny 'olher
Borrower her.ond.r may agree 10 <xt.nd, modify, lorbear, or make any olher accommodations wilh regard to th.
terms of this Mortgag. or the Note without that Ilorrower's consent and withoul releasing that Borrower or modilying
this Mortt:Jge as to that Borrower's Interest in the Property,
12, Notice, Except for sny notice reqoired under applicabl. law to be giv.n in another manner, (a) any notic. to
Borrower provided for in this Morlgage shall be given by dclivering it or by mailing such notice by c.rtified mail
addressed to Borrower at the Property Address or at such other address as Borrow.r may designate by notice to Lender'
as provided herein, and (b) any notic. to Lender shall be given by certilied mail to Lender's address stated herein or to
such other address as Lender may designate by notice to Borrower as provided hcrcin, Any noticc provided Cor in Ihis
Mortgage shall be 'deemed to have been given to Borrower or Lender when given in th. ",anner designated herein,
t3. Governing Law; Sevcrability. The slato and local laws applicable to this Mortgage shall be the' 'laws 01 th.
jurisdiction ili which Ihe Property is located, Tire, foregoing 60ntence shall not Ii mil tire "pplicability'of Federal law to
this Mortgage, In the event that any provisio~ or clause of this Mortgage or the Note conflicts withapplieable law" such
conflict shall not aflect other provisions of this Mortgag. or the Note which can be given eflect withoullhc.'confhcting
provision, and to this end the provision" of this Mortgage and the Note arc declared to be severablc,':A,s used herein,
"costs,"' "expenses" and "attorneys' fees", includ. all sums If) the extent, not prohibiled by 'applicable law or. Iimiled
herein.
'14. !lorrow","s Copy, Borrower shall be furnished a conformed copy of the Note and of this Mortg~ge at the tim.
of e,ecut'on or af",r rccor~ti~!, he!;:-;\~f"'~"" " ' Bood438PAG[ .282
01-21-97 "'"'''' f''-, OR~j~ll'" '. "'. ,111~~I~mlll[~'IIU:IliMli~I\IIIII~~lllllIInIIIMm[lllilll~~mllII PM012<3
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IS, R.habilllalion I.o.n Acrecmenl. Borrower _h.1I 1"llill all 01 Ilorrowcr'. ohllGalillM 'IIIder-any homo
rehabilitation. improvement, rep"ir, or ot!l('r 10:l.n agreement whi..:h Horhiwtr enter,. into with Lender, Lender. at
Lender's option, mllY require Borrower tu ~xecuttl and deliver 10 l..entJrr, in I form Icupable to Lender, an aaoignmcnt
of .ny rights, claim. or defcnllC8 which Borrower may h.vo aGaiocI parti.., who lupp1y labor, mal.ri.l. or IlCrviCC3 In
cOMerclion Wilh improvements made 10 Ihe Property,
16; Transfer of lh. Properly. If Ilorrower sell. or Iran.fer. .11 or .ny part of Iho Properl)' or an inler..1
therein, excluding (a) Iho crealion of a lien or encumbrance sUbordinale 10 Ihis Morlg.ge, (h) 0 Ir.""fer by dovise,
descenl, or by "peralion 01 law upon the deuth 01 . joinllenant, (c) lhe grant of any ItlollChold inlUest of Ihroc years or
less nOI cootaining an oplion 10 purd",." (d) tho creation "I . purdlaLc money securily inlerost for hnusehold
applisnces, (c) . transler' 10' relalive resulling Irom .Ihe death 01 . Borrower, (I) a lranslcr where Iho spouse or
children of lhe Borrower become an OWner 01 lho property, Cg) a lransler resultins lrom a deeree of di=lution 01
marriage, legal ooparation agreement, or lrom an incidental property selllcmenl .greement, by which Iho spouse of tho
Borrower becomes an owner of lhe properly, (h) a transfer into an inter viv"" lrusl in which the Borrower is and
remains a beneficiary and which dOCD not relolo to a transler of righ~; 01 occupancy in tho property, or (i) .ny other
transfer or disposition described in regulatiollS prescribed by the Federal Homo Loan &ok Board, Borrower shall
cause to be submitted informalion required by Lender to evaluate tho lransleree III if a new loan were being made 10
the transferee, Borrower will continue 10 be obligated under Ihe NOle and this Mortgage unless Lender releases
Borro,wer iq !yriting, ,
If Lender docs nol agree to such saie or transCer, Lender may doclare all 01 Ihe soms secured by this Mortgage to be '
immedialely due and payable, If Lender exercises such option ,to accelerale, Lender sbaJl mail Borrower nOlice of
acceleralion in accordance wilh paragraph 12 hereol. Such nOlice Shall provide a period of nOI 1= lhan 30 days from,
the dale tho nOlice is mailed or delivered within whi9h Borrower may pay Ih. sums declared due, If Borrower fails to
pay such sums prior to Ihe expiralion oC such period, lender may, "ilhoul Curlher nulice or demand On Borrower,
invoke any remedies pcrmilled by paragraph 17 hereof,
NON-UNIFORM COVENANTS: Borrower and lender furlher covenant and agree as follows:
17. Acceleration; Remedies, Except as provided in paragrapb 16 bereof, upon Borrower's breach of any
covenant or agreement of Borrower in tbls:Mottg.ge, including,the covenanls la, pay .when due any sums
- sCcurc'c!-bY- this.'Mortgage;' render' prior '10 'aecelerallonsbal1 give notice to Borrower as pxovided in
" paragraph "12 'bereof 'specifying: (I) the ,breacb;- (2) ,th., action, required"to Cure sucb bre.eb:, (3) ,&-d.te,-Dot .
,Iess.tban 30.-days,from,tbe date the,n()ti,Ge i,5o maiJe,dtoJlprr.owGr, ,b,y,l'h,il<h,sueb breach must be cured;;'and
(4) tbat failure to, c,ur,e. sucb breach on o.r b.lore the date specified ,in :the ,notice.- may rcsultin acceler.ation
01 tho sums secured by this Mortgage,' foreclosure by judicial proceeding, and sale CJl the Property.' Tbe .
notice sball furlher inform Borrower of tbe right ,10 reinstate afler acceleration and tbe rigbt to assert in tbe
foreclosure proceeding the nonexistence of a default or any other deCense or Borrower to acceleration and
foreclosure. If the breach is not cured on or before the date specified in the notice, Lender, at Lender's
option, may declare all of the sums secured by this Mortgage 10 .be immediatoly due and payabie withoul
lurther dcmaud and may loreclose this Mortgage by judicial proceeding. Lender shall be entitled to collect
in sucb proceeding all expenses of foreclosure, including, but not limiled to, reasonablc atlorneys' fees and
costs or documentary evidence, abstracts and title reports. .
18, Borrower's Rigbt to ,Rcinslatc, NOlwithstanding Lender's acceleralion of the sums by Ihis Mortgage due to
Borrower's. breach, BOrrower ,shaU: have the,rjght, tQ lil!ve any ,proceedings, begun by Lender t.o. enlorce this Mortgage
disconti'iiUedal any 'lime prior 10 enlry of a 'judgment 'enforcing itiis Mortgage if: 'Ca) Borrowerpay,d':'i1der al1"sums
which would be then due under this Morlgage and the Note had no acceleration occurred; (b) Borrower cures all
breaches of any other covenants or agreements of Borrower contained, in this Mortgage: Cc) Borrower paYll,: all
reasonable expenses incurred by Lender in enforcing the covenant::; nnd agreemt:nt!i ot Borrower contained in ,.this;.,
Mortgage, :",d in enforcing Lender's remedies as provided, in paragraph 17 hcreof, including, bUI not-limited .to:".'i'~
reasonable atlorneys' fee::;; and (d) Borrower takes such action as lender,may reasonably require to assure that the lien "
oC this Mortgage, Lender's inler,,"t "in the Property and Borrower's obligation to pay thc sums secured by this Mortg~gq .::
shall continue un,impaired, Upon such paym.ent and cure ,by Borr.ower, this Mortgage and thc oblig~tio~,~~~;/
hereby shall remalD lD full force and effecl as 1f no acceleration h.d occurred, ,>,:.,;...",~~ "..'
19. Assignment of Rents; Appointment of Receiver, As addilional security hereunder, Borrower: heiebY'a~fgrlS
t.o Lender the rents :of. the Property, provided'ihat Borrower shall, prior. tQ acceieration under paragraph'17',hCl'oof, in
abandonmenl 01 the Property, have the right ,to collect and retain such rents as they become due and payable,
," Upon 'acceleration 'under paragraph 7' her<;of or'abandonment oC the Property: Lender shall, be ,entitled to ,have a
receiver appoinled by a court t.o enter upon" take possessio" of and man~gc the Property and to colleet the rents of the
Property including those past due,' AlI r"~ts'collected 'by tne receiver shall be opplicd first to payment oC the costs of
management of the Property and collection of rents, including, but not limited t.o, re(',.iver'r. fee:::, premiums on
n."Ceivcr's bonds Ctnd reasonabit attorney};' f::(;'~1 and then tll the SUms secured by thi!; Mortgage. The receiver shall be
luthlc to account only, for .tbose rr;nt..';,;ictua!ly receLvt:d,
07-2t-97 Mortg.ge PI. ';',r.,:;" ;',"''-:. ,',' ',":0 ,eg(j~i438r,'GE 283' PA001244
(ll,;1.1N;iL
I WJJIII~IIIIIIIII'IIII!II:II!I ~llim W/J ill!~11111II ~~W ~II iUll ~ 1If. ml ill U
-5-
.
~20, Relnse. Upon payment or all .um. oecurcd by lhi" Mnrtt>ge, t.ender sh.1I rrl..~ ,hi~ Morlg.~ without c!urge
to Borrower, Borrower shall pay all costs of rccord~tion, if any,
21. W.lver of 1I0me.le.d, !lorrower hereby ....iv~ oil ritht of homestead exemption in the Propeny under ol.ue
M~~ . ,
, 22, IDle~esl Rale Afler Judgmenl, Borrower .grees the interesl rale pay.ble .lter a judsmenlla eniered on Ihe
NOlo orin .n .clilln of mong.So foreclosure .hall be,the rate stated in,lh~,Nole, , " ; , ;, ..':, '
.. .'
...'1'. .
REQUEST FOR NOTICE OF. DEFAULT
AND FORECLOSURE UNDER;SUPERIOR
MORTGAGES OR DEEDS OF:rRUST'
"
Borrower and Lender requesl the holder of any morts.se, deed of trust or olher eneumbranco with a lien which has
priorily over this Morlgago to give Notice to Lender,.1 Lender'o addr... sel forlhon page Olle of thia MOrlsage, or any delault
under the superior eneumbranco and of any sale or other foreclosure action,
, .'
'1d[),C;~
FRED"D CARBAUGH -Borrow.,
........
-Borrowor
I hereby ~erlifythat the precise a.ddress of the Lender (M?rlgagrie):is: :'H.O:II!;~HO,I 0 I'TNANCF
. , . . .. . .'. .. . . . .
. " '.,' 25 'GATFWAY, ORTVF "MFr.'HANj'r.'!iRIIRr.': PA ',17'110;0;:' ,. "'.' .
.On behalrof,theLender;By: , ."MATT "HERMAN,. ". :'.',::.,,' ,:' .. ,,,Tille: BRANCH ";tANAGER
COMMONWEALTH'OFPENNSYLVANIA; ',;' (A,;.~,Iq,>V:!., " .: Coun\Yss:.."',.
. , . \. .
,
I,' 'ANNE 'A STAFFORD ,0 NotarY Public iri and for said county and statc, do hereby ccrlifythat
FRED 0 CARBAUGH & JUDY B CARBAUGH
personally lenown to me to be Ihe same person(s) whose name(.) 'are subscribed to the foregoing instrument,
appured before me Ihis day in person. and acknowledge that _th<;,~ signed and delivered the said instrumenl as
. the ir free voluntary acI, for the uses and purpoo;es therein sel forth.
Given under my hand and official seal, this
My. Commi~on ekpires: .
13th day of MARCH
,19.llB....
'~~.t? ~
Notary, he
NOTAR,IAL SEAL
ANlIe A, STAFFORD
PA 'COMMISSiOnER OF DeEDS
MY COMMISSion EXPIRES APRil 02, 2001
JhiS inslrumenl was prepared by:
~I!~~
, HOUSEHOLD FINANCE CORPORATlO~
. .25 Gateway Drive, Suite 107 . ' .
~cmlCSburg,pb..ld1.;r055 ' ._, ..
.;.. .1,.
(Space Below This Lint:! ReliervedFor Le.~do; end Recorder) .. ..,. ....
Return To:, ".. ,
, HouSehold Firiance Corporation.
577 Lamont Road
Blmhu"", II. 60126
...,':/;,
. j.
..':.. ....
07-21-97 Mortgege PA
. .BOOK1438 r~E284:,
ORIGINAL
, I~~ 1m ~I~ ImmOOIIl~~~~1 ~I i~1 ~~llimmHumm~IIUllm~~
':. ." ".'. . . -_.~."....-.,~..". ~,........... .~. . ~ -~ _." ., ,,, .~.j....... ."..~.."_. . . . -............-~
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 mort9aa~ is in default because you have failed to pay
promptly installments of princioal and interest, as required, for
a period of at least sixty (60) days, The total amount of the
delinquency is $3553,60, That sum includes the following:
principal and interest,
Your mortgage is also in default for the fOllowing reasons:
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 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 your application
and will submit your completed application to the Pennsylvania
Housing Finance Agency. Your application mus;:: f~;.:~ ~~
postmarked, within thirty (30) days of vour face-t - c~ in
It is extremely important that you file your application
promptly, If you do not do so, or if you do not follow the other
time periods set forth in this letter, foreclosure may proceed
against your home inunediately.
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 ao~lication is accurate
and comolete 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
proceeding will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by
that 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 number (717) 780-3800 or 1-800-342-2397 (toll free
number). Persons with impaired hearing can call (717) 780-1869,
In addition you may receive another notice from this lender
under Act 6 of 1974, That 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
TERRF.NCEJ,McCADE
I.AWOmns
McCABE, WEISBERG & CONWAY, P.C.
SUITI; lOIO
FIR.H UNION DUllI>lNO
III SOUTII OROAD STREET
PIIII.ADI'I.PIIIA. PENNSYI,VANIA 19109
IlIll79O.1010
FAX Illl) 790.ll74
SUITE 600
ll611ADllON AVENUE
WESTMONl', NIOIIOI
(609) 111-7010
"AX (609) 851.70l0
SUITE 1211
lOO FIFTIl A VENUE
NEW YORK, NY 10110
(2Il) m.IOIO
FAX (212) m.2l37
January 26, 1999
Fred D, Carbaugh
196 Lawrence Lanes
Carlisle, PA 17013
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
PLEASE READ ALL OF THIS NOTICE
LENDER: Household Finance Corporation
ACCOUNT NUMBER: 713303 - 00 - 965131
REAL ESTATE: 196 Lawrence Lanes, Carlisle, PA 17013
Dear Fred D, Carbaugh:
The MORTGAGE held by Household Finance Corporation
(hereinafter we, us or ours) on your property located at 196
Lawrence Lanes, Carlisle, PA 17013 IS IN SERIOUS DEFAULT because
you have not made the monthly payments of $1184.40 for the months
of November, 1998 through January, 1999, and/or because of this
failure to remit,
Late charges, and other charges have also accrued to this date
in the amount of $N/A, The total amount now required to cure this
default, or in other words get caught up in your payments, as of
the date of this letter is $3553,60,
You may cure this default within THIRTY (30) DAYS of the date
of this letter, by paying to us the above amount of $3553,60 plus
any additional monthly payments and late charge 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
Household Finance Corporation
961 Weigel Drive
Elmhurst, IL 60126
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, I have been instructed to start a lawsuit to foreclose your
mortgaged property, If the mortgage is foreclosed, your mortgaged
property will be sold by the Sheriff to payoff the mortgage debt,
Once this matter is referred to me for suit, but you cure the
default before I begin legal proceedings against you, you will
still have to pay the reasonable attorney's fees, actually
incurred, up to $50,00, However, if legal proceedings are started
against you, you will have to pay the reasonable attorney's fees
even if they are over $50.00, Any attorney's fees will be added to
whatever you owe, which may also include reasonable costs, If you
cure the default within the thirty day period, you will not 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 mortgage, If you have not
cured the default within the thirty 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 Foreclosure Sale, You may do so by paying the total
amount of the unpaid monthly payments plus any late or other
charges then due, as well as the reasonable attorney's 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 Sale could be held would be
approximately 5 months,
A notice of the date of the Sheriff Sale will be sent to you
before the sale. Of course, the amount needed to cure the default
will increase the longer you wait, You may find out at any time
exactly what the required payment will be by calling the following
number: 1 (800) 846 - 7510, Ext. 7767. This payment must be in
cash, cashier's check, certified check or money order and made
payable to us at the address stated above,
You should realize that a Sheriff's Sale will end your
ownership of the mortgaged property and your right to remain in it.
If you continue to live in the property after the Sheriff's Sale,
a lawsuit could be started to evict you.
You have additional rights to help protect your interest in
the property. You have the right to sell the property to obtain
money to payoff the mortgage debt, or to borrow money from another
lending institution to payoff this debt. (You may have the right
to sell or transfer the property subject to the mortgage to a buyer
Tl!RRENCE I McCAIII!
I.A W OITICr:S
McCABE, WEISBERG & CONWAY, P.C.
SUITE 2010
fiRST UNION IllJll.lllNO
12l SOUTII nROAIl STRI:I:T
PIIll,AIlEI.PIIIA, PI:NNSYI.VANIA 19109
(2Il) 79{).1010
fA" (21l) 790.1274
SUITE 600
21611AIllXlN AVI!NUP.
WESTMONT. NI 01101
(609) 1lI.7010
.'A" (609) IlI.mO
SUITE l22l
loo flFTII A VENUE
NEW YOR~. NY 10110
(212)m.1010
FAX (212) "'.2'l7
January 26, 1999
Judy B. Carbaugh
196 Lawrence Lanes
Carlisle, PA 17013
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
THE COMMONWEALTH OF PENNSYLVANIA'S
HOMEOWNER'S 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
au derecho a continuar viviendo en su caaa, Si no comprende el
contenido de esta notificacion obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance
Agency) sin cargos al numero mencionado arriba, Puedes ser
elegible para un prestamo par el programa llamado "Homeowner' a
Emergency Mortgage Assistance Program" el cual puede salvar au caaa
de la perdida del derecho a redimir su hipoteca,
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
TO:
FROM:
RE:
Judy B. Carbaugh
Terrence J, McCabe, Esquire
Premises: 196 Lawrence Lanes, Carlisle, PA 17013
Account Number: 713303 - 00 - 965131
You may be eligible for financial assistance that will prevent
foreclosure on your mortgage if you comply with the provisions of
the Homeowners' Emergency Mortgage 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 this 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 (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 the Household
Finance Corporation representative is as follows:
T. Johnson
Household Finance Corporation
961 Weigel Drive
Elmhurst, IL 60126
1 (800) 846 - 7510, Ext, 7767
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 mortaage 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 $3553.60. That sum includes the following:
principal and interest.
Your mortgage is also in default for the following reasons:
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 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 your application
and will submit your completed application to the Pennsylvania
Housing Finance Agency, Your Appl ication must he 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 the 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 imoortant that your application is Accurate
and comolete in everY resoect, The Pennsylvania Housing Finance
Agency has sixty (60) days to make a decision after it receives
your application. During that additional time, no foreclosure
proceeding will be pursued against you if you have met the time
requirements set forth above, You will be notified directly by
that 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 number (717) 780-3800 or 1-800-342-2397 (toll free
number), Persons with impaired hearing can call (717) 780-1869,
In addition you may receive another notice from this lender
under Act 6 of 1974, That 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
TERRENCE J, McCAIII:
I.AW OffiCES
McCABE, WEISBERG & CONWAY, P.C.
SUITI: 2010
fiRST UNION DUII.DINO
12) SOUTII DROAD STREET
PIIII,AI>E1,PIIIA. PI!NNSVLVANIA 19109
(215) 790.1010
FAX (21l)790.ll74
SUITE 600
21611ADOON AVENUE
WESTMONT, NJ 01101
(609) 1l1.7010
FAX (609) 15I.70l0
SUITE SllS
500 flFTII AVENUE
NEW YORK, NV 10110
(lI2) 575.1010
FAX (2Il) 575.2537
January 26, 1999
Judy B. Carbaugh
196 Lawrence Lanes
Carlisle, PA 17013
NOT~CE OP INTENTION TO PORECLOSE MORTGAGE
PLEA8E READ ALL OF THIS NOTICE
LENDER: Household Finance Corporation
ACCOUNT NUMBER: 713303 - 00 - 965131
REAL ESTATE: 196 Lawrence Lanes, Carlisle, PA 17013
Dear Judy B, Carbaugh:
The MORTGAGE held by Household Finance Corporation
(hereinafter we, us or ours) on your property located at 196
Lawrence Lanes, Carlisle, PA 17013 IS IN SERIOUS DEFAULT because
you have not made the monthly payments of $1184.40 for the months
of November, 1998 through January, 1999, and/or because of this
failure to remit,
Late charges, and other charges have also accrued to this date
in the amount of $N/A, The total amount now required to cure this
default, or in other words get caught up in your payments, as of
the date of this letter is $3553,60,
You may cure this default within THIRTY (30) DAYS of the date
of this letter, by paying to us the above amount of $3553,60 plus
any additional monthly payments and late charge 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
Household Finance Corporation
961 Weigel Drive
Elmhurst, IL 60126
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, I have been instructed to start a lawsuit to foreclose your
mortgaged property. If the mortgage is foreclosed, your mortgaged
property will be sold by the Sheriff to payoff the mortgage debt,
Once this matter is referred to me for suit, but you cure the
default before I begin legal proceedings against you, you will
still have to pay the reasonable attorney's fees, actually
incurred, up to $50.00, However, if legal proceedings are started
against you, you will have to pay the reasonable attorney's fees
even if they are over $50,00, Any attorney's fees will be added to
whatever you OWe, which may also include reasonable costs, If you
cure the default within the thirty day period, you will not 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 mortgage, If you have not
cured the default within the thirty 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 Foreclosure Sale, You may do so by paying the total
amount of the unpaid monthly payments plus any late or other
charges then due, as well as the reasonable attorney's 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 Sale could be held would be
approximately 5 months.
A notice of the date of the Sheriff Sale will be sent to you
before the sale. Of course, the amount needed to cure the default
will increase the longer you wait, You may find out at any time
exactly what the required payment will be by calling the following
number: 1 (800) 846 - 7510, Ext. 7767. This payment must be in
cash, cashier's check, certified check or money order and made
payable to us at the address stated above,
You should realize that a Sheriff's Sale will end your
ownership of the mortgaged property and your right to remain in it,
If you continue to live in the property after the Sheriff's Sale,
a lawsuit could be started to evict you,
You have additional rights to help protect your interest in
the property, You have the right to sell the property to obtain
money to payoff the mortgage debt, or to borrow money from another
lending institution to payoff this debt. (You may have the right
to sell or transfer the property subject to the mortgage to a buyer
.
,
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-02151 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS,
CARBAUGH FRED D ET AL
ROBERT FINK , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND COMPLAINT IN was served
upon CARBAUGH FRED D the
defendant, at 15:20 HOURS, on the 14th day of April
1999 at 196 LAWRENCE LANE
CARLISLE, PA 17013 ,CUMBERLAND
County, Pennsylvania, by handing to FRED CARBAUGH
a true and attested copy of the NOTICE AND COMPLAINT IN
together with MORTGAGE FORECLOSURE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So a?~~~
K. !homas K!ine, ~herlfr
18,00
3.72
,00
8,00
$'<:1, 1'<
MCCABEi WEISBERG & CONWAY
04/15/ 999
by ~~d~-C-
Sworn and subscribed to before me
this {11-:J~ day of -/J-pv-i (
19 C;1 A.D.
~