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HomeMy WebLinkAbout07-2147Pluese, Becker & Saltzman, LLC Rob Saltzman, Esquire Attorney Identification No.: 53957 20000 Horizon Way, Ste 900 Mt. Laurel, NJ 08054 (856)813-1700 Attorneys for Plaintiff SOVEREIGN BANK ~. Plaintiff, TWILA E. RIFE Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE NOTTCE YOU HAVE BEEN SUED M COURT. ff YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH N THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENT Y (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING THE WRITING WITH THE COURT YOUR DEFENSES OR OBIECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT 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 LAWYERAT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GOT 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 1/800-990-9108 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUB3RE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIEN7'ES, USTED TIENE (20) DIAS DE PLAZO A PARTBl DE LA FECHA DE LA DEMANDA Y LA NOTTFICACION. USTED DEBE PRESENTAR UNA APAR[ENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AVTSADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION O POR CUALQ[ER QUEJA O ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DBVERO, SUS PROPiEDADES 0 OTROS DERECHOSIMPORTANTESPARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADOO SI NO TB3NE EL DINERO SUFICBiNTE PARR PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAMEPOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 1!800-990.9108 CIVIL ACTION -- COMPLAINT IN MORTGAGE FORECLOSURE 1. The Plaintiff, Sovereign Bank is a corporation having been organized under the laws of the United States of America and having its principal place of business at 601 Penn Street, Reading, PA 19601. 2. (a) Defendant, Twila E. Rife, is an individual whose last known address is 609 Cedar Ridge Lane, Mechanicsburg, PA 17055. (b) Defendant, Twila E. Rife holds an interest in the subject property as mortgagor and record owner. (c) If any of the above named Defendants are deceased, this action shall proceed against the deceased Defendant's heirs, assigns, successors, administrators, personal representatives and/or executors through their estate whether the estate is probated. 4. (a) The subject mortgage (the "Mortgage") is described as follows: Mortgage executed on: December 3, 1999 Mortgage recorded on: December 16,1999 in Mortgage Record Book 1587, page 664. County of: Cumberland See Exhibit "A," Note and Mortgage. (b) The Mortgage encumbers property (the "Subject Property") located at: 224 South Enola Drive, Enola, PA 17025. (c) The "legal" description of the Subject Property, expressed in metes and bounds, is incorporated in the Mortgage. See Exhibit "A," Mortgage. 5. The requisite pre-foreclosure Combined "Act" Notice has been sent to the ~• Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". 6. The Mortgage is in default (the "Default") because the Defendant(s) failed to timely tender the monthly payment of $577.51 due and/or to be applied to the payment due December 1, 2006 (the "Default Date"), and thereafter failed to make the monthly payments. 7. Pursuant to the terms of the Mortgage, the secured loan obligation has been accelerated. 8. By reason of the foregoing Default, Plaintiff respectfully requests entry of judgment in rem incorporating the following sums: (a) Outstanding Principal Balance $55,303.04 (b) Interest due and owing at the rate of 6.375% calculated from the Default Date through April 17, 2007. Interest will continue to accrue at the per diem rate of $9.57 through the date of entry of Judgment in rem. $1,617.39 (c) Attorneys' fees $1,250.00 (d) Title Search $343.00 (e) Escrow Due $223.93 (f) FHA Premium Due HUD $49.56 (g) Late Charges $96.20 (h) Payoff Processing Fee $25.00 (i) Satisfaction Fee $27.00 (j) Lien Search $70.00 TOT AL IN REM JUDGMENT SOUGHT BY PLAINTIFF $59,005.12 9. The attorneys' 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 or satisfied prior to the Sale, reasonable attorneys' fees will be charged. WHEREFORE, the Plaintiff respectfully requests the following relief: -- Entry of Judgment in rem against the Defendants in the total amount of $59,005.12 as previously itemized, plus al additional interest and other charges accruing through date of Judgment; debarring and foreclosing the Defendant(s), and any person or entity holding or claiming underhim/her/them, j/s/a, from the equity ofredemption; foreclosure of the Mortgage and issuance of a Writ of Execution providing for Sheriff's Sale of the Subject Property. Respectfully Submitted, Pluese, Becker & Saltzm , LLC. By: Robe ho as, Esquire Atto ey for Plaintiff Attorney I.D. No. 70206 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054-4318 telephone: 856-813 -1700 email: rthomas@pbslaw.org NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT, (the act), l 5 U.S.C. SECTION ] 60] AS AMENDED To the extent the act may apply, please be advised of the following: 1. The amount of the original debt is stated in paragraph one of the Complaint attached hereto. 2. The Plaintiff who is named in the attached Notice to Plead and Complaint is the Creditor to whom the debt is owed. 3. The debt described in the Complaint attached hereto and evidenced by the copy of the mortgage/note will be assumed to be valid by the Creditor's law firm, unless the Debtor(s), within ihiriy days after receipt of this notice, disputes, in writing, the validity of the debt or some portion thereof. 4. if the Debtor notifies the Creditor`s law firm in writing within thirty days of the receipt of this notice that the debt or any portion thereof is disputed, the Creditor's law firm will obtain verification of the debt and a copy of the verification will be mailed to the Debtor by the Creditor's law fi~7n. 5. if the Creditor who is named as Plaintiff in the attached Notice to Plead and Complaint is not the original creditor, and if the Debtor makes written request to the Creditor's law firm within twenty (20) days from the receipt of this Notice, the name and address of the original Creditor wit] be mailed to the Debtor by the Creditor's law firm. 6. Written request should be addressed to Pluese, Becker & Saltzman, LLC 20000 Horizon V'1ay Suite 900 Mt Laurel, New Jersey 08054.. Attention: Rob Saltzman, Esquire VERIFICATION The undersigned, a foreclosure processor of Sovereign Bank, the instant Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are taken from the records maintained by said persons supervised by the undersigned who maintain the business records of the Mortgage held by the Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa C.S.A. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. //~1~ DATE: ~ U ~ BY: `7' /L.c:~~ ~.c~- Name: Michele Heck Title: Foreclosure Administrator "9 DEC 16 A~ 10 Q8 ~~~--~; Q~1-15-~~~1~-~~/~ ~i ~~ ~~ ~ 1 (Space Above This Line For Recording Data) `- ~J MORTGAGE THIS MORTGAGE ('Security Instrument`) is given on ......pflf9I11~Bf ..............~ ~.~~ ....................................................................... ...........1. e mortgagor is ................................)N.l(.B.fw,..F3lfB. ........... .. ... ... . ..... ....... ... . ............ . ...... .. . . .... .. . ....... . ....... . .. . ..... ..... . .. . .. . . . ... . . . . . .. . . . . .. . . . . . .. .. . . ...... .... .. . . . ... . .... .. . . ... . ........... .. . ... .. .. . .... . . ....... . . . ..... .. . ....... ... . ........ ..... .. .... . ............................................................229..S.al~th.koala..Rdva.....~oala..P..A.1.7.025............................................................................ ........... ("Borrower"). This Security Instrument is given to ........................Her.C)5..,~.aY)flgf.sdfl{5................................. which is organized and existing under the laws of ....... Psf)f.1Sy)V,aRla ................................. and whose address is ...................................................................... ........................P.,..~?...~ax..1.7.1.1............. .Harpisblatg..P.A..J.7.J.Q~:........... .......................... ("Lender"). Borrower owes Lender the principal sum ot ..................r$.IXIy.Q.(IB..T>7A.USi~(1~...~~V.Af.I.H.URdCdf~.a.C1S~.f1.Q~~.Q~............................,....................................... .......................................................... .Dollars (U.S. $ ......f 1,7p.Q,AQ............................. ). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full deb[, if not paid earlier, due and payable on ....,danUaCy........... ~ 2Q3Q ...........This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extenalons and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the following described property located in ..........................Cr~lfT.la~CI~DS~........................... County, Pennsylvania: which has the address of ........2~9...~QU.Ih..(;.RA(a.~.CIV.2 ........................................................... .................~i1Q)Q............,.... . [Street] ................................... [cnyj Pennsylvania ..............t.7.0~5. ........ ("Property Address"); ......................... [Zip CoCe] TOGETHER WITH all the improvements now or hereafter erected on the property, antl all easements, appurtenances, and flMUres now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the `Property." BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property Is unencumbered, except for encumbrances of record. Borrower warrants and will defentl generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. PENNSYLVANIA•Single Family-FNMA/FHLMC UNIFORM INSTRUMENT Page l of 5 pages PA0I.FRM (03/91) FITECH (10/98) Harris Form 3039 9/90 eouwi5L7PasE „664 /~ - UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due the ~ principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Note. 2. FUndS for TaXeS and InSUranCe. Subject to applicable law or to a wiltten waiver by Lender, Borrower shall pay to Lender on the day monthly payments are due under the Note, until the Note is paid In full, a sum ("funds") for: (a) yearly texas and assessments which may attain priority over this Security Instrument as a lien on the Property; (b) yearly leasehold payments or ground rents on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums, if any; (e) yearly mortgage insurance premiums, if any; and (f) any sums payable by Borrower to Lander, In accordance with the provisions of paragraph 8, in lieu of the payment of mortgage insurance premiums. These items are called "Escrow Items." Lander may, at any time, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally related mortgage loan may require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act of 1974 as amended from time to time, 12 U.S.C. S 260~et seq. ("RESPA"), unless another law that applies to the Funds sets a lesser amount. If so, Lender may, at any time, collect and hold Funds in an amount not to exceed the lesser amount. Lender may estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with applicable law. The Funds shall be held in an institution whose deposits are insured by a federal agency,.lnstrumentality, or entity (including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lander to make such a charge. However, Lender may require Borrower to pay aone-time charge for an independent real estate tax reporting service used by Lender in connection with this loan, unless applicable law provides otherwise. Unless an agreement Is made or applicable law requires interest to be paid, Lender shall not be required to pay Borrower any Interest or earnings on the Funds. Borrower and Lender may agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds, showing credits and debits to The Funds and the purpose for which each debit to the Funds was made. The Funds are pledged as additional security for all sums secured by this Security Instrument. If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Bo«ower for the excess Funds in accordance with the requirements of applicable law. K the amount of the Funds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower in writing, and, in such case Borrower shall pay to Lender the amount necessary to make up the deficiency. Borrower shalt make up the deficiency in no more than twelve monthly payments, at Lender's sole discretion. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against the sums secured by this Security Instrument. 3. Application Of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs t and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third, to interest due; fourth, to principal due; and last, to any late charges due under the Note. 4. Charges; LIenS. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Property which may attain priority over this Security Instrument, and leasehold payments or ground rents, ii any, Borrower shall pay these obligations in the manner provided in paragraph 2, or if not paid in that manner, Borrower shall pay them on time directly to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this paragraph. If Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security InstUment, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within TO days of the giving of notice. 5. Ha2ard Or Property InSUranCe. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage" and any other hazards, including floods or flooding, for which Lender requires insurance, This insurance shall be maintained in the amounts and for the periods that Lender requires. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's approval which shall not be unreasonably withheld. If Borrower fails to maintain coverage described above, Lender may, at Lender's option, obtain coverage to protect Lender's rights in the Property in accordance with paragraph 7. All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lander all receipts of paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender, Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair of the Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. If Borrower abandons the Property, or does not answer within 30 days a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument, whether or not then due. The 30-day 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 referred to in paragraphs t and 2 or change the amount of the payments. M under paragraph 21 the Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to lender to the extent of the sums secured by this Security Instrument immediately prior to the acquisition. PAOl7.FRM (03/97) Fn'ECH Page 2 of 5 pages Form 3039 9ry0 ~"'~ 8001(157 PACE ' o~ Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Bo«ower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of "this Security Insirument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall be in default if any forfeiture action or prooeeding, whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture of the Property or otherwise materially impair the lien created by this Security Instrument or Lender's security interest. Borrower may cure such a default and reinstate, as provided in paragraph 18, by causing the action or proceeding to be dismissed with a ruling that, in Lender's good faith determination, precludes forfeiture of the Borrower's interest in the Property or other material impairment of the lien created by this Security Instrument or Lender's security Interest. Borrower shell also be In default If Borrower, during the loan application process, gave materially false or Inaccurate Information or statements to Lender (or failed to provide Lender with any malarial information) in connection with the loan evidenced by the Note, Including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument Is on a leasehold, Borrower shall comply with all the provisions o} the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 7. Protection of Lender's Rights in the Property. ff Borrower falls to perform the covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights In the Property (such as a proceeding in bankruptcy, probate, for condemnation or forteiture or to enforce laws or regulations), then Lender may do and pay for whatever Is necessary to protect the value of the Property and Lender's rights In the Property. Lender's actions may Include paying any sums 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 take action under this paragraph 7, Lender does not have to do so. Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear Interest from the date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 8. Mortgage Ir1SUranCe. If Lender required mortgage insurance as a condition of making the loan secured by this Security Instrument, Borrower shall pay the premiums required to maintain the mortgage Insurance in effect. If, for any reason, the mortgage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay the prerniume required to obtain coverage substantially equivalent to the mortgage insurance previously in effect, at a cost substantially equivalent to the coat to Borrower of the mortgage insurance previously in effect, from an alternate mortgage insurer approved by Lender. H substantially equivalent mortgage Insurance coverage is not available, Borrower shall pay to Lender each month a sum equal to one-twelfth of the yearly mortgage Insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to be in effect. lender will accept, use and retain these payments as a loss reserve in lieu of mortgage insurance. Loss reserve payments may no longer be required, at the option of Lender, ii mortgage insurance coverage (in the amount and for the period that Lender requires) provided by an insurer approved by Lender again becomes available and Is obtained. Borrower shall pay the premiums required to maintain mortgage Insurance in effect, or to provide a loss reserve, until the requirement for mortgage insurance ends in accordance with any written agreement between Borrower and Lender or applicable law. 9. IRSpectlOn. Lender or its agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 10. CondeRlnatlOn. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property In which the fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall 6e reduced by the amount of the proceeds multiplied by the following fraction: (a) the total amount of the sums secured Immediately before the taking, divided by (b) the fair market value of the Property immediately before the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or ii, after notice by Lender to Borrower that the condemnor offers to make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. 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 referred to in paragraphs t and 2 or change the amount of such payments. t t. Borrower Not Released; Forbearance By Lender Not a Waiver. l=xtenaion of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor In interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any }orbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; CO-SlgnerS. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 17. Borrower's covenants and agreements shall be Joint end several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 13. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by PA012.FRM (03/91) FiTECH Pape 3 of 5 pages Form 3039 9/90 eooK 1587 McE .6~i - reducffig the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge under the Note. e 14. NOtIC6S. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Addressor any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for In this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 15. Governing Law; Severability. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 16. BOrrOWer'S COpy, Borrower shall be given one conformed copy of the Note and of this Security Instrument. 17. Transfer of the Property or a Beneficial Interest in Borrower. It an or any part of the Property or any interest in it is sold or transferred (or it a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without 1andet}~, _ prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. HoweJeT 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 tails to pay these sums prior to the expiration of this period, Lander may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 18. BOrrOWer'S Right t0 R6lrlstate. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any lima prior to the earlier of: (a) 5 days (or such other period as applicable law may specify for reinstatement) before sale of the Property pursuant to any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions ere that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takes such action as Lender may reasonably require to assure that the lien of this Security Instrument, Lender's rights in the Property and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under paragraph 17. 19. Sale Of Note; Change of Loan Servicer. The Note or a partial interest in the Note (together with this Security Instrument) maybe sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known as the `Loan Servicer") that collects monthly payments due under the Note and this Security Instrument. There also may be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change in accordance with paragraph t4 above and applicable law. The notice will state the name and address of the new Loan Servicer and the address to which payments should be made. The notice will also contain any other information required by applicable law. 20. HBZardOUS $UbstanC2S. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that Is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other ramadiatlon of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 20, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 21. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraph 17 unless applicable law provides otherwise). Lender shall notify Borrower of, among other things: (a} the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 2t, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by applicable law. 22. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 23. W81VerS. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. PAOl3.FRM (03/91) FITECH Pape 4 of 5 pages Form 3039 9ry0 ,, eooK1b87Pac~ :6f7 , r •. J _ ..24. RCInStatement PerlOd. Borrower's time to reinstate provided in paragraph 1y8 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument. a 25. Purchase MOney Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 26. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a Judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 27. Riders t0 thlS S2CUrlty InStrUment. R one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)) ^ Adjustable Rate Rider ^ Graduated Payment Rider ^ Balloon Rider ^ Other(s) [specify] ^ Condominium Rider ^ Planned Unit Development Rider ^ Rate Improvement Rider ^ i-4 Family Rider ^ Biweekly Payment Rider ^ Second Home Rider BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. Witnesses: a ^ ... wile E. Rife ..~ ......~... ..... 4 ......... ....(Seaq -Borrower Social Security Number ......... ...................................... .......................... ............................................................................................................. (Seal) -Borrower Social Security Number ............................... .......................................... .............................................................................................................(Seal) -Borrower Social Security Number ......................................................................... ............................................................................................................. (Seal) -Borrower Social Security Number ......................................................................... (Space Below This Line For Acknowledgment] Certificate of Residence I, James A. Miller, do hereby certify that the correct address of the within- named Mortgagee is P.O. Box 1711, Harrisburg, PA 17105. Witness my hand this 3rd day of December, 1999. `~ Agent of ortgagee COMMONWEALTH OF PENNSYLVANIl~ DAUPHIN COUNTY , On this, the 3rd day of December, 1999, before me, the undersigned officer, personally appeared Twila E. Rife known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that they executed the same for the purposes herein contained. ~.~. IN WITNESS WHEREOF, I hereunto set my hen My commission expires: I I t _ . PA014.FRM (03/91) FiTECH Page 5 of 5 pages Form 3039 9/90 BOOR ir'1~ 17 PACE .6~ ,-. ALL THL •`;ERTAIN tract or parcel of land~'~'tith the improvements thereon erected, situate i~I"Ea'st,E~nnsbgYo Township, Cumberland County, Pennsylvania, more parrticularly bounded and set forth as follows, to wit: BEGINNING at a point on the easterly line of South Enola Drive, which point is 39 feet southwardly of the southeasterly corner of Beale Street and South Enola Drive; thence north 55 degrees east, 74.50 feet to a stake; thence north 64 degrees 17 minutes east, 47.90 feet [o a stake; thence south 35 degrees east, 9.08 feet to a stake; thence south 55 degrees west, 122 feet to a point on the easterly line of South Enola Drive aforesaid; thence along same north 35 degrees west, 16.50 feet to a point, the place of BEGINNING. BEING Known as 224 South Enola Drive. BEING the same premises which Nancy M. Stuck, single woman and Edward E. B. Pope, single man, by Deed dated June 16, 1995 and recorded at Cumberland County, Pa. in Deed Book 123 page 691, granted and conveyed unto Housing Authority Of The County Of Cumberland. _.- - ____ _--___ . _ Y _ BEING the same premises which Housing Authority of The Count of Cumberlan, by Deed dated ,? ~ n ~.~/y and intended to be herewith recorded, granted and conveyed unto Twila Rife. ~ tf~ ~• 1~~ JJ ~ z~ 7. 91 LEGAL DESCRIPTION S%=;.~ of p~nnsl'f"a~Ea _ : of'~u^~i~erfar~d~ 86 . ^; r;;;~ ~r~ ±~h~ eff . re for the recordin ,~ ~:~ !,,~ t 9 of Deads ?~%:d Co ~a f'o , "i~ ,~ unPyB, ~p•~ Crrfide, Pq his ~ rrf of c~ffic ~~ day of f corde vn »>ea~ 604K1J~i P~ ,fj69 December 3 1999 (Date] '"~"'~ NOTE `"`~" IYv2~ ~3~5 ~ Harrisburg _ P®nnsylvanla [Cltyj [state] 224 South Enola Drive Enola, PA 17025 (Property Addreaaj 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, t promise to pay U.S. $ 61,700.00 (this amount Is called principal"), plus Interest, to the order of the Lender. Tha Lender Is Harris Savingl~ fan I understand that the Lender may transfer this Note. The Lander or anyone who takos this Noto by transfer and who is entlUed to receive pay- ments under this Note is called the 'Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay Interest at a yearly rate of 6.375 %, The interest rate required by this Section 2 is the rate I will pay both 6etors end after any default described in Section 6(B) of this Note, 3. PAYMENTS (A) TIME AND PLACE OF PAYMENTS I will pay principal and interest by making payments every month, I will make my monthly payments on the first day of each month beginning on February 1 2000 I will make these payments every month until I 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. H, on January 1 2030 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the'maturlty date." I wilt make my monthly payments at P. O. BOX 1711 Harrisburg, PA 17105 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. $ 384.93 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of principal at any time before they era due. A payment of principal only Is known as a "prepayment." When I 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 Note Holder will use all of my prepayments to reduce the amcuni of principal that I owe under this Note. If I make a partial prepayment, there wilt 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. 5. LOAN CHARGES Ii a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges col- lected or to be collected in connection with this loan exceed the permitted limits, than: (I) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted Ilmit; and (ii) any sums already collected from me which exceeded permitted limits will be re- funded to me. The Note Holder may choose to make this refund by reducing the principal I 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 A5 REDUIRED (A} LATE CHARGE FOR OVERDUE PAYMENTS If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will ba 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) DEFAULT ff I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) NOTICE OF DEFAULT If I 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. (D) NO WAIVER 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 tight to do so it I am in default at a later time. (E) PAYMENT OF NOTE HOLDER'S COSTS AND EXPENSES I} the Note Holder has required me to pay immediately in full as described above, the Nota Holder will have the right to be paid back by me for a(I of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorney's teas. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by mailing It by Urst class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. MULTISTATE FIXED RATE NOTE-Single Femey-FNMA/FHLMC Unltorm Instrument Page 1 of 2 Form 3200 12/83 1004.FRM (01/ae) FITECN ~. OBLIGATIONS OF PERSONS UNDER THIS NOTE M more than one person signs this Note, each person Is fully and personally obligated to keep all of the promises made in this Note, in- cluding the promise to pay the full amount owed. My person who is a guarantor, surety or endorser of this Note is also obligated to do these things. My person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce ita rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to 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 this Note, a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), dated the same date 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 I owe under this Note, Some of these conditions are described as follows: Transfer of the Property or a Beneficial Interest in Borrower. If all or any part 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 es of the date of this Security Instrument. ff Lender exercises this option, Lender shall give Borrower notice of acceleration. Tha 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 futher notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. Witness \~'~;~~ /~~. Twlla E. Rife (seal) Borrower Witness (Seal) Borrower Witness (Seal) Borrower Witness (Seal) Borrower (Sign Original Only) Page 2 of 2 10041.FpM (01/e9) FITECH (70/98) Harris S P ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Date of Notice: February 13, 2007 TWILA E RIFE 609 CEDAR RIDGE LN MECHANICSBURG, PA 17055 Loan # 0356106663 This is an official notice that the morteaee on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paces The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of this Notice. If you have anv questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397.(Persons with impaired hearing can call (717) 780-1869)• This Notice contains important legal information. If you have anv questions representatives at the Consumer Credit Counseling Agency may be able to help explain it You may also want to contact an attorney in vour area. The local bar association may be able to help you find a lawyer LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES 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 CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): TWILA E RIFE PROPERTY ADDRESS: 224 S ENOLA DR ENOLA, PA 17025 LOAN ACCT. NO.: 0356106663 CURRENT LENDER/SERVICER: Sovereign Bank ~` M HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- 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 one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 30 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and tele hone numbers of desi nated consumer credit counselin a encies for the count in which the roe is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION --Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) NATURE OF THE DEFAULT --The MORTGAGE held by Sovereign Bank (hereinafter we, us, or ours) on your property located at 224 S ENOLA DR , ENOLA, PA 17025 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE THE MONTHLY PAYMENTS of $ 577.51 since 12/1/2006 to the present. 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 $ 1,734.74. The total amount includes late charges and any other charges that have accrued to this date. If you disagree with the assertion that a default has occurred or the correctness of the calculated amount required to cure the default, contact: SOVEREIGN BANK OVERNIGHT DELIVERY: MORTGAGE COLLECTIONS DEPARTMENT PO BOX 8627 OR 601 PENN STREET READING PA 19603 READING, PA 19601 1-800-753-7366 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,734.74, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable to Sovereign Bank and sent to the above address IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the rieht to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by paving the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writine by the lender and by performmQ any other reau~rements under the morteaee. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SOVEREIGN BANK Address: PO BOX 8627, READING PA 19603 Phone Number: 1-800-753-7366 Fax Number: 1-800-881-9334 Contact Person: Constance M. Cocroft, Vice President EFFECT OF SHERIFF'S SALE -You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may have the right to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER TIIE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (SEE ENCLOSURE) You may contact our Mortgage Services Department via E-mail at: MORTSERV(a,SOVEREIGNBANK.COM This bank is a debt collector attempting to collect a debt and any information obtained from you will be used for that purpose. HOUSING AND URBAN DEVELOPMENT ("HUD") NOTIFICATION IMPORTANT NOTICE OF THE HOUSING AND COMMUNITY DEVELOPMENT ACT OF 1987 PLEASE READ THIS NOTICE. HOMEOWNERSHIP COUNSELING MAY BE AVAILABLE TO YOU. DATE: February 13, 2007 TO: TWILA E RIFE RE: Account No. 0356106663 FROM: Sovereign Bank The Housing and Community Development Act of 1987 requires that Sovereign Bank notify eligible homeowners with delinquent home loans of the availability of homeownership counseling. Because your home loan is DELINQUENT, you may be eligible for homeownership counseling provided by certain non-profit organizations. PLEASE CALL THE HUD TOLL FREE NUMBER AT 1-800-569-4287 FOR MORE INFORMATION. If you have any questions about your home loan you may call or write to Sovereign Bank at: MORTGAGE COLLECTIONS DEPARTMENT SOVEREIGN BANK PO BOX 8627 READING PA 19603 1-800-753-7366 Constance M. Cocroft Vice President ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Date of Notice: February 13, 2007 TWILA E RIFE 224 S ENOLA DR ENOLA, PA 17025 Loan # 0356106663 This is an_official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (IiEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information If you have any questions representatives at the Consumer Credit Counseling Aeency may be able to help explain it You may also want to contact an attorney ~n your area. The local bar association may be able to help you find a lawyer 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 CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): TWILA E RIFE PROPERTY ADDRESS: 224 S ENOLA DR ENOLA, PA 17025 LOAN ACCT. NO.: 0356106663 CURRENT LENDER/SERVICER: Sovereign Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- 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 one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN TAE NEXT (30) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseli~ agencies for the county m which the property ~s located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) NATURE OF THE DEFAULT --The MORTGAGE held by Sovereign Bank (hereinafter we, us, or ours) on your property located at 224 S ENOLA DR , ENOLA, PA 17025 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE THE MONTHLY PAYMENTS of $ 577.51 since 12/1/2006 to the present. 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 $ 1,734.74. The total amount includes late charges and any other charges that have accrued to this date. If you disagree with the assertion that a default has occurred or the correctness of the calculated amount required to cure the default, contact: SOVEREIGN BANK OVERNIGHT DELIVERY: MORTGAGE COLLECTIONS DEPARTMENT PO BOX 8627 OR 601 PENN STREET READING PA 19603 READING, PA 19601 I -800-75 3-7366 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,734.74, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable to Sovereign Bank and sent to the above address IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its riehts to accelerate the mort~aee debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your morteaQed property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - 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 Sheriffls Sale You may do so b~payin~ the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writine, by the lender and by performm~ any other requirements under the mortg~. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SOVEREIGN BANK Address: PO BOX 8627, READING PA 19603 Phone Number: 1-800-753-7366 Fax Number: 1-800-881-9334 Contact Person: Constance M. Cocroft, Vice President EFFECT OF SHERIFF'S SALE -You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may have the right to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (SEE ENCLOSURE) You may contact our Mortgage Services Department via E-mail at: MORTSERV(a~SOVEREIGNBANK COM This bank is a debt collector attempting to collect a debt and any information obtained from you will be used for that purpose. HOUSING AND URBAN DEVELOPMENT ("HUD") NOTIFICATION IMPORTANT NOTICE OF THE HOUSING AND COMMUNITY DEVELOPMENT ACT OF 1987 PLEASE READ THIS NOTICE. HOMEOWNERSHIP COUNSELING MAY BE AVAILABLE TO YOU. DATE: February 13, 2007 TO: TWILA E RIFE RE: Account No. 0356106663 FROM: Sovereign Bank The Housing and Community Development Act of 1987 requires that Sovereign Bank notify eligible homeowners with delinquent home loans of the availability of homeownership counseling. Because your home loan is DELINQUENT, you may be eligible for homeownership counseling provided by certain non-profit organizations. PLEASE CALL THE HUD TOLL FREE NUMBER AT 1-800-569-4287 FOR MORE INFORMATION. ]f you have any questions about your home loan you may call or write to Sovereign Bank at: MORTGAGE COLLECTIONS DEPARTMENT SOVEREIGN BANK PO BOX 8627 READING PA 19603 1-800-753-7366 Constance M. Cocroft Vice President `~ \ ,t a ~~ ~~ E m - w = I ~y~ a° ,~~ ;~y ,: m ~~ ` =~ ~•, '- -' t1i N W Q o ~ Q .-, r a .;;~ wz ¢wQ '"~ Fx ~ m a~i ~ A LL LL d m'a LL d 1---1 ~ O O ~ CQ r ~~¢ m ~~ >¢ m N z HcvW U cm ~E _ ~m yE o _ ;ax ;~ ro~ ~ ~ti a m m o .¢m ~~ ;~ a c w e O ¢~ ~ C 'm ~~ ~ Fn `o .U QE'[L DELL SDDD OS'C2 9DDL m ~ LLa and ~ V _ m IL ~ ~ a N ~ ~ ~ 6 t m¢ >~ ~ .~ V Q~ om `° ;2z ~E mE ~ x @ ~~ . o a1 ¢W ¢w H m ~mq -- -- ~n o Sh2L DELL SDDD DS'C2 9DDL AFFIDAVIT OF MAILING ACT 91 NOTICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF BERKS Constance M. Cocroft, being duly sworn according to law, deposes and says that she is Vice President of Asset Recovery of Sovereign Bank, successor to Penn Savings Bank, Plaintiff herein, and that • on Q ~r(~f~aO(;3~ she mailed the Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, copies of which are attached hereto to the within Defendants, ~~ ~ ~ ~~>v that the required period of time has elapsed since mailing of said Notice; and that the Plaintiff has received no response from the Defendants, or from any consumer credit counseling agency with regard to the Homeowner's Emergency Mortgage Assistance Act. Constance M. Cocroft Vice President Sworn to and subscribed before me this ~ ~~~` day of~~('~(',~ 2007. n q r n Notary Pu 'c cot~~vio~~w~~~.~~~ :~r~ ;r;~~sr~:~s~rt~. Notari315'eal Shannon M. Shugar, Notary Public City of Reaosng, perks County My Commis.~ior Expires Oct. 4, 2009 Member, Penns~~ivcni€: ?ssocatior! of Notaries ~ ~ ~ ~ 1 d a ~' w "~Q ~J ~- ~Z` ~~ ~_. ~.~ r ~, c .,z -n --~ ~= ~ r°r' ~.-=T _; !.~ - _~ ";"~, ::~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-02147 P COI~IMONWEALTH OF PENNSYLVANIA: `COUNTY OF CUMBERLAND SOVEREIGN BANK VS RIFE TWILA E MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RIFE TWILA E the DEFENDANT at 1941:00 HOURS, on the 26th day of April 2007 at 609 CEDAR RIDGE LANE MECHANICSBURG, PA 17055 BRIAN COMSTOCK, SON-IN-LAW a true and attested copy of COMPLAINT - MORT FORE by handing to ADULT IN CHARGE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 10.56 Affidavit .00 Surcharge 10.00 .00 :~1~. alb ~ ~~„r / 2 6 . 5 6 Sworn and Subscibed to before me this day of , So Answers: ,~- ~,~, ., R. Thomas Kline 04/27/2007 BLUESE BECKER SAL ZMAN By. _ eput heriff A.D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-02147 P COMMONTWEALTH OF PENNSYLVANIA COL,TNTY OF CUMBERLAND SOVEREIGN BANK VS RIFE TWILA E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT RTFF. TWTT.A F but Wds unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT RIFE TWILA E 224 SOUTH ENOLA DRIVE NOT FOUND as to ENOLA, PA 17025 DEFENDANT NO LONGER LIVES AT GIVEN ADDRESS. Sheriff ' s Costs : S o answer • .---""'~ __~_--- - ~_~--~ Docketing 18.00 ~.--r '~ ~.--- ~.-- Service 14.4 0 `~ : ^°' `'! Not Found 5.00 R. hom s Kline Surcharge 10.00 Sheriff of Cumberland County .00 S~~ ~'d~l ,, -' 4 7 .4 0 BLUESE BECKER SALTZMAN 04/27/2007 Sworn and Subscribed to before me this day of , A.D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-02147 P COMMONTWEALTH OF PENNSYLVANIA `COUNTY OF CUMBERLAND SOVEREIGN BANK VS RIFE TWILA E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TENANT/OCCUPANT but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT TENANT/OCCUPANT 224 SOUTH ENOLA DRIVE ENOLA, PA 17025 HOUSE APPEARS TO BE VACANT. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 ~l a ~~0 7 n- _ ~/ 21.0 0 NOT FOUND as to S o answer - ~~ f,,,..... ~..~___ ~~ R. T omas Klin Sheriff of Cumberland County BLUESE BECKER.SALTZMAN 04/27/2007 Sworn and Subscribed to before me this day of , A.D.