Loading...
HomeMy WebLinkAbout99-03010\a C HOMEAMERICAN CREDIT, INC. d/b/a UPLAND MORTGAGE By: Robyn L. Brown, Esquire - Attorney No. 74894 111 Presidential Boulevard - Suite 128 Bala Cynwyd, PA 19004 (610) 668-2440 (610) 617-4967 (Telecopy) HOME AMERICAN CREDIT, INC. d/b/a UPLAND MORTGAGE Bala Pointe Office Centre 111 Presidential Blvd., Suite 128 Bala Cynwyd, PA 19004, Plaintiff, V. ROBERT F. SPANGLER 26 and 28 East Simpson Street Mechanicsburg, PA 17055, and ALETA A.SPANGLER 26 and 28 East Simpson Street Mechanicsburg, PA 17055, Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS TRIAL DIVISION NO. 99-3010 Defendants. PRAECIPE TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly Settle, Discontinue and End the abo aptlor`d matter wi out Prejudice. ?vE AN BUSINESS CREDIT, INC. BalaPointe Office Centre 11 I Presidential Boulevard, Suite 103 Bala Cynwyd, PA 19004 Attorney for Plaintiff 1:\LLGAI.\H AC\4pangicr\plcad\I'ItAS DS GI XK ?- o. ?: L 1? C :?__r ?l% . C ?!'? . ij. ., __ .?. -1 ?? :? ? ?iA ?"?? .. 1 _7 ' tS, ? .? 1- ?,iliU ? G , 11.. C•t V O HOMEAMERICAN CREDIT, INC. d/b/a UPLAND MORTGAGE By: Benjamin Reich, Esquire - Attorney No. 54439 Robyn L. Brown, Esquire - Attorney No. 74894 111 Presidential Boulevard - Suite 128 Bala Cynwyd, PA 19004 (610) 668-2440 Attorneys for Plaintiff (610)617-4967(Te1ccopy) ------------ HOMEAMERICAN CREDIT, INC. CUMBERLAND COUNTY d/b/a UPLAND MORTGAGE COURT OF COMMON PLEAS Bala Pointe Office Centre TRIAL DIVISION I I I Presidential Blvd., Suite 128 Bala Cynwyd, PA 19004, NO. CJ9- 3O/U C' TG Plaintiff, V. ROBERT F.SPANGLER 26 and 28 East Simpson Street Mechanicsburg, PA 17055, and ALETA A. SPANGLER 26 and 28 East Simpson Street Mechanicsburg, PA 17055, Defendants, NOTICE COMPLAINT - CIVIL ACTION AVISO 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 defenses or objections to the claims set forth against you. You arc warned that if you fail to do so the case may proceed without you and ajudgment 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 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 LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249.3166 (800) 990-9108 Le ban demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en ]as paginas siguientes, usted tiene viente (20) digs de plazo al partir de la fccha do la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objecliones a ]as demandas en contra de so persona.. Sea avisado clue si usted no se defiende, la torte tontara medidas y upedc continuer la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la cone pucdc decidir a favor del demandanle y requiere que usted cumpla con todas las provisioner de esta demanda. Listed pucdc pcrdcr dinero o sus propiedades u otros dercchos importantes pars usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SINOTIENEABOGADO0SI NO TIENE EL DENERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJOPARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249.3166 (800) 990-9108 HOMEAMERICAN CREDIT, INC. d/b/a UPLAND MORTGAGE By: Benjamin Reich, Esquire - Attorney No. 54439 Robyn L. Brown, Esquire - Attorney No. 74894 111 Presidential Boulevard - Suite 128 Bala Cynwyd, PA 19004 (610) 668-2440 (610) 617-4967 (Telecopy) HOMEAMERICAN CREDIT, INC. d/b/a UPLAND MORTGAGE Bala Pointe Office Centre 1 I1 Presidential Blvd., Suite 128 Bala Cynwyd, PA 19004, Plaintiff, V. I I ROBERT F.SPANGLER 26 and 28 East Simpson Street Mechanicsburg, PA 17055, i and ALETA A.SPANGLER 26 and 28 East Simpson Street Mechanicsburg, PA 17055, i j Defendants. Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS TRIAL DIVISION NO. 99- jU/U Ocun 72- COMPLAINT IN MORTGAGE FORECIDSURE HomeAmerican Credit, Inc. d/b/a Upland Mortgage ("HAC"), by and through its counsel, files the following complaint in mortgage foreclosure, and in support thereof, states as follows: 1. Plaintiff, HAC, is a Pennsylvania corporation, with a place of business at Bala Pointe Office Centre, 11 I Presidential Boulevard, Suite 128, Bala Cynwyd, PA 19004. 2. Defendants, Robert F. Spangler and Aleta A. Spangler (the "Mortgagors"), are adult individuals with an address last known to HAC to be 26 and 28 East Simpson Street, Mechanicsburg, PA 17055. rat 3. At all times relevant hereto, the Mortgagors have been and remain the owners of certain real property with an address at 26 and 28 East Simpson Street, Mechanicsburg, PA 17055 (the "Property"). 4. The Property is more fully described in Exhibit "A", attached to this Complaint and made a part of it. 5. On December 4, 1996, in consideration of an extension of credit in the original principal sum of $50,000.00 from HAC to Mortgagors, Mortgagors executed and delivered to HAC a Promissory Note dated December 4, 1996 (the "Note"), evidencing the Mortgagors' indebtedness to HAC (the "Obligation"). A true and correct copy of the Note is attached to this Complaint as Exhibit "B", and is made a part of it. 6. On December 4, 1996, to secure the obligations owed by the Mortgagors to HAC under the Note, Mortgagors executed and delivered to HAC a mortgage dated December 4, 1996 (the "Mortgage"), granting to HAC, inter alia, a first-priority lien on and security interest in the Property. 7. On December 11, 1996, the Mortgage was recorded in the Office of the Recorder of Deeds in and for Cumberland County in Mortgage Book 1355, Page 1024&c. A true and correct copy of the Mortgage is attached to this Complaint as Exhibit "C", and is made a par!. of it. 8. The Note and the Mortgage, together with all other instruments, agreements and documents delivered in connection therewith are sometimes hereinafter collectively referred to as the "Loan Documents". 9. The Mortgagors are in default under the Obligation to HAC by reason, i= alia, of their failure to make payments as required under the Loan Documents. 2 10. On February 10, 1999, HAC sent to Mortgagors notices of HAC's intention to take action to enforce the Mortgage, including acceleration of the maturity of the Mortgage and commencement of an action in mortgage foreclosure, pursuant to Section 403 of Act 6 of 1974 (the "Act 6 Notices"). True and correct copies of the Act 6 Notices are collectively attached to this Complaint as Exhibit "D", and are made a part of it. IL On February 10, 1999, HAC sent to Mortgagors notices of HAC's intention to take action to enforce the Mortgage, including acceleration of the maturity of the Mortgage and commencement of an action in mortgage foreclosure, pursuant to Section 1680.403c of Act 91 of 1983 (the "Act 91 Notices"). True and correct copies of the Act 91 Notices are collectively attached to this Complaint as Exhibit "F,", and are made a part of it. 12. In the event a default is not cured as specified in HAC's notices to Mortgagors, the Mortgage entitles HAC to require immediate payment in full of all sums secured by the Mortgage without further demand, and to foreclose the Mortgage by judicial proceeding. 13. The total sum of $57,717.07 is due from Mortgagors to HAC, set forth in detail as follows: Outstanding Principal Balance $47,389.75 Unpaid Interest to 5/11/99 2,127.63 (Per diem interest of $13.30 at 10.24%) Late Charges 163.38 NSF Fees 50.00 Force-Placed Insurance 86.00 Legal Costs 334.50 Other Fees Permitted Under Loan Documents 37.50 SUBTOTAL AMOUNT DUE $50,188.76 Attorneys' Fees 7.528.31 05% of all sums due) TOTAL AMOUNT DUE $57,717,07 14. The defaults of the Mortgagors not having been cured, the entire balance under i i I ,.1 the Note, including, but not limited to, the entire principal balance, has been accelerated, and is due and owing, together with all other sums due and owing under and pursuant to the terms of the Loan Documents. WHEREFORE, HomeAmerican Credit, Inc. d/b/a Upland Mortgage demands judgment in its favor and against the Mortgagors, jointly and severally, in mortgage foreclosure and in the sum of $57,717.07, together with interest thereon, at the contract default rate of 10.24% per annum (at the per diem rate of $16.19) from May 12, 1999 through the date of judgment, plus interest accruing thereon at the contract default rate of 10.24% per annum from the date of judgment, as well as costs of suit, and all other fees and costs collectible under and pursuant to the terms of the Loan Documents. HOMEAMERICAN CREDIT, INC. d/b/a d/b/a UPLAND MORTGAGE By:_ ??^ l \ 1?cL BENJAMIN REICH, ESQUIRE, ROBYN L. BROWN, ESQUIRE BalaPointe Office Centre 111 Presidential Boulevard, Suite 128 Bala Cynwyd, PA. 19004 f.\sharcd\Icgal\hac\spanglcr\plcad\forcclos.cmp Attorneys for Plaintiff HomeAmerican Credit, Inc. d/b/a Upland Mortgage 4 i 1 i i i 1, SUSAN B. NAFTULIN, declare and verify that I am the Assistant Vice President - Legal Affairs of HomeAmerican Credit, Inc. d/b/a Upland Mortgage ("HAC"); that I am authorized to make this verification on behalf of HAC; that the facts contained in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief. I make these statements subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsifications to authorities. S AN B. NAFTUL V Assistant Vice President - Legal Affairs HomeAmerican Credit, Inc. d/b/a Upland Mortgage Dated: ??r?l 5 OF I! . '?.,,. ?TA Y 1,_, ,SYu EXHIBIT A LEGAL DESCRIPTION ALL THAT lot of ground situated on the South side of East Simpson Street iu the Second Ward of the Borough of Mechanicsburg, County of Cumberland and Stale of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the building line of said East Simpson Street, at the corner of property formerly of Irene Stough; thence along said property of Irene Stough, Southward one hundred thirty-two (132) feet to a twenty (20) foot alley; thence Eastward along said alley, sixty-eight (68) feet to a point at corner of property formerly of 0. H. Autlhouse; thence along said property of O. H. Aulthouse, Northward one hundred thirty-two (132) feet to a point on the building line of said East Simpson Street; thence along the building line of said Street, Westward sixty-eight (68) feet to a point, the place of BEGINNING. NOW IMPROVED by a two and one-half (2 ''/2) story frame dwelling house numbered 26 East Simpson Street, Mechanicsburg, Pennsylvania, and Office building at 28 East Simpson Street, Mechanicsburg, Pennsylvania. 1 EXHIBIT 8 ro LOAN ID& 11645 NOTE DECEMBER 4711, 1996 MECHANICSBURG , PENNSYLVANIA IDUe) IChyI ISterel 26 AND 28 EAST SIMPSON STREET, MECIIANICSB=, PENNSYLVANIA 17055 Worm." Addresrl 1. BORROWER'S PROMISE TO PAY 'In return for a loan that 1 have received, I promise to pay U.S. $ 50, 000.00 (this amount is called principal'), plus interest, to the order of the Lender. The Lender is HOMEAt4ERICAN CREDIT INC D/B/A UPLAND AIC IIGAM . 1 understand dim the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the 'Nate Holder.' 2. INTEREST Interest will be charged on unpaid principal until the fill amount of principal has been paid. 1 will pay interest at a yearly rate of 10.240 %. The interest rate required by this Section 2 is tint rate 1 will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and race of Payments I Will Pay principal and interest by making payments every month. I will make my monthly payments on the 9141 day of each month beginning on JANUARY 9TH, 1997. 1 will make these payments every month until 1 have paid all of the principal and interest and any other charges described below that I may owe under this Note. My monthly payments will be applied to interest before principal. If, on DECEMBER 9141, 2011 . I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the 'Maturity Date.' I will make my monthly payments at 111 PRESIDENTIAL BOULEVARD, SUPPS 142, BAIA CYMM, PFMIMVANIA 19004 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 544.67 4. BORROWER'S RIGIIT TO PREPAY I have the fight to make payments of principal at any Bloc before they arc due. A payment of principal only is known m a 'prepayment.' When 1 make a prepayment, I will tell the Note Holder in writing that I am doing so. I may make a full prepayment or partial prepayments without paying any prepayment charge. The Nate Holder will use all of my prepayments to reduce the amount of principal that 1 owe under this Note. H 1 rake a partial prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. S. LOAN CHARGES If a law, which applies to Ihit loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (i) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (if) any sums already collected from me which exceeded permitted limit; will be refunded to me. The Note Holder may choose to make this refund by reducing the principal 1 owe under this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) !ate Charge for Overdue Payments If the Note Holder has not received the fail amount of any monthly payment by the end of TEN calendar days after the date it is due, I will pay a late charge to the Note Ilolder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only ono on each late payment (0) Dehult If 1 do not pay the full amount of each monthly payment on the date it is due, 1 will be in default. (C) Notice of Deratdl If 1 am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that I owe on that amount That date must be at least 30 days after the date on which the notice is delivered or mailed to me. (1)) No Walvef By Note Holder Even if, at a time when I am in default the Note Holder does not require me to pay immediately in full As described above, the Note Holder will still have the right to do so if 1 am in default at a later time. (E) Paymmi of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable momcys' 11m. 41MUSTAw nxED RATE NOTE - Sa sk Ibnay - FNMA11"l11A/C UNIP01101 INMUam:NT Form 3200 1241 AATGIG . 642119f1 rate 1 0r2 Dot Pimp Elm, la. 7. GIVING Olt N(YRCES IOAN IN 11645 Unless applicable law requires a different method, any notice [tint must be given to rim under tlds Note will be given by delivering It or by mailing It by first class mail in me at the Properly Address above or at o different address if I give the Note Holder a notice or toy different address. Any notice that must in given to the Note Holder under this Note will be given by mailing it by first class mail to the Note Iloldcr nt the address stated in Section 3(A) above or at a different address if I tint given a notice of that different address. S. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one Persian signs this Nom, each person Is fully and personally obligated to keep all of the promises made in this Note. Including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surely or endorser of this Note, is also obligated to keep all of the promises made In this Note. The Note Holder may enforce its rights under this Note against each person individually or against all or us together. Tlds means that any one of us may be required to pay all of [be amounts owed under this Note. 9. WAIVERS and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. 'Presentment' means the right 10 require the Note Holder to demand payment of amounts due. 'Notice of dishonor' means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations In some jurisdictions. In addition to the protections given to the Note Holder under ibis Note, a Mortgage, Decd of Trust or Security Dad (the 'Security Instrument'), dated the same dam as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts 1 owe under this Note. Some of those conditions arc described as follows: Transfer or the Property or a Beneficial Interest in Borrower. If all or any pan of the Property or any interest In it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment In full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may Invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED, z '1? MMKI! r. SPAtiGLER JR. (Soap Jsea l) .po lxr?7A Q Spati.,,[,,, A is A. SP'11N,TEIL (Seal) -Borrower -Borrower (Seal) .Borrower (Seal) -Borrower (Seal) .Borrower /Sign Original Onlyl AATC2G • 04211"S rMae 2 42 Ibc 14rp Nu, In<, EXHIBIT C I hone car•tity that this a true and co is rral co o tCr al floct olent. py of the PIWARED BY JOY lUUtBBSOpI RICAN CR®PT, INC. Di UPIAND PUIi'IGAC? 111 PRESIDENTIAL BOULEVARD, SUITE 142 DN'A CYNWYD, PENNSYLVANIA 19004 IAFere Al-re This Ifne For lbronang Nelal -? MORTGAGE IRAN IDI 11645 THIS MORTGAGE ("Security Instrument") is given on DECEMEM The mortgagor is IIOBERT F. SPAN(T8R JR. AND 4711r 1996 ALETA A. SPANGLER This Security Instrument Is given to f r I ("Borrower'). which is organlmd and existing under lha laws or SIT, INC. Di UPIANp MORE and whom address is 111 PRESIDENTIAL TIC COMIAM P'ALTTI OF PENNSYLVANL4 19004 BOUILVARD, SUITE 142, BATA CyNWyO, pENNSYLVANIA, Borrower owes (ender the principal sum of FIFTY TI)ODSANO AND NO/100 Dollars (U.S. $ 50, 000.00 ("Lender"). ). 11lis debt is evidenced by Borrower's note dated the some date as this Security Instrument ("Note"), which prmides for monthly ryaymenis, Willi the full debt, if not pall earlier, due and payable nn D1xQ.? 9Z'N, 2011 This Security Instrument secures to Lender: (a) the rcpaymcm tile evidenced by the Nate, with Inleresl, and all renewals, other sums, will, interest, advanced performance of or Borrower's mvennnla and agre m1cmlons and mrnlifiraNnns of file Note; (b)oti1e P debt en under paragraph 7 to Protect the security of this Security Instrument; and (c) the emenla under this Security instrument and file Note, For th all is purpose, Borrmvcf does hereCUMBEIU by mortgage, grant and coi to Lender [lie rollawing described property talented in County, Pennsytvanin; 26 AND 28 EAST SIMPSON STREET BMIDLM F MECHWCSB= COUNTY OOFcuMBLIUAW . I2/ 1/BYLVANIA DELL RMX0ED 12/14/89 MED BbOK B-34 PAGE 1140 PARCM ND. 17-23-0565-063 which has the address nr Pennsylvania 17055 tUp Cp)cI 26 AND 20 EAST SIMPSON STREET IsIreell ("Property Address"); r MB lChyl (5017liG ICiryl l'IINNSI1.VANIA--5In01a Ihadty-.FNkjfVF111.MC 11NIFGRhl INSllttlki PACMIG • rwgaraw. Is. Iles Parr / of 6 Fpm 5071 Will Up IWF Flu, Im j f i I. r e, grain COVIIHAN cg lvc 8Ilrn[ Ilmnawcr Is lawfully selsed of the usual, Ilemby conv fly tic titl Ip/ 11645 B eyed cool tills Ille rlg?hl IN) or And sW cmwcy ] tic Propcny aul [lint It,, 1'mpcrty in uncuaunbul. cxccpl far enatmha tight ( ht record Borrower grain n Warrants ant will defend generae m the Property ngahut all dnims anti defnds, subject to nay encumbrances of record, , 11115 SECURITY INSTn[rkt11N7 cmublues uniform covcmnnls for variations by Jurisdiction to Constitute a unlfarm security Ina nnllnnnl nsc and nmrvuniforu, covcnmus with Iindled lument covering real Properly. UmFlaat C/VINAN75. Borrower and Lender covenant mist Agree its follows: 1, I'aynlenl or I4lndpul'Intl hdcresq Prepayment And Laic Charges, Borrower a,,,,, prompllY PAY when due 'lie prindpal of and Interest on tine debt evidenced by Btu Note and Ally Prepayment and lac charges due under the Note. 2. Funds for Taxes and b]snmuce. Subject la applicable law or lu a written waiver by Lender, Borrower shall pay to Lender on the day monthly paynlen[, arc due under the Note, until tic Note Is paid In full, a sum ('Funds`) far; (a) yearly coxes and assessments yearly rly le Icmchold payments which MAY Alain priority over [his Security Instromcal as a lien on [Ile Property; (b) or ground rcnrs on the 1'mpcrty, if Any; (c) yearly bound or p Yearly Bra Insurance premiums, if any; (c) yearly mortgage insurance premiums, if by harrower to LenJ,r, roperty insurance premiums. by , In accordance will, she provisions of poragrs b 8, in lieu of t any; ant (f) any sums payable IlMnluills. he payuCot of mortgage insurance 10 exceed The e max max itemimum s are calla, 'Iscrow Ocros'• Lender may, at ally lime, collect and hold Funds In an annual nai to exceed t amount a eJ mortgage loan may require for FBorrowcr,s unds a escrow Account under its, federal Real Fatale Lender for a federally tell, Schi,mcut Procedures Act of 1974 as Amended train little to time, 12 U.S.C. § 2601 el seq. (`RMPA`), unless another law that applies to the hunts acts a lesser amount. If so, Lender may, at any time, CoIIecI and hold Funds in all numunl not to canal the lesser amour, rider may cstinale title on the basis of current dam and mmonab[e csiinmtcs of cxpendiu,res tile 8111011111 of Funds accordance will] applicable law. of fnwrc Escrow lien's oti Otherwise in Tile Funds shall be held in an inadlali°n whose deposits arc insured by a federal agency, iusWm,nmlity, or cn,hy, (including Lender, jr Lender is such an Institution) or In any Pay Mho EsCrOw Bans, Lender may not charge h Federal (Tome Loan Dank. Lender shall apply the Funds to escrow account, or verifying tile Borrower for holding and applying t Funds, annually analyzing the Escrow Items, unless Lender pays Borrower hnterml of tiro Funds and Applicable law Partial Lender to make such a charge. Ilewcvcr, Lender may require Borrower to pay a one-time charge for an independent real esmte tax reporting service used by Lender in connection with this Inn, unless applicabi° law provides otherwise, Unless an agreement is made or Applicable law, requires interest to in paid. Leader shall not be required m Pay Borrower any ""am' or mornings on the Funds. Borrower and Lender may agree In writing, however, that interest shall be paid b the iliae Funds Lender and (lie shall give purpose , to Borrower witho credits and debits to th Fu ut charge, an annual -accounting of ilia Funds, showing for which cacti debit to the Funds was made. The Funds arc pledged as Additional security for all suns secured by 41,15 Security Instrument If d'lie er aside hc.J by Leader exceed Abe mnouuts pcnnilted Io in held by apPlinblc law, Lender shall -aceaunl to Borrower far the excess Funds im accordance will, the requiremeus of applicable law, If die amour of I a Funds heat by Lender at any Unto is not suffidau it, pay the Escrow llenu lender may sec ranotify Burrower in warthog , and, to such easse Borrower shall pay to Lender ilia amoral acce when nary to dnc, make de the deco cy. Ilarrowrr shall make up (tic deficiency in no more than twelve monthly paylues, a1 n Leader's ary go sole discretion. n. Upon Payment in full of all ens secured by this Security lustnnncm, lender shall pronsP,ly refund to Dorrowcr any Funds held by Lender. If under paragraph 21, Lender shall acquire or sell ,he Property, Lender, Prior to the rmwcr an or sale cutin Propcny, shall apply any FAWa held by Lender at the time of acquisition sa to a credal (tAgainst ic Acq the noun secured by this Segally hutronlent. J. Appliwiino or Payments, Unless applicable law provides rnllerwise, all payments received by lender under Paragraphs I and 2 shall be appliah: first, to any Prepayment charges (file older [lee Note; second, to amounts Payable under paragraph 2; third, to interest due, four,h, to Principal due; and last, 10 any laic charges due under the Nate. 4. Charges; ideas. Borrower shall pay all taxes, assessmens, charges, hues and impositions attributable to the roperly which borrower shall PAY Iliac n I gaff ns inrtile rn, nertprovid d in pa?agrapph2 °or if not aid io flat manner, Borrower shall pay them on time directly to rile inmost owed payment. Burrower shall promptly furnish to Lender all notices of muouuts is Ire paid uodcr this paragraph. If Borrower makes nhese paynaols dimelly, Borrower shall Promptly furnish to Lender receipts evidencing ilia payments. agmses io writing to ilia payment of tilc obligation s which ecured by ntiletlic ] b, arna,merrAcceptable IrBorrower (a emler; in good faith Bra lien by, or defends against ci forecttent of the fiat in, legal operate to Prevcr]t Ilia enforcement of the licit; at (c) secures front file holder f?luc jicn an n n]gorccmcLender's satisfactory opinion III Lc,Wcr aulafnllnntiug Ili, lira to tills Secud]y Instmn,cn,. If len(far dc,cnniacs dial any pan of tlra Pmpcny is subject 10 a lien Willett may atlainpriority over this Security Instrument, Wndcr army give Ilurrower a notice iderifylog the lien. Borrower shall Satisfy Ibc lien or take one or arc of the Actions set forth alxwe within 10 days of the giving of notice. Properly Insure or against I Propeny lasuralace. I Borrower shall kocp tl¢ imPmveucnh ]row existing or hcrcaricr crated on life ?Including floods or looding. for which Lender requires in surrmmaaT ills insurance shall Inc maintained in the momuS Bud [Or she Wider r's dun res. subject to Wider's approval whirls slhall no['Ina umeneaaona fly wi,h? Id nr 'INC faiilsto shall ntabe christen inuhnCoVe se d uibod above. Leader may, at Lenda's option, mbuin wverage t° protect Lender's rights in Itic Pmperty in accorduec will, paragraph 7. . 1'AQIM • 11161"S Attest arti trot Rrp liar, ix. MAN IDI 11645 All Insurance policies and renewals shall be acceptable to Lender and shall Include n standard mortgage clause. Lander shall havc the right to hold the policlcs and renewals. If lender requires, Harrower shall pratnpily give In Lender all receipts of paid prenuhons and renewal mulces, tit the event of loss, Borrower atoll give prompt notice m the Insurance carrier and Lender, Lender may mnke proof of loss If not made promptly by Borrower, Unless Lender null Borrower otherwise agree hl writing, huurnnce proceeds shall be applied to ratornllon or repair of the Property damaged, If the ramrmlon or repair Is economically feasible mud landcr's security Is not lessened, If the restoration or repair Is not eco ondeadly feasible or Lender's security world lee lessened, the Insurance proceeds shall be applied to lite suns secured by tills Security Insuomenl, whether or not then due, will] Ally excess pald to Borrower. If Ilnrmwer abandon$ file Properly, or does not answer within 70 days it notice from Lender that lies insurance carrier Ins offered u] settle a chain], then lender nay collcel the Insurance proceeds. Lender may use the proceeds ill repair or restore the Property or to pay aunts secured by tills Security Instrument, whether or not then (Inc. 11so 70Any period will begin when the notice Is given. Unless Lender and Borrower otherwise agree in writing, Any application of proceeds to principal shall not extend or postpone the due date of the monthly payments mfcrrcd to in paagrnphs I And 2 or change the amount of the payments. If under paragraph 21 trite Property is acquired by Lender, Borrower's right to any insurance policlcs and proceeds resulting from damage to the Property prior to fie acquisition shall pass ht lender to the extent of the sums secured by this Security Instrument immediately prior to Ida acquisition. 6. Occupancy, Preservation, Maintenance And Proleclinn of the Property; Ilnrrower's loan Application; Leaseholds. Borrower shall occupy, establish, and use the I'mpeny as Borrower's principal residence within sixty days after the execution of this Security Instmment and shall continue to occupy the Property as Borower's principal residence for at least one year after fim date of occupancy, unless Lender nfiuctwise agrees tit writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which arc beyond Borrower's control. Borrower shall not destroy, damage or Impair llte Pmpcrty, allow Idle Property In deleriormc, or comml waste on file Propcny. Borrower shall be lu default if any forfehure action or proceeding, whether civil or criminal, Is begun that in Lender's good fallh judgment could result in forfeiure of the Prorerly or otherwise materially 1 Apair the lien created by Ills Security Instrument or Lender's security interest. Borrower may cure such a defauh and reinstate, as provided in paragraph 18, by causing the action or proceeding to be dismissed with a ruing that, fu Lender's good faith determination, precludes forfciture of the Borrower's interest in the Property or other material impairment of fie lice created by this Security Instmment or Lender's security interest. Borrower shall also be it, thermal if Borrower, during Ilia loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of tine Properly as a principal residence. If this Security Instrument is an a leasehold. Borrower shall comply with file provisions of lire (case. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to [lie merger In writing. 7. Iholceioa Of Lender's [lights in Ilia Properly, If Borrower fails to perform the covenants and agreements contained In this Security Instrument, ter [hem is a legal proceeding that may significantly affect Under's rights In the Property (such its a proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), [hen Lender may do and pay for whatever is necessary to protect the value of lire Property and Lender's rights in Ilia Property. Lender's actions may Include paying any suns secured by a lien which has priority over this Security Instrument, appearing In court, paying reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may lake action under this paragraph 7, Lender dace nol have iu do so. Any amounts disbursal by Lender under this paragraph 7 shall become Additional debt of Borrower secured by this Security Instmment. Unless Borrower and lender agree to other terns of payment, titac amounts shall bear Interest from lm date of disbursement at the Note rate and shall be payable, with fnterest, upon notice from Lender to Uormwcr requesting payment. 8. Morlgoge Insurance. If Lender required mortgage insurance as a condition of making the loan secured by this Security Instrument, Borrower shall pay lire premiums required to inaotoia late mArtgAgc insurance In effect. If, for any reason, Use mortgage Issuance coverage required by Louder lapses or ceases to he in effcct, Borrower shall pay the premfuns required to obtain coverage substantially equivalent to the mortgage insurance previously in effect, at a rest substantially equivalent to lite col to Borrower of lie mongnge insurance previously in effect, from an alienate nnorgage insurer approved by Lender. If substantially equivalent mortgage insumncc coverage is not available. Borrower shall pay to Lender each month a sun equal to one twelfth of fie yearly mortgage insurance premium icing paid by Borrower when the insurance coverage lapsed or ceased Io In in effect. Lender will accept, use and retain these payments As a loss reserve in licit of mortgage insurance. Loss reserve payments may no longer be required, at the option of Lander, If nartgage Insurance coverage (fn lie Antonio and for Ilia period [hat Lender requires) provided by an insurer approved by Leader again beconsu available and is obtained. Borrower shall pay Ibe premfunss required to maintain nmrtgagc insumncc In effect, or to provide a loss reserve, until Ida requirement for mortgage insurance ends in accordance with any written agreanent between Borrower and Lendcr or applicable law. 9. l specton. Lcndcr or its agent may make reasonable aria upon and inspections of the Pmpcrly. Lando shape give Borrower notice at the fine of or prior to am inspection specifying reasonable cause for the inspection. 10. Coudauallo]. 71e pmeeeds of any awaid or claim for damages, direct or cousetpa:oiai, in connection with any condenustion or other taking of any pan of the Property, or for conveyance fn lieu of condemnation, arc hereby sssigned and shall be paid to lender. I•Ach0c • 11161"s Psaes orb Ile I•np 17w, lac. MM 101 11645 In the even[ of a anal Inking of Iles Property, the proceeds shall be appliml it, Ilse sums secured by this Security fnslnunenl, whether or nor then due, with any excess paid to Borrower. In Ilse event of a partial taking of rise Property in which the fair market value of Oa pmpeny larredintcfy before Ose taking Is equal to or greater thou Ose amount of Ilse sums secured by this security Inslmnicnt lounedlntely before tile taking, unless Ilormwer mod Leader olherwhe agree In writing, Ilia sums accused by this Smurhy Instrument shall be reduced by ilia ammo of rise proceeds multiplied by Ilia following frcluno: (a) Ilia total anaunt of the suuu sccumd luulnvllnlely befum Ile Inking, divided by (b) the fair market value of Ilse Property intinallataly befom the taking. Any balance shall be pnld m Borrower. In the event of a partial taking of [he Property in which ilia fair narket value of file Propeny Inunedhntcly before Ilia taking Is less than ilia anoanl of the sums secured Ilmnalinlely Iefom the inking. unless (lorrowcr and Lender ollmrwise ngrec in writing or unless applicable law otherwise provides, the proceeds slmll be appfial to the swim secured by this Security Ins(mmcul whether or not bite sums are then due If Oa Property is abandoned by Borrower, or if, after notice by Lcnder [o Borrower (hat tire condcomor offers to make an award or settle a claim for danagm, Borrower fails to respond to Lendcr within 30 days after ilia dale ilia notice Is given, lender is mnhnrimd to collet[ amt apply the proceeds, at Its option, either to restoration or repair of the Property or to the sums smumd by [his Security lostrumenl, whether or not then (Inc. Unless Lender laid Borrower otherwise ngnee in writing, any application of pmcmds in principal shnll not extend or postpone the line date of Ilia monthly payments referred to in paragraphs 1 and 2 or change Ole amount of such payments. 11. Borrower Not Released; b-orbearnuce Ily Lender Not a Waiver. Extension or the lime for payment or nudiftcntlon of amortimlfon of rise sums smumd by this Security Instrument granted by Lender to any successor in interest of Borrower scroll not operate to release Ooc liability of the original Burrower or Borrower's successors In interest. Lender shall not Ie requimd to continence pracmdings against any successor In iucrmt or reruse to extend time for prymenu nr otherwise modify anmrtiration of the sums secured! by this Security Instrument by reason of any demand mode by ilia original Borrower or Borrower's successors in ime=(. Any forbearance by Lender in exercising any right or mmedy shall not he n waiver of or preclude ilia exercise or any right or mmcdy. 12. Successors and Assigns Boond; Joint and Several Liability; Co-signers, Tile covenants and agreements of this Saurity Ins[mmcat shall bind and benefit doe successors and assigns or Lender and Borrower, subject to tire provisions of parngnph 17. Borrower's covenants and agmcneas shall be joint and several. Any Borrower who co-signs this Security Inswnoenl but does not execute the Note: (a) is co-signing this Saurity Ins(mment only to mortgage, grant and convey tits Borrower's interest in Ilse Proper- trader ilia terns of this security Instrument; (b) is not personally obligated to pay (he stuns sccumd by this Security turn nient; and (c) agrees that Lender and any other Borrower, only agree to extend, modify, forbear or make any acco nnoahatfons with regard to tire terns of this Security instrument or Ile Note without that Borrower's consent. 13. Loses Charge. If [lie loon secured by this Security Inslnuncnt is subjm[ to a law which sets maximum loan charges, and dust law is finally interpreted so iliac lire intemsl or other loan charges collected or to be collected In conueclion with the loan exceed Ilia [ermined limits, then: (a) any such loan charge shall he reduced by due amount necessary to reduce dire charge to die permitted Both: and (h) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower, lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, ilia mduclion will be trained as a partial prepayment without any prepayment charge under ilia Note. 14. Notices. Any notice to Borrower provided for in this Security Insert uem shall be given by delivering it or by nailing it by fir[ class mail unless applicable law requires use of another nathnd. Ilia notice shall be directed to the Prop>rry Address or any other ailmss Borrower designate by notice to render. Any notice to Lcnder slat[ be given by first class mall ;a Lender's address stated herein or any other address Lender designates by no(icc to Borrower. Any notice provided for in this Saurity Ins[no ant shall be decnoal to have been given to Borrower or Lender when given as provided In [Isis pangmph. 15. Governing Law( Severshllity. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which tine Property Is located. In the event 111,11 any provision or clause of this Security Insimmenl or ilia Note conflicts with applicable paw, such connict shall not affect other provisions or this Security Instrument or the Note which can be givcn effect without ties connicling provision. To this end the provisions of this Security Instrument and the Note arc declared to le uvcnble. 16. Borrower's Copy. Borrower shall be given one conformed copy of blue Note and of []its Security Instrument. 17. Transfer or ilia Property or a Beneficial Interest In Borrower. If all or any pan of ilia Property or any ilnemsl In it is old or transferred (or if a beneficial interest in Borrower is sold or transferral and Borrower is not a natural person) without Lender's prlor written consent. Lender may, at its option, mquim innnediatc payment in full of all sums secured by this Saurity Instrument. However, this option shall not be exercised by Leader If exercise is prohibited by federal paw as of ilia date of this Security Instrument. If trader exercises this option, (ender shall give Borrower notice of aaxlern[inn. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrumcnl. If Borrower fails to pay these sums prior in the expiration of this period, Lender nay invoke any mmedim pero ricd by this Smurity Instrument wilhaut further notice or denatd on Borrower. 19. tha rowa's Itlghl In HeInslale. If lorrowcr mats certain condbtma, Borrower shall have the right to have cnromarnenl of this Security Inslmuoent discontinued at any sine prior to the earlier or: (a) 5 days (or suds other period as applicable low may specify for minstatenocm) Iefom We of ilia Property pursuant to any power of sale contained in this security'Instmnsens; or (i) airy of a judgement enforcing this Security Inslrnncm. 'Those conditions are that PACKNC - 1116BSS Mae 4 r6 1W Prep lius, b,e. =1111 ID1 11645 Borrower: (a) Pays Lender ill sons which then would be due under this Security ]nstnunenl and the Note as if no acceleration occurred; (b) cures any default of my other covenants or ngrecmenis; (c) Pays all expenses incurred In enforcing this Security hrntmrnenl including, but not limited m, rcasauable miomcya' fees; coed (d) sakes such action as Lender may reasonably require to assure ,,a, the lien of this Sgcurisy Instrument, Lender's rights in the property and Borrower's obligation in flay tiro sans secured by tills Security Instrument shall continue unchanged. Upon reinstatement by Burrower, tills Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration lend occurred. However. this right 10 rcinsmte shall line apply In the case of acceleration under paragraph 17, 19. Sale of Note; Change or Lean Serviccr. The Note or a partial Interest In the Nule ((ngether with tills Security Instrument) may be sold one or more limes without prior notice to Borrower. A sale may mull in a change in the entity (known as Bee -Lon Serviccr') film collects monthly payments duc under the Note and tills Security Instrumem. nlcm also MAY In one or more changes of she Lane Serviccr unrcimcd I0 a snic of Use Note. if there Is a change oflicallm Loan Serviccr, Borrower will be given written lin1ln of the chnngc in accordance wills parograpls 14 above and appble law. 7Le notice will state she name and address of file new Lunn Serviccr and the address to which payments should be node. The notice will also contain any other information required by applicable law. 20. Hazardous Substances, Borrower shall not cause or per ill the presence, else, disposal, storage, or release of any Ilaurlous Substances on or ht the Property, Borrower shall not (In, nor allow anyone else to do, anything arfecting presence, use,l at is lit violation storage onl us10 (lie tl a Property of small quantities; of Hazardous b Sutwo bstances stint are generally yrecognlud to be appropriate to normal residential uses and to maintenance of she Property. Borrower shall promptly give Lender wriltcn notice of any investigation, claims, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Properly and any Ilazarelous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that my removal or other renadiation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary renledial sections in aCCOrhmece with Environmental Law. As used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law end tite following substances: gasoline, kerosene, other framable or toxic petroleum produce toxic pesticides and herbicides, volatile solvents, materials conmiotng asbrstns or formaldehyde, and radioactive materials. As used iu tills paragraph 20, 'Envimmnsa lal Law' means federal laws and laws of site jurisdiction where situ Property is located that rctasc a health, safely, or environmental protection. NON-UNIFORM COVGNAMS. Borrower and Leader further covenant and agree as follows: 21. Acceleration; Remedies. Lender shall give notice to Borrower prior to uccelerolinn following Borrower" breach or any covemmt or agreenteul 131 tills Securlly Inslrumenl (lint not prior to acceleration under parognph 17 odes applicable leer provides olimcnvise). Lender shall reality Borrower or, among other things: (a) the default; (b) the action required to care the default (c) when the deroult roust be cured; need (d) Ball failure to cure the deroull as specified may result In acceleration or the sinus secured by tills Security Instrument, foreclosure by judicial proceeding and safe or the properly. Under shall further luronm Burrower or the right to rdnstate after acceleration mill lime right to anal he Ilene foreclosure pecmling the non•exhience or a default or may other derense of Borrower It) accelcmt(on cud rurccinsmre. If the default Is not cured as specified, Leader at Its option relay require Immediate paymCnl In full or all smus secured by this Securlly. Instrument without further danand and may roreclose tills Sorority Instrument ley judicial prscmBng. Lender shut] be entitled to collect sell expenses hmcurned lei pursuing (lie renteties provided bat tills imrngruph 21, Including, but an( limited to, allomeys' fees need costs or title evidence to time extent permilled by applicable law. 22, ltclcac. Upon payment of all sums secured by this Security hnsln neat, this Security Instrument and the estate conveyed shall lemdnale and becouec void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any u:cnrlatinn casts. M. Waivers. Borrower, to the extent pernitled by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instnmncal, and hereby waives the benefit army prescul or future laws providing for slay of execution, extension of little, exemption from allnchmenl, levy and sale, and homesicad exemption. 24. Rehsslntcnan Period, Borrower's lime to Mosinee provided fit paragraph IS shall extend to one hour prior to the commencement of bidding at a sheriff's safe or other sale pursuam to this Security Instrument. 25. Purchase Mousy filortgage. If ally of del debt secured by this Smorhy luumacul is leal m Borrower to acquire tide to lite Property, this Smartly Insunmaul shall IV a Purchase money Inungage. 26. Inlemi (tole After Judgment. Borrower agrees that the interest tale payable after a judgment is entered on the Nate, or in an anion of usoregage forclusum xlall In ]lie earn pnyablc from time to time under the Nate. MOM . 111HSSS Pape S It Ust M1vp Mu, Inc. i 27JUders to Ibls Security holnnne,l• Ir arse or "Into riders arc exacted by Borrower slid rccorJcJI Ingc?hcr w su 646 hir tub Security le cOyc enL the ca gmellm and ngreenucnrs of one[] Such rider shall In Iucorluarnfed Imo nod 311411 Amend and Iusflu Mmrseenl. file )Cheeck ck applicable AnJbwx(csux Of fills Security Insirunent as If do rldcr(A) were a part of fhb Security s)l Adjustable Rate Rider - CondouJnluuu Rider BradaAmd Paymcul Rider ® 1 • A Pulnlly Rider 0 130110,011 Rider Planned unit Development Rider Blwcckly Paymcnl RIJcr V.A. Rider Rare 1nlProvemcul Rider Odmr(s) ISPnciryl Second Dome Rider any riderr(s) execured O cxmu parrower In any rider(s) accepts And agrees tO the leans and covcnnnts comnlneJ In by Borrower and recanted will, if. b, Ills Security Inalmment and Witnesses:? ?{'/?J?? ?/ rvtuvu !• SPA); !7(t, (Seal) Tor?wer _nrA.sn n. SPA[7GLpi (Scat) -BOVOWcr (Seal) -Borrower -Borrower (Seal) -Borrower (Seal) -Borrower ISp[r! 004w Trds Uft Par Ackn[wlNlaallmll COMMONWEALTIr OP PENNSYLVANIA ) COUNTY OP )SS: On Ibis file MI Jay of ) B1?7 ? .46 . before on, ?j?(s MIDH2r 1o f the undersigned officer. personally appeared I03ERT P. SPANMM JR. AND ALEfA A. SPANGGIIt known 10 Inc (or salisrneforily Proven) In be die Person S whose name s ARE subscribed to the within instnlmcal and acknowledged dwt TiRiY execute! Be sarne for Je purpose herein contained. IN 7119 WrrNess WNEREOP, I hereunto set my hand and official seal. MT?C17';EA? I NOTARIAL SL NnuaA hour. «wrA[r wan I CCCvyv??? «AYly[N w>NA muwr., ,M YT:%YIYI.wnN X,IIb,«'M [[R. [. IIw[ Nlwrlllw, NaYLVAN1AAgq;, O NNOTAM I!! n,ll of arr¢!r PACAI60 . liralslS Met a art; IM[ AYy Act. IM. S I EXHIBIT 0 PL BoloPointe Office Centre • III Presidential Boulevard • Suite 141 • Bala Cynwyd, PA 19004 (610) 668.1083 1.800.411.1456 • Fax (610) 668.8316 February 10, 1999 VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED AND REGULAR MAIL Mr. Robert F. Spangler, Jr. 26 East Simpson Street Mechanicsburg, PA 17055 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear Mr. Spangler: The mortgage held by HomeAmerican Credit, Inc. d/b/a Upland Mortgage on your property located at: 26 and 28 East Simpson Street, Mechanicsburg, PA 17055 IS IN SERIOUS DEFAULT because you have not made the monthly payment of $544.67 for the period of December 9, 1998 through February 9, 1999. 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 $1,823.70, which includes interest and fees due to date. YOU MAY CURE THIS DEFAULT WITHIN THIRTY (30) DAYS OF THE DATE OF THIS LETTER, BY PAYING THE ABOVE AMOUNT OF $1,823.70 PLUS ANY ADDITIONAL MONTHLY PAYMENTS WHICH MAY FALL DUE DURING THIS PERIOD. Such payment must be made either by cash, cashier's check, certified check or money order payable to HomeArnerican Credit, Inc, d/b/a Upland Mortgage, Attention: Benjamin Reich at 111 Presidential Boulevard, Suite 128, Bala Cynwyd, PA 19004, If you do not cure the default within THIRTY (30) DAYS, HomeAmerican Credit, Inc. d/b/a Upland Mortgage INTENDS TO EXERCISE ITS 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 pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days, LENDER ALSO INTENDS TO INSTRUCT ITS COUNSEL TO Mr. Robert F. Spangler, Jr. February 10, 1999 Page 2 START A LAWSUIT TO FORECLOSE YOUR MORTGAGED PROPERTY. IF THE MORTGAGE IS FORECLOSED YOUR MORTGAGED PROPERTY WILL BE SOLD BY THE SHERIFF TO PAY OFF THE MORTGAGE DEBT. IF YOU CURE THE DEFAULT WITHIN THE THIRTY (30) DAY PERIOD, YOU WILL NOT BE REQUIRED TO PAY ANY ATTORNEY'S FEES, NOTWITHSTANDING THAT THIS ACCOUNT HAS BEEN REFERRED TO COUNSEL. If you do not cure the default within the THIRTY (30) DAY PERIOD you will have to pay a reasonable attorney's fee, not to exceed $50.00, for services actually incurred. If legal proceedings are started against you, you will have to pay a reasonable attorney's fee even if it is over $50.00. Any attorney's fee will be added to whatever you owe Lender, which may also include reasonable Court costs. Lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty (30) day period and foreclosure proceedings have begun, YOU STILL HAVE THE RIGHT TO CURE THE DEFAULT AND PREVENT THE SALE AT ANY TIME UP TO ONE HOUR BEFORE THE SHERIFF'S FORECLOSURE SALE. YOU MAY DO SO BY PAYING THE 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 Sheriffs sale could be held would be approximately August, 1999. 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 Benjamin Reich of HomeAmerican Credit, Inc. d/b/a Upland Mortgage at (610) 668-2440. This payment must be in cash, cashier/certified check or money order made payable to HomeAmerican Credit, Inc. d/b/a Upland Mortgage at the address previously provided. You should realize that a Sheriffs 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 Sheriffs 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 PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION Mr. Robert F. Spangler, Jr. February 10, 1999 Page 3 TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OF THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT ANY OTHER REQUIREMENTS OF THE MORTGAGE ARE SATISFIED. CONTACT THE UNDERSIGNED TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST). YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default has occurred. However, you are not entitled to this right to cure your default more than three times in any one calendar year. In addition, you may receive another notice from this lender entitled "Notice of Homeowners' Emergency Mortgage Assistance Act of 1983". You must read both notices since they both explain rights which you now have under Pennsylvania-law. If you choose to exercise rights described in the Notice of Homeowners' Emergency Assistance Act of 1983, we cannot foreclosure upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving assistance. Sincerely, HOIVIEAMERICAN CREDIT, INC. d/b/a UPLAND MORTGAGE By:_Z. Benj in Reich, Counsel BR/me cc: Marcy C. Panzer, Vice President - Legal Affairs Aleta A. Spangler Loan File C\charc"cgaNac\spangter\sta".not%act6pa.hae_2 L A N D UG A G E BaloPointo Office Centre • 111 Presidential Boulevard • Suite 141 • Bala Cynwyd, PA 19004 (610) 668.1083 1.800.411.1456 0 Fox (610) 668.8316 February 10, 1999 VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED AND REGULAR MAIL Ms. Aleta A. Spangler 26 East Simpson Street Mechanicsburg, PA 17055 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear Ms. Spangler: The mortgage held by HomeAmerican Credit, Inc. d/b/a Upland Mortgage on your property located at: 26 and 28 East Simpson Street, Mechanicsburg, PA 17055 IS IN SERIOUS DEFAULT because you have not made the monthly payment of $544.67 for the period of December 9, 1998 through February 9, 1999. 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 $1,823.70, which includes interest and fees due to date. YOU MAY CURE THIS DEFAULT WITHIN THIRTY (30) DAYS OF THE DATE OF THIS LETTER, BY PAYING THE ABOVE AMOUNT OF $1,823.70 PLUS ANY ADDITIONAL MONTHLY PAYMENTS WHICH MAY FALL DUE DURING THIS PERIOD. Such payment must be made either by cash, cashier's check, certified check or money order payable to HomeAmerican Credit, Inc. d/b/a Upland Mortgage, Attention: Benjamin Reich at 111 Presidential Boulevard, Suite 128, Bala Cynwyd, PA 19004. If you do not cure the default within THIRTY (30) DAYS, HomeAmerican Credit, Inc. d/b/a Upland Mortgage INTENDS TO EXERCISE ITS 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 pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days, LENDER ALSO INTENDS TO INSTRUCT ITS COUNSEL TO Ms. Aleta A. Spangler February 10, 1999 Page 2 START A LAWSUIT TO FORECLOSE YOUR MORTGAGED PROPERTY. IF THE MORTGAGE IS FORECLOSED YOUR MORTGAGED PROPERTY WILL BE SOLD BY THE SHERIFF TO PAY OFF THE MORTGAGE DEBT. IF YOU CURE THE DEFAULT WITHIN THE THIRTY (30) DAY PERIOD, YOU WILL NOT BE REQUIRED TO PAY ANY ATTORNEY'S FEES, NOTWITHSTANDING THAT THIS ACCOUNT HAS BEEN REFERRED TO COUNSEL. If you do not cure the default within the THIRTY (30) DAY PERIOD you will have to pay a reasonable attorney's fee, not to exceed $50.00, for services actually incurred. If legal proceedings are started against you, you will have to pay a reasonable attorney's fee even if it is over $50.00. Any attorney's fee will be added to whatever you owe Lender, which may also include reasonable Court costs. Lender may also sue you personally for the unpaid principal balance and all other sums dub under the mortgage. If you have not cured the default within the thirty (30) day period and foreclosure proceedings have begun, YOU STILL HAVE THE RIGHT TO CURE THE DEFAULT AND PREVENT THE SALE AT ANY TIME UP TO ONE HOUR BEFORE THE SHERIFF'S FORECLOSURE SALE. YOU MAY DO SO BY PAYING THE 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 August, 1999. 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 Benjamin Reich of HomeAmerican Credit, Inc. d/b/a Upland Mortgage at (610) 668-2440. This payment must be in cash, cashier/certified check or money order made payable to HomeAmerican Credit, Inc. d/b/a Upland Mortgage at the address previously provided. 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 Sheriffs 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 PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION Ms. Aleta A. Spangler February 10, 1999 Page 3 TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OF THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND THAT ANY OTHER REQUIREMENTS OF THE MORTGAGE ARE SATISFIED. CONTACT THE UNDERSIGNED TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST). YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default has occurred. Hdwever, you are not entitled to this right to cure your default more than three times in any one calendar year. In addition, you may receive another notice from this lender entitled "Notice of Homeowners' Emergency Mortgage Assistance Act of 1983". You must read both notices since they both explain rights which you now have under Pennsylvania,law. If you choose to exercise rights described in the Notice of Homeowners' Emergency Assistance Act of 1983, we cannot foreclosure upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving assistance. Sincerely, HOMEAMERICAN CREDIT, INC. dPo/a UPLAND MORTGAGE By: 16,4- Benjamin Reich, Counsel BR/me cc: Marcy C. Panzer, Vice President - Legal Affairs Robert F. Spangler, Jr. Loan File L4hareficp tu4vang1cedutereq.noNct6pa.hac 2 EXHIBIT E ACT 91 NOTICE TAKE ACTION TO SAVE YOUR DOME FROM FORECLOSURE THE COMMONWEALTH OF PENNSYVANIA'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 AD.IUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CAR- GOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWN- ER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A RED- IMIR SU HIPOTECA. BoloPointe Office Centie • 111 Presidential Boulevard • Suite 142 a Bala Cynwyd, PA 19004 (610) 668.1083 1.800.421.1456 • Fax (610) 668.8316 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at (800) 342-2397. La notificion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente Ilamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado artiba. Puedes ser elegible para un prestamo por el programa Ilamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salva su casa de In perdida del derecho a redimir su hipoteca. ACT 91 NOTICE IMPORTANT: NOTICE QF 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 DATE: February 10, 1999 RE: Account No. 1011645 $50,000.00 Loan to Robert F. Spangler, Jr. and Aleta A. Spangler; Secured by Mortgage on premises located at: 26 and 28 East Simpson Street, Mechanicsburg, PA 17055. TO: Mr. Robert F. Spangler, Jr. 26 and 28 East Simpson Street Mechanicsburg, PA 17055 FROM: HomeAmerican Credit, Inc. d1b/a Upland Mortgage 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 the eligibility requirements .1 1 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 have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this Notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address and telephone number of our representative is: Benjamin Reich, Esquire HomeAmerican Credit, Inc, "a Upland Mortgage 111 Presidential Blvd., Suite 128 Bala Cynwyd, Pa 19004 (610)668.2440 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly the installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is 51,823.70. That sum includes principal, interest and fees. . 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 Homeowner's 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. It must be filed or postmarked within thirty (30) days of your face-to-face meeting. lit 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 established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105. Telephone Number (717) 780.3800 or 1-800.342.2397 (toll free number). Persons with impaired hearing may call 1-800-342-2397. 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 choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, HOMEAMERICAN CREDIT, INC. d/b/a UPLAND MORTGAGE By. Benjamin Reich BR/me ' Enclosure cc: Marcy C. Panzer, Vice President Legal Affairs Aleta A. Spangler Loan File Via certified mail, return receipt requested and first class mail with certificate of mailing f•.4hmdVegillh3elrpanglerVtate rcglact9i ps.hx PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (1) ACTION HOUSING, INC. Number Two Gateway Center 9th Floor Pittsburgh, PA 15222 (412)391.1956 Allegheny, Beaver, Butler, Fayette, Greene, Washington & Westmoreland counties (27) AMERICAN RED CROSS - COVER DIVISION 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 Adams, Franklin & York counties (5) BUCKS COUNTY HOUSING GROUP, INC, 140 E. Richardson Avenue Langhorne, PA 19047 (215) 7504310 Bucks county only (2) CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1515 Market Street, Suite 1325 Philadelphia, PA 19102 (215) 563-5665 Bucks, Chester, Delaware, Montgomery & Philadelphia counties (3) CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1031 Linden Street Allentown, PA 18102 (215) 821-4011 Berks, Bucks, Carbon, Lancaster, Lehigh, Monroe, Northampton & Schuylkill counties (6) COMMISSION ON ECONOMIC OPPORTUNITY OF LUZERNE COUNTY 211-213 South Main Street Wilkes-Barre, PA 18701 (717) 826-0510 Carbon, Columbia, Luzeme, Monroe, Schuylkill & Wyoming counties (4) CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PA, INC. 309 Smithfield Street, Suite 2000 Pittsburgh, PA 15222 (412) 471-7584 662 North Main Street Greensburg, PA 15601 (412) 838-1290 500-02 3RD Avenue P.O. Box 278 Duncanville, PA (814) 696-3546 1st Federal Plaza Suite 406 North Mill Street New Castle, PA' 16101 (412) 652-8074 Allegheny, Armstrong, Beaver, Bedford, Blair, Butler, Cambria, Cameron, Centre, Clarion, Clearfield, Fayette, Franklin, Fulton, Greene, Huntingdon, Indiana, Jefferson, Juniata, Lawrence, Mercer, Mifflin, Snyder, Somerset, Union, Venango, Washington & Westmoreland counties. (7) CONSUMER CREDIT COUNSELING DIVISION OF FAMILY SERVICES 670 West 36th Street Erie, PA 16508 (814) 864.0605 Clarion, Crawford, Elk, Erie, Jefferson, McKean, Mercer, Venango & Warren counties (8) CONSUMER CREDIT COUNSELING SERVICE OF NORTHEASTERN PENNSYLVANIA Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 655-9527 Bradford, Carbon, Columbia, Lackawana, Luzeme, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tina, Wayne & Wyoming counties (9) BERKS COMMUNITY ACTION PROGRAM Budget Counseling Center 247 North Fifth Street Reading, PA 19601 (215) 375-7866 Berk, Chester, Montgomery & Schuylkill counties (10) FAYETTE COUNTY COMMUNITY ACTION AGENCY, INC. 137 North Beeson Avenue Uniontown, PA 15401 (412) 437-6050 (412)437.4400 Fayette county only (31) INDIANA COUNTY COMMUNITY ACTION PROGRAM 827 Walter Street Box IV Indiana, PA 15701 (412) 465-2657 Armstrong, Cambria, Clearfield, Indiana, Jefferson & Westmoreland counties (12) HOUSING COUNSEL OF YORK 116 N. George Street York, PA 17401 (717) 854-1541 York county (19) HOUSING ASSOCIATION OF DELAWARE VALLEY 1314 Chestnut Street, Suite 900 Philadelphia, PA 19107 (215) 545-6010 658 N. Watts Street Philadelphia PA 19123 (215) 978-0224 Philadelphia county only (20) HOUSING OPPORTUNITIES, INC. 133 Seventh Street P.O. Box 9 McKeesport, PA 15132 (412) 664-1590 Allegbeny, Beaver, Butler, Washington & Westmoreland counties (21) JOHN F. KENNEDY CENTER, INC. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 Crawford & Erie counties (14) LYCOMING-CLINTON COUNTIES COMMISSION FOR COMMUNITY ACTION (STEP) 1221 W. 3rd Street P.O. Box 1328 Williamsport, Pa 17703 (717) 326-0587 Clinton & Lycoming counties (26) MON-VALLEY UNEMPLOYED COMMITTEE 116 Fifth Avenue McKeesport, PA 15132 (412) 678-1409 Allegheny, Beaver, Butler, Fayette, Greene, Washington & Westmoreland counties (28) NEIGHBORHOOD DEVELOPMENT ALLIANCE 5935 Ogontz Avenue Philadelphia, PA 19141 (215) 424-1111 Bucks, Chester, Delaware, Montgomery & Philadelphia counties (22) PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 100 North 17th Street Suite 600 Philadelphia, PA 19103 (215) 567-7803 c/o The YWCA 1605 Catherine Street Philadelphia, PA 19146 (215) 790-9232 Chester, Delaware, Montgomery & Philadelphia counties (15) SHENANGO VALLEY URBAN LEAGUE, INC. Housing Counseling Services 39 Chestnut Street Sharon, PA 16146 (412) 981-5310 Mercer, Crawford and Lawrence counties (23) SOUTHWEST GERMANTOWN COMMUNITY DEVELOPMENT CORPORATION 5002 Wayne Avenue Philadelphia, PA 19144 (215) 843-2000 Philadelphia county only (16) TABOR COMMUNITY SERVICES, INC. 320 S. Duke Street Lancaster, PA 17602 (717) 397-5182 Chester, Lebanon & Lancaster counties (24) URBAN LEAGUE OF METROPOLITAN HARRISBURG 25 N. Front Street Harrisburg, PA 17101 (717) 234-5925 Cumberland, Dauphin & Perry counties (17) URBAN LEAGUE OF PHILADELPHIA Urban Education Foundation 4601 Market Street 2nd Floor, South Wing Philadelphia, PA 19139 (215) 4764040 Philadelphia county only I (25) URBAN LEAGUE OF PITTSBURGH, INC. Building for Equal Opportunity 200 Ross Street Pittsburgh, PA 15219 (412) 261-1130 Allegheny county only (18) WARREN-FORREST COUNTIES ECONOMIC OPPORTUNITY COUNCIL 204 Liberty Street P.O. Box 547 Warren, PA 16365 (814) 726-2400 Forest &: Warren counties (29) YWCA OF CARLISLE 311 South West Street Carlisle, PA 17013 (717) 243-3818 Cumberland, Franklin and Perry counties Vann/act91#l.doc Revised 10/03/95 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR DOME FROM FORECLOSURE THE COMMONWEALTH OF PENNSYVANIA'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 SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CAR- GOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRE STAMO, POR EL PROGRAMA LLAMADO "HOMEOWN- ER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A RED- IMIR SU HIPOTECA. UPLANI MORTGAGE BoloPointe Office Centro • 111 Presidential Boulevard o Suite 142 • Bala Cynwyd, PA 19004 (610) 666.1083 1.800422.2456 o Fax (610) 668.8316 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at (800) 342-2397. La notifscion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia .(Pennsylvania Housing Finance Agency) sin cargos al numero mencionado am'ba. Puedes ser elegible pars un prestamo por er programa llamndo "Homeowner's Emergency Mortgage Assistance Program" el cual pucde salva su casa de la perdida del derecho a redimir su hipoteca. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS DATE: February 10, 1999 RE: Account No, 1011645 $50,000.00 Loan to Robert F. Spangler, Jr. and Aleta A. Spangler; Secured by Mortgage on premises located at: 26 and 28 East Simpson Street, Mechanicsburg, PA 17055. TO: Ms. Aleta A. Spangler 26 and 28 East Simpson Street Mechanicsburg, PA 17055 FROM: HomeAmerican Credit, Inc. d/b/a Upland Mortgage 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 the 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 have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this Notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address and telephone number of our representative is: Benjamin Reich, Esquire HomeAmerican Credit, Inc. d/b/a Upland Mortgage 111 Presidential Blvd., Suite 128 Bala Cynwyd, Pa 19004 (610) 668-2440 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly the installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $1,823.70. That sum includes principal, interest and fees. . 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 Homeowner's 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. It must be filed or postmarked within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so or if you do not follow 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 established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Sox 8029, Harrisburg, PA 17105. Telephone Number (717) 780-3800 or 1.800.342-2397 (toll free number). Persons with impaired hearing may call 1-800.342-2397. 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 choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance, Very tnlly yours, HOMEAMERICAN CREDIT, INC. d/b/a UPLAND MORTGAGE By: c? J Benjamin Reich, Counsel BR/me Enclosure cc: Marcy C. Panzer, Vice President - Legal Affairs Robert F. Spangler, Jr. Loan File Via certified mail, return receipt requested and first class mail with certificate of mailing t:kh=cNegalVuc\spanglet\state reglsct9i pa.hac PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (1) ACTION HOUSING, INC. Number Two Gateway Center 9th Floor Pittsburgh, PA 15222 (412) 391-1956 Allegheny, Beaver, Butler, Fayette, Greene, Washington & Westmoreland counties (27) AMERICAN RED CROSS - COVER DIVISION 529 Carlisle Street Hanoler, PA 17331 (717) 637-3768 Adams, Franklin & York counties (5) BUCKS COUNTY HOUSING GROUP, INC, 140 E. Richardson Avenue Langhorne, PA 19047 (215) 750-4310 Bucks county only (2) CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1515 Market Street, Suite 1325 Philadelphia, PA 19102 (215) 563-5665 Bucks, Chester, Delaware, Montgomery & Philadelphia counties (3) CONSUMER CREDIT COUNSELING SERVICE OF DELAWARE VALLEY 1031 Linden Street Allentown, PA 18102 (215) 821-4011 Berks, Bucks, Carbon, Lancaster, Lehigh, Monroe, Northampton & Schuylkill counties (6) COMMISSION ON ECONOMIC OPPORTUNITY OF LUZERNE COUNTY 211-213 South Main Street Wilkes-Barre, PA 18701 (717)826.0510 Carbon, Columbia, Luzeme, Monroe, Schuylkill & Wyoming counties (4) CONSUMER CREDIT COUNSELING SERVICE OF WESTERN PA, INC. 309 Smithfield Street, Suite 2000 Pittsburgh, PA 15222 (412) 471-7584 662 North Main Street Greensburg, PA 15601 (412) 838-1290 500-02 3RD Avenue P.O. Box 278 Duncanville, PA (814) 696-3546 1st Federal Plaza Suite 406 North Mill Street New Castle, PA 16101 (412) 652-8074 Allegheny, Armstrong, Beaver, Bedford, Blair, Butler, Cambria, Cameron, Centre, Clarion, Clearfield, Fayette, Franklin, Fulton, Greene, Huntingdon, Indiana, Jefferson, Juniata, Lawrence, Mercer, Mifflin, Snyder, Somerset, Union, Venango, Washington & Westmoreland counties. (7) CONSUMER CREDIT COUNSELING DIVISION OF FAMILY SERVICES 670 West 36th Street Erie, PA 16508 (814) 864-0605 Clarion, Crawford, Elk, Erie, Jefferson, McKean, Mercer, Venango & Warren counties (8) CONSUMER CREDIT COUNSELING SERVICE OF NORTHEASTERN PENNSYLVANIA Human Services Building 541 Wyoming Avenue Box 168 Scranton, PA 18501 (717) 655-9527 Bradford, Carbon, Columbia, Lackawana, Luzeme, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tiogn, Wayne & Wyoming counties (9) BERKS COMMUNITY ACTION PROGRAM Budget Counseling Center 247 North Fifth Street Reading, PA 19601 (215) 375-7866 Berks, Chester, Montgomery & Schuylkill counties (10) FAYETTE COUNTY COMMUNITY ACTION AGENCY, INC. 137 North Beeson Avenue Uniontown, PA 15401 (412) 437-6050 (412) 437-4400 Fayette county only (31) INDIANA COUNTY COMMUNITY ACTION PROGRAM 827 Walter Street Box 187 Indiana, PA 15701 (412) 465-2657 Armstrong, Cambria, Clearfield, Indiana, Jefferson & Westmoreland counties (12) HOUSING COUNSEL OF YORK 116 N. George Street York, PA 17401 (717) 854-1541 York county (19) HOUSING ASSOCIATION OF DELAWARE VALLEY 1314 Chestnut Street, Suite 900 Philadelphia, PA 19107 (215) 545-6010 658 N. Watts Street Philadelphia PA 19123 (215) 978-0224 Philadelphia county only (20) HOUSING OPPORTUNITIES, INC. 133 Seventh Street P.O. Box 9 McKeesport, PA 15132 (412) 664-1590 Allegheny, Beaver, Butler, Washington & Westmoreland counties (21) JOHN F. KENNEDY CENTER, INC. 2021 East 20th Street Eric, PA 16510 (814) 898-0400 Crawford & Erie counties (14) LYCOMING-CLINTON COUNTIES COMMISSION FOR COMMUNITY ACTION (STEP) 1221 W. 3rd Street P.O. Box 1328 Williamsport, Pa 17703 (717) 326-0587 Clinton & Lycoming counties (26) MON-VALLEY UNEMPLOYED COMMITTEE 116 Fifth Avenue McKeesport, PA 15132 (412) 678-1409 Allegheny, Beaver, Butler, Fayette, Greene, Washington & Westmoreland counties (28) NEIGHBORHOOD DEVELOPMENT ALLIANCE 5935 Ogontz Avenue Philadelphia, PA 19141 (215) 424-1111 Bucks, Chester, Delaware, Montgomery & Philadelphia counties (22) PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 100 North 17th Street Suite 600 Philadelphia, PA 19103 (215) 567-7803 c/o The YWCA 1605 Catherine Street Philadelphia, PA 19146 (215)790.9232 Chester, Delaware, Montgomery & Philadelphia counties (15) SHENANGO VALLEY URBAN LEAGUE, INC. Housing Counseling Services 39 Chestnut Street Sharon, PA 16146 (412) 981-5310 Mercer, Crawford and Lawrence counties (23) SOUTHWEST GERMANTOWN COMMUNITY DEVELOPMENT CORPORATION 5002 Wayne Avenue Philadelphia, PA 19144 (215)843.2000 Philadelphia county only (16) TABOR COMMUNITY SERVICES, INC. 320 S. Duke Sheet Lancaster, PA 17602 (717) 397-5182 Chester, Lebanon & Lancaster counties (24) URBAN LEAGUE OF METROPOLITAN HARRISBURG 25 N. Front Street Harrisburg, PA 17101 (717) 234-5925 Cumberland, Dauphin & Perry counties (17) URBAN LEAGUE OF PHILADELPHIA Urban Education Foundation 4601 Market Street 2nd Floor, South Wing Philadelphia, PA 19139 (215) 4764040 Philadelphia county only (25) URBAN LEAGUE OF PITTSBURGH, INC. Building for Equal Opportunity 200 Ross Street Pittsburgh, PA 15219 (412) 261-1130 Allegheny county only (18) WARREN-FORREST COUNTIES ECONOMIC OPPORTUNITY COUNCIL 204 Liberty Street P.O. Box 547 Warren, PA 16365 (814) 726-2400 Forest & Warren counties (29) YWCA OF CARLISLE 311 South West Street Carlisle, PA 17013 (717) 243-3818 Cumberland, Franklin and Perry counties Uartn/acO1#I.doc Revised 10/03/95 J ' J ?q ti !I 1 112 c 1 .. 1 p J ti I .I i- Il om: !i U `. 1 1 _I i j SHERIFF'S RETURN - REGULAR CASE NO: 1999-03010 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMEAMERICAN CREDIT INC VS. SPANGLER ROBERT F ET AL DAWN KELL , 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 SPANGLER ROBERT F the defendant, at 18:40 HOURS, on the 25th day of May 1999 at 26 EAST SIMPSON STREET MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to ALETA A. SPANGLER a true and attested copy of the NOTICE AND COMPLAINT IN together with MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 6.20 Affidavit .00 Surcharge 8.00 AA R? Fhms K i e i 0OMEAMERICAN CREDIT INC by vat t ep17 y S i Sworn and subscribed to before me this Z ?iM- day of _? _ SHERIFF'S RETURN - REGULAR CASE NO: 1999-03010 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMEAMERICAN CREDIT INC VS. SPANGLER ROBERT F ET AL DAWN KELL 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 SPANGLER ALETA A defendant, at 18:40 HOURS, on the 25th day of May the 1999 at 26 EAST SIMPSON STREET MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to ALETA SPANGLER a true and attested copy of the NOTICE AND COMPLAINT IN together with MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn a ubscribed this -'=l day of - 19,rf,GJ A.D.I 0 i 6.00 So answers: .00 POI .00 8.00 R- o Cline, 1 17 $T4-OII'HOIJE,NERICAN CREDIT 05//26//1999 by vat u before me HOMEAMERICAN CREDIT, IN THE COURT OF COMMON PLEAS OF INC., d/b/a UPLAND CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE, Plaintiff V. CIVIL ACTION - LAW ROBERT F. SPANGLER, ALETA A.-SPANGLER, Defendants No. 99-3010 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of October, 2002, it appearing that docket activity has occurred recently in the above-captioned case, the case is stricken from the purge list, and shall remain active. By the Court, Carolee Berasi, Esquire For the Plaintiff , /Robert F. Spangler Aleta A. Spangler 26 and 28 East Simpson Streets Mechanicsburg, PA 17055 Defendants Court Administrator wcy V ESL •? ?, ?,: ?,i?. ,„ .?i i....1.:1: ,. ': ? HOMEAMERICAN CREDIT, IN THE COURT OF COMMON PLEAS OF INC. d/b/a UPLAND CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE, Plaintiff V. ROBERT F. SPANGLER and ALETA A. SPANGLER, Defendants CIVIL ACTION -LAW NO. 99-3010 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of January, 2003, upon relation of the Cumberland County Prothonotary that the above-captioned case was erroneously placed on the 2002 purge list, when in fact the case had been discontinued, the case is stricken from the 2002 purge list. Carolee Berasi, Esq. BalaPointe Office Centre 111 Presidential Boulevard, Suite 103 Bala Cynwyd, PA 19004 Attorney for Plaintiff Robert F. Spangler Aleta A. Spangler 26 and 28 East Simpson Street Mechanicsburg, PA 17055 Defendants, Pro Se BY THE COURT, J /nT ? Q/. 23 .kJ ?" - :rc U.I?~ hl 7 ? ° t1? N. 57 ' c? o =?