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07-2533
THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein / I.D. No. 53002 Kristen D. Little / I.D. No. 79992 Jacqueline F. McNally / I.D. No. 201332 425 Commerce Drive, Suite 100 File No. 02-9132 Fort Washington, PA 19034 (215) 653-7450 Attorneys for Plaintiff MANUFACTURERS AND TRADERS TRUST COMPANY, as Trustee, on Behalf of the Holders of the Home Equity Loan Pass-Through Certificates, Series 1999-3, Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. ©? - o2s33 c v. KAREN A. ETTER AND TERRI L. HOLDER, Defendants. CIVIL ACTION -- COMPLAINT IN MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT ANDNOTICE 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 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. NOTICIA LE RAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE (20) DIAS DE PLAZO A PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION O POR CUALQIER QUEJA O ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO, SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service (717) 249-3166 Cumberland County Bar Association (800) 990-9108 32 South Bedford Street Carlisle, P A 17013 LLEVE ESTA DEMANDA A UN ABOGADO TNMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE PARA PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. Lawyer Referral Service (717) 249-3166 Cumberland County Bar Association (800) 990-9108 32 South Bedford Street Carlisle, P A 17013 NOTICE REQUIRED UNDER THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1601 (AS AMENDED) AND THE PENNSYLVANIA UNFAIR TRADE PRACTICES ACT AND CONSUMER PROTECTION LAW, 73 PA. CON. STAT. ANN. § 201, ET SEQ. ("THE ACTS") To the extent the Acts may apply, please be advised of the following: The amount of the original debt is stated in the Complaint attached hereto. 2. The Plaintiff who is named in the attached Complaint and/or its loan servicing agents are Creditors to whom the debt is owed. 3. The debt described in the Complaint attached hereto and evidenced by the copies of the mortgage and note will be assumed to be valid by the Creditor's law firm, unless the Debtors/Mortgagors, within thirty days after receipt of this notice, dispute, in writing, the validity of the debt or some portion thereof. 4. If the Debtors/Mortgagors notify 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 firm. 5. If the Creditor who is named as Plaintiff in the attached Complaint is not the original Creditor, and if the Debtor/Mortgagor makes written request to the Creditor's law firm within thirty days from the receipt of this notice, the name and address of the original Creditor will be mailed to the Debtor by the Creditor's law firm. 6. Written request should be addressed to: THE LAW OFFICES OF BARBARA A. FEIN, P.C. Attention: Kristen D. Little, Esquire 425 Commerce Drive, Suite 100 Fort Washington, PA 19034 THIS LETTER MAY BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL ACTION -- COMPLAINT IN MORTGAGE FORECLOSURE 1. (a) The Plaintiff, Manufacturers and Traders Trust Company, as Trustee, on Behalf of the Holders of the Home Equity Loan Pass-Through Certificates, Series 1999-3, is the holder of a mortgage as below described. (b) Select Portfolio Servicing, Inc., is a corporation having been organized under the laws of the State of Utah and having its principal place of business at 3815 South West Temple, Salt Lake City, UT 84115. (c) Select Portfolio Servicing, Inc. is the loan servicing agent for Plaintiff, maintaining the business records for the Plaintiff/ Mortgagee in the ordinary course and scope of business. 2. (a) Defendant Karen A. Etter is an individual whose last known address is 207 Shughart Avenue, Boiling Springs PA, 17007. (b) Defendant Terri L. Holder is an individual whose last known address is 207 Shughart Avenue, Boiling Springs PA, 17007. (c) Defendant Karen A. Etter holds an interest in the subject property as both a Real Owner and Mortgagor. (d) Defendant Terri L. Holder holds an interest in the subject property as both a Real Owner and Mortgagor. (e) If either 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. 3. (a) The residential mortgage being foreclosed upon is secured by property located at 207 Shughart Avenue, within the Township of South Middleton, Cumberland County, Pennsylvania. (b) All documents evidencing the residential mortgage have been recorded in the Recorder of Deeds' Office in Cumberland County, Pennsylvania. (c) The Mortgage was executed on March 10, 1999 and was recorded on March 17, 1999 in Mortgage Book 1527, at Page 18. (d) The legal description for this parcel is attached and incorporated as Exhibit "A" (Mortgaged Premises). (e) The herein named Plaintiff has standing to bring the instant action by virtue of Assignments of Mortgage, duly and publicly recorded as below: Assignor: ContiMortgage Corporation Assignee: Manufacturers and Traders Trust Company, as Trustee Recording Date: As Recorded (Assignment) Book: As Recorded At Page: As Recorded (f) By virtue of Pennsylvania Rules of Civil Procedure Rule 1147 (1) and 1019(g), and on the basis of environmental responsibility, Plaintiff is not obliged to append copies of the above mentioned publicly recorded documents to this mortgage foreclosure action. These documents are, however, appended hereto and incorporated herein by reference as Exhibit "B". 4. The mortgage is in default because the Defendants above named failed to timely tender the monthly payment of $1,121.44 on December 15, 2006, and thereafter failed to make the monthly payments. 5. accelerated. As authorized under the mortgage instrument, the loan obligation has been 6. Plaintiff seeks entry of judgment in rem on the following sums: (a) Principal balance of mortgage due and owing $105,698.46 (b) Interest due and owing at the rate of 9.35% $4,514.03 calculated from the default date above stated through April 30, 2007 Interest will continue to accrue at the per diem rate of $27.08 through the date on which judgment in rem is entered in Plaintiffs favor. (c) Late Charges due and owing under the Note $329.35 in accordance with the Mortgage Instrument (d) Recoverable Corporate Advances $96.35 (e) Suspense Balance < $51.86 > (fl Court Costs and fees as recoverable under the mortgage terms, estimated $ 300.00 (g) Attorneys' fees $5,284.92 Calculated as 5% of the principal balance due, in accordance with the mortgage terms TOTAL IN REM JUDGMENT SOUGHT BY PLAINTIFF $116,171.25 7. (a) The attorneys' fees set forth as recoverable at Paragraph 6(g) are in conformity with Pennsylvania law and the terms of the mortgage, and will be collected in the event of a third-party purchaser at a Sheriffs Sale only. (b) If the mortgage arrears are to be reinstated or paid-off prior to the Sheriffs Sale, Plaintiffs actual attorneys' fees (calculated at counsel's hourly rate) will be charged based upon work actually performed. 8. (a) The original principal balance of the Mortgage is more than Fifty Thousand ($50,000.00) Dollars. (b) Under ACT 6, 41 P. S. §101, et seq., Plaintiff Mortgagee is not obliged to serve Notice of its Intention to Accelerate the Mortgage by certified mailing prior to its instituting foreclosure proceedings. 9. (a) The subject mortgage is governed by ACT 91 of 1983 35 P. S. § 1840.401C, et seq.. (b) Under Pennsylvania's ACT 91, Plaintiff Mortgagee is obligated to serve the Defendants with notice of their rights under the "Homeowners Emergency Mortgage Assistance Program", by regular mailing, prior to initiating foreclosure proceedings. (c) Appended hereto and incorporated herein by reference as Exhibit "C" are copies of the Notices required, having been sent on the date set forth on the Notice. (d) The Defendants have failed to make a timely application for financial assistance with the Pennsylvania Housing Finance Agency. WHEREFORE, the Plaintiff, Manufacturers and Traders Trust Company, as Trustee, on Behalf of the Holders of the Home Equity Loan Pass-Through Certificates, Series 1999-3, demands: -- Entry of Judgment In Rem against the Defendants above named in the total amount of $116,171.25 as stated Paragraph 6, plus all additional interest and late charges accruing through date of judgment entry; and -- Foreclosure and Sheriffs Sale of the subject mortgaged property. Respectfully Submitted, THE LAW OFFICES OF BARBARA A. FEIN, P.C. BY: Barbara A. Fein, Esquire Attorney for Plaintiff Attorney I.D. No. 53002 I r 11 r 1 04/28/2007 ,15:48 FAX 21,58251201 CUSTOMER SERVICE Z015 FirstAmerican ride Insurance Cvrnp$„y SCHEDULE C NUMBER: 12906 arnd, with the •r.eted, ric"ttoi L. cook at l t t L"coouMnt. Oom mom 7NASyien4le, b`oomdAd end esquAltoa an 401-r CUSbarl..d t:oetCy, deerih.'t ea lw@, .Ltr Y 14dla.ma at a thaFFlo lat c gathe .44!41% lido of ShoghAlL A.ff to. ""',a aLt la t.o •estOw tWo o t: oghrse !whet ragftTa, to, Irh.ah "'all !h -store did. ? O t oa weld ! aee the at ad 1hMhmm A.oa.e 6 moRh 11 I"I the -ea toe !Pole! AO t4, a?uoM e? Lot /ebr a t?^ IIYY41?tly (f- fro*. .s eight Todd =."y, LtiIY? 4e if j lwdalftos Beat, ona Nll?i't ?IfIA.. ;M land gorn y of vu / left Point at Latter, 1109th 21 d F t?fl?hASt Mllloea thw.ee .2onUse j1 6. won't Outy haadvedl? s. S1 w ni4Uss It ¦egfelde rut, sigh wok AF , a o• fAL+P1 ? 961 goes to A lwiwt At th. aesn.s mlhatae "mat, o. nor ° a°Oe along us letter, geuth'?! d. Ilf]:etl .l:.t to .un de.d °i~ Aed of ht n i !etas, the oleee of AM MINC, eNea hW dlfde n whlehh712" Lot a., a ci4 a 11 . An of Lot. k,., An ghogkArt, A regard" And "r e"barl44d CAeeeY, Pthe' ..sylraglA. 1N jankrl? jN??., . !0? ehugkaLt 'kv m.. wractsd a d"ouia4 heoee koooe And sYrtte:etl .,. •1 r BEWO THE SAME PREMISES whkh Tcni L. Holds Oelober 27, 1995 in Ibt Accoraer•, Office In hod for CumbeGrl nd CoA. Elle uM r PA tlladR?ecord Book 17u, a? ,f. Bad conveyed unto Toth L. Holder uW KArco A. Etter. , r.l Curapan.x.r;! PA-) I:<; •?,.•r i Igo Ull a for Om come n?? tied lad Cv, [OOM1S?7PACE 24 hr„?B V^ 1 At yhfe^ ( f? r 1 In. Corllda r? " hel:rngr?/ /? -• r 11 • 1 04/26/2007 1.5:47 FAX 2158251201 CUSTOMER SERVICE X009 rCCEftT :'. ,°IfGIER QVI?O C?. r " ?Cf; 0. » rJs I CUi•iEi1L@.:;0 P:ZLINT :"-r.1 199 N 17 AM 11!0 Prtcd NeMbN: P J~ Am" T& Lim r4r aw4iry pawl Pumm Off Tor MORTGAGE LORI A 0606676397 ftiffIVINOT C/o cm:cmicxsahos 104 ¦ m? MARLWA?W ILVD, AT= 104 LAN V29A9, NV 60102 r W MOR70AOB ('11amr)ey IYCmsu') Is given on ow A OVER and TVRAI L NOW= NASwb 20th. 1999 .71c IIWTllmotIN ('Rortowta'). 7110 3O W41Y Immiinew b Pir•A m corlTZHORroaod CORPOAITSON whk6 Is orptiite/ and ciislins I Amr (be laws of DVt AYARR at10 Wheat addmill 390 I, ItARNiNPisR 10", ¦ASIM0, PA 10000-7430 ('Ladcr9. k rower own Le, der IIIe vdmlpei man of cps sunup THIAr'm T90CIAND POOR Runs= a 00/;OO Dolun (U.S. 3 310,400.00 ), 7111 debt is eNdemed y U"Wer'9 raw anted dle male dole m tbi. Sewdly L invirow ('NOW'). wt dt OrWA&t for a khtY peynwnlr, with Ibe WO dcbl, if rot pfd set1hr, doe and payable on NasOA 10, 201P . 7)179 S.twlty Itrirormm &mm 0 under: (r) IR. rrpaymad of dY deb[ OeldtliCd by 1179 N&A. With 11 1bat, and 40 r armfa, crteYlone sad mOdlRealbm or die Note: (a) die pwmmu or all Olb.r ewY. wbb ba•m.I. M.emed wtdw prpaple 7 in Oreow to m&mW Of Ihlr 3ewrip 4tlnuorw; and (e) prallll.me of Brrrol er'e enveteaY ¦I d ap oom wdcr Ibb 3pi wiry bmwvn d ml Me Note. For We putpoee. Parrowcr dote hwft mm Up. pain rod cwM to lader die frlbwly der dbed propnry Iocald In e mberlaeid CWAW, Penmylvoraw oaA mm=XP •A. wNe1 hY 1119 iddrma Of 207 0110121ART Avamm. I0IA1,10 IPRpIOP yt,ea,yl9,119 17007 [tipc•dd ('PmpmyAddrm'): 91tNW5nVAMII . Supie FWAY - YN"PRLMC 0IIA9oRr1 WPRIARM 1`1104031911011 ,..I1WA) Iwle Am 11.4 O91 wruslMNro9w-?aN111I1 ?d .._ paoKi527 fwe 18 111111111 'a .a 11 a 1 a 1 04/26%2007 15:47 FAX 2158251201 CUSTOMER SERVICE 1 i Y ..I X004 i, .. X11. . TOGFrOM WTTH W the 0 ilimvmsw mew or bameec tltlad as rte mropery. ad all el krrow. apput"Ma, obd nemrea mw or hemahar a part of hri property, AN replaoaai m ad addfoms rhWl on be wvem by tld• Swarity Iaautuneu. Au of dm haF ft it refereed a r Wit BsuAw Immuni e u tam 'Prepaw BORROWIN COVIENAN" wr swimmer la uwhpy Pakod of der sae hereby ecniryed N I hot the eyM a toollpue. pwit.a tsasay the Prpaty OW an the Properly If Wearumbered, aeaept hr fccumbrawa Of m nmd. Bcrmirm wartamt ad wNl del* pat:rally am Oda to On Properly molar mLL dd m W tmtdl, a h*1 a may arwbrie man of rewtl. TM SRCUR1'IY INMVMWF asoMms ttdhim ism he auiaal un and ara,erif m eeve mta wkh Iimikd "Modem by jerladkmtm to Comedians a vothrnm smdw ladbuu m cGrAma red prom. UNIFORM COVR ANU. Borrows um Leader ?osmarN Pet{ ahtam Of h0 m: 1. Nyumot of rdndp d mad Imaramrl Propaymmit and Lots Cbt¦aw. Benawu abPA pimply pay whas lee me prAclpW of amd idereal es tN debt plMoold by W Now Yd aw mewy mein mad lam dwim On it der de Noe. 7. Puma hr Tuna mad fasteadta. lubjeet to APP901de law or a a wrbtm wmlvmr by V Met. Beerower chill pay a lends an the day moodily payaaora w AW ender dry Now nest ea Now is Paid In h41, r cum r laiuda•) for: W yarw auo WN ormaaawto which nay Arlo pdmAly over OW SmAdw Ins - m u alien an rob Prepa0l: (i) yearly I"Whdd Paymaea er pmhsd ram am the property, of erg; (c) yearly herded of popery Iaamamm pmmmmal (d) yarly tided Ilwummme Presluar, W arty: (e) Yet* mompp Lnuaooe p-gWria, If OW; mad (a aq am pgaWr by haerewor to L der, M acartdwa with the provides of paruraph t. In Kau of ft pWy of amsrimmlo kwtam a pandiame. Thane ion as cwbd •Twtiew hem lector ttuy, at mar fine. eblim and bold Pat In a manes m to travel the ma ifte amt a keels fbr a lodemgy related m r pe Imo my require hr Bmvw*i moon aaaert vw*r Ow Irdo l Real lboft hW km Pmeadas An of 1974 me rmiad floe dude a haw. IT U.S.C. Jecdom 1601 eta, ('MPAr), aalsm amrhor law rya apl r a to the Nmdm meta m ka'mr amm,ae_ If ao. Lamler may, a wag fimw. aulort and hold Pud¦ 10 as armmt not a oneed In hear pmelmt. Lawar may afar; site mriwimt of Puny due an 0te hark of cur. x data tad rawrrble er{hrlda of npeadlmd is of lase Harrow lure at aquwlme in Weoedare wldt applicable law. no Pura shill be held Is m loviiation wheat dreemict am haamd by a hdcial lmawy, I man =WIW. or entry avakwint Lender. U LaMar If rocs ma ladudr) or In wv Pdual Hord: Loa Bent. Leader daN apply he Palm to pay the Bwew harry. Larder nwy mmt 0W ja harrows for holding mid applykt tae PA&. actually ar4hrl ah der wsew actatmu, or veAhiom the liaemw trees, wilam L adem payer Dertewer Ia - oat dw Piodm and oppurblt law purAge L tiler a rents smb a dbwpc. _ However. Linder my manse Borrower to pay a am.dmC carp hr rob hiltmmtet rd eau i e upatla t Amite thud by LAMor In wrowodom with 6b loon, usku applic" late presidia othew4e. Unket mA agmeme a if rode or applicable law ngpima !rant w he pid. Leader Wwu ms be replied a pay b uirws may Wriest or aruipp on der Pnde. bnowcr hid lends may arena is writhy, however, the Imariel mime ho odd err dry Put. Lender rwu dry r aeeroaer. wlehari aharar, N anal a mmiating of the Fwak. duwly uedlio sad akbbm is as Pods mail re Int" far which rani dehir a the Pao war made. 'due Fuadm are pkdpmd u adds law sorrily be YI rarer lmpxd by 0is 3%*w hamrmm. If dw Pws4 hmW by seder trimmed die wwaar pardsd a be-hold by epplk" law. todar i haN meow a Borower hr the tam Pods In wor4ance 11th as rogdmvwm of op"Is law. I(ft laous of the Transit i all by laden u Wry dine If not roe9riaa to pay the Bacrow lu= what dm. Loder may to waft Bmower bt wrI t, ad, In arch came Borrower shah pay so Lander do sawn .d.aay a realm p the Malaey. Borrower all nuke p " ddlcl. cy is sin mow den twelve -ahly paymew. at Leadn's solo direadon. Upao payment is fdl of W sum armed by dala Undly Imulmtn, Leader WMN promptly to !tad a Bonowar coy Purim held by Lender. If..rl I pats aph 21, lade AW aapda at tau dim Propm. ladu, prior a dry mo¢damee or mak of rot Rapes, ebWl aroly any Pwrds bald by Longer at ft dam of moguldueo or aid me m credit aim ui dry ammo aersed by Wa Sewriy hwrruodu_ a. AppUadon of Pgm"A& Udau applic" law provl4u opwwtu, so pyrmarm Maim by Longer radar pamBeapa and 2 Aoll bo applled: den, a may paepaymwa d"m due trade elk Not, end, to areal : payable under puammph 1: third. is dtaeu dung hueth, is pliadpq due, and laW, to any laic dame dW minds die Not. 4. Charier; L OU- Borrower mtmb pry all aim. NNAM m, &am. Ow tad lmpakfa n aNrlbuable to sin Propmeq which any ty" Priority doer Oda Swi iq lawmen, mad WMdWW phyrimirm u tmeud Balm. If I cry. /ermwer All] Pqy there obtioio.a is the imamate provided V paeepmpb Z, or If mr poW Is them dormer. Dot corer mall pea chair on drd directly a WC penm owtd pbylwraL Barrows mat pro"M Burma a Larger di mdma of L"Wasm to be l aid mite"paragraph. It Borrow alma dim pgdma dlrmfy. Bormwh Mall imirs" hrelmh is Laden meeyu avideac mil Be pamm ts. Borrows alua pmew y' dkd.rpa aq 0a st" liar priority ever dale Satrdw bamaam IN bin pare -,a: is) mar=s in weldna a the paymm at of sir obilplmthn ostatd by der Ire V ¦ fatigue aoepable to LmedW: (b) t aura" In good fabh the Van by. or defender mplat erdaa¦mes of the Iles ht, lop) Praeaad"p width la die Ledsiarm or owe epaawa a peeves the cnhrtsaan of tin 111111 err (1) aaromo ten Its holder Of Ito Ilea w apratme "henry a Le der aftrabodng fie Ira to " Suurlq li mwmat. If Leeds dunink a dw wry part e(Ao Property is abjen to a ties whle n may mule, priority over ddi Saurlty lmruser, !seder in" give borrower • rodeo Ilemffylag es Nam, borrower "I aaadl Ali der at take am or owe. of She tedsre sea fare above wtmk 10 das fir dry thing of rider. A -.tarPA) M./ ti/rl •la,a, -ra oom(1527Pd1iE 19 0010 'a 11 m 1 a 04/26,'2007,15:47 FAX 2158251201 CUSTOMER SERVICE S. Haswd ar rraperly Iromwo. lorry. flab tmsp die IMFV%W arm mw erialy car heath ehsrtad on malt properly INafed /plat Loa by An. hazards hretbdad within the arm 'aaredmd wvww, 6ml my ages mm rdl, including floods of no"all, for wbkh Under mgtklram ltlmdra[. nim Wudeaare 40 to, weInd In maw arm" and fa tie period, mm Loader galska. Ilia km um carder pmvww Me Imurun alrll to hewed by Mltpwr mtbjM to Lodee's Ipprovdl which $hall not k tUnn=Wy wlt)1mM. If !mower aWa in addIRmh1 eovervIo kit" above, Lender my. at Ladar'f apdan, obmin W'%rfpe a link. Lamder's do's lit the property is araardom arm Pgrsph 1. All Inswaraa polklep ad ramwai shall M otapebk to Lander add doll Include a auahd morq spa e1Swe. Ignitor 3411 have the We to hold as ponder and reaewdk. If Lead.t regdra, dara.At Assn prorpdy she to L moor all reodpat of pole prtrdraa mad rental rarI In the aver of loer, leoliaww? ball giro prompt /mace a the teanlrmm a rrler and Larder. Lander may slob proof of hoe tram Risk promptly by tomposir. LMka. Latahlar and sm Asset odrer.l.a Was In w WW Imam Pfoeda anal! be apptkd ld n ttarallad or kdper or llhD Properly dm ug". Y der rerlwrdon or rt pair as eemmddeely larhk ad Landetr aeeurly Is no ko med. it the remstmiee as mp4t It one amimmla Wy bWbk or Loom's smie y world be lumratd, do' whmret paom4 she I ba "Jud to the pros waded by eta Secrrlq lasivinum, whether or Iwl drew due, with OW AARaa paid ss so *-'a. 11 leribwes abatdow the hopay, or dace amt armawr within )p it" a .tee from Leader vital the laatedoce carrier has artiv od to scale a claim. Mtn Walter may, eolltet dv bwna a plaeeede. Labe dry me the promadA a mpei or common Use hops y a so Pq mum asr,smd by iWo Stn wW Wwmerr, wLA wror dot that &a. The )Oday paled will be& wWt the mncg is qw a, UOau Lerida more lanoww oberdme SSW in wMdeed, aw gppliealtR of plooegh a primood air It sat eeund at pardon me due data of 119 no" Payamas Rhmin! in la para6lpW 1 alt 2 or di epe rite amudM of tit pqi arm. If vndv pr+yraph 21 tho rrapny is aegrdred by La der. Oorrewerl w4lin to any Investors, polkkr amt proaaWa am I1r1a from danoW to the Prvpery prior m mass aogd.ldmt slid "AS a LM*f a be !ogre of mar dam mewed by this Saaarie - Immahaa lamnadlaaly prier to the acqubldaL 6.Ooebpmgr promenades rr Melmlaamise well rvalarlem of the P.wlarty. Borrower's Laub , kptlkedsom Lumholdt. 9ortvwer abali oeeWr', taaablkh. ad vast do R"uly AS lorrawam's p I It noires within day d rya ah" hie eatfmdon of this Smmwby Instrument ad shall aw mr to aocepy die hapery Y 1119r100R'a pnomW M WW= for sit least we year glass she tae or eom*eey, wdeas leader obawlw AFM its wflty, width team slap flat k msmeaoen ably w*JWW. at anhds uterawlrr dam mhmmnmt trial which ue leyo d llaneder'1 carol. emrawer Shall not earthy. duty a or ItpLmlr the Property, all- mm trepan w Omtae4eeata6 or .oink waste so We Pe p m, loltaaar doll be in dormh l ' arty htfdhrre action or pmoveaq. whaler Gill or c"nal, lie begtur mat h L.etder'd pad filth IhdVmx eaWd moll In bt Mom or use property, or fahefwlae Iiakrially bnpalr the Ilan .,read by this Saamily Imimnem or Lader'f Seeurlry lrvatUL 1 orrvwmr racy cum dud) it d.1" and nMsum, AS prwidd In pon6yaph It. by amlm the dada or praoeodlop to be dbmW sd wtm a initial owi. in Ludo's pose Wilt dercrmimrien, ilmiudeA Inklorre of der larverm's barm M die Pio,M or adi if smieflel Wsind"nom of IM Ilan eraamd by M Smmiiy laMMnerr of Lfdrev etcrrity Irereml. lorroaar ahaN @No le In dabs 11 If Be 9--m. during the loan appflWlon pro m#, OK mmarilly hie ar imamrait lobrmrdmof eildmrma to Leader (or IWI d to provide Isrder with any rrmAd bomad* In earalectlal with the damn avldeeeel by mate Neu, hicholkhs. but fret 11 called to, mptawmmlom carturmiap voreissee'r wA-vpmmq of map Propnq car a priw4d remldence. If No Soculty laswrmod in on a losgaid, porrewor .Wall coohply Who all mt pmrblom of the lease. If So some atadrn pe one m IM Prapany, Inc Iran hold and flu he elk .1111 not merpe mats Later oprme to the soon M wicking. 7. pivitmo a or lavilsr•s W#u In the Istvpe iy. If lmlvrya Was to perform the cwrmee a aamdrraae contained in shim Stuoriy ummbmgM. or dote i g IoW pmeeedkit that nay SlpmUkanlb *UWA Lader1 rW- I 1 the Property (-,h on a proeamdlng In bmkripley, prober. her eerdaomden at hrklrre a to aefarea laws W nbaladetm), dm it La+dmr may do and pay for w/ataver Is newsery m protect as value of ere Pooperty ad 1~6 ripe in the Property. List der's mptaAS rmy Include ptylyd any mode nowed by s Ikn which has poorly curt All Security knout am, Wsewint in taut. P kylnp masormblt aararrwye lets need eoevhlp an the Property a make repln. Aldmssph Latest may mkz action wda ddb pahptaph 7. L.erder dnf am have m do to. Mss'strIRYaI dislmuaed by LaMar wWa Ibi patepaph 7 that brI -- addMmW dos of tornswe Secure/ by this Smamiiy Irmeunwas. unlem eam.awtr and Lmatrr mom a other rtmr or prayrma. Ipso mroaums Akan beat Immrrr from the dale or dhtaua m of aims Note sae aed she! be payable, wide tderse, rpm nodor I-R Rader a larvawr i tquadrt Pkvftm. 1. Morays IWWWWa. if Wader lW4kd mwkW IWrmnme a a caadlBee of maWap do sm h oared by mda Sgsurlry Inaw, raem, Donewm meat pay me pmaNvras reghirsd car mabrla she manpga IrewMH M Alto L If. la sly swan, din awmpps hmbtrrpe eavtldp sagvW by Under ldpmm of eeaaa a be is after, Doto-do Ahab pay him prelitma trued in ohleel coverall; smbsmmoy agldaaknl as der ANmdye Imomflu inmrloute 10 Mao, IS a coal mud NRdally colwum m ft set a Narrower of tints mostwo IM1mda prnleq In 97M. dam a ahpmmte rra/lp6t laws r apt. by Linder. If sulmmmbdly mpivalafl msgW Irmosstre ewmrga b no moolasbke, Lompoc AIM pay 1a.Lrnder a eeh month at sun! equal ro fre,iwal h of the yearly menpaas bsawsa a pmmiuar beat poll by BwnWcr Wilson, Ike IuWmc cat /rye lapu)d or awed to to in effeet. IeMer will "I, me dad rendn data paymmNS ¦ m has reserve in Ilya or manse io Iruuvane.. Los tvi-e Q011 P6- wr -ja(PA) Miss Pw3do Iot11527 PACC 20 r r 11 e 1 r 04/28;2007 15:47 FAX 2158251201 CUSTOMER SERVICE IMyrner+. toq ro longer he tequlyd, s Ow option of Lender, it dsmgye lmurmee eewye (Igo 0:1 eewem w Ibr Ids Paled gem Lra0er IrgWros) jor"A d by a Nerve sppnvgod by Lrhdw ryeh bsrmau avallahle And Is ebs rood, llenowcr WY ply des psesdsum m imed a ssaielia mor"s, lemweca is di or to pmwW a less trove, still It r ngWrotmn b wenpgt Imsapw _ds la acraedalmc wi0r goro wvllsta tnglelmepl bateme BO nswsr d (AMU er eppBable sw. IF. In>w loon. Lander K Its Oita bay Nola eransabk Istria spas sd Irpeodsrw of drm lir,ty. Lena -Wl gift sanewer "Wes ds me dne of or prior a so Imi oedes epedl),ly cam@Ak canes for the Inspection. so. CaRdemlmtlen. Ina pleeealo sf s0' sMld a tdshll Mr OeeWed, alto m msesglre W, b tmstctlY wish erD' mdstnsmdon or odor leldeg of nq pest of du Preputy, or (m sw"ymu In lieu of cardemtnok n, are beret' atip.d Led "I be pad to lardar. Is dal Irma N r toll mum of an rmpcrw. be plttemds Yet be applied to do room secured goy dW S.onlry lmuunml. nth dwr or net dwe ate. wldl arty emu VOW to Renews. In de ...el of a pudd Wasp Or 6 Property In wNee doss hit inorkst value of Ibe Prapsty ksstmdhm)y bebm rive raft k Iqud m or Oedsa IbM Ole Maori if to sum; saved by ibis Sawrhy tsssusswu Idemedlslsly balloon: dw Istla6 w1w lwsewer and LeMbr dttvwles mgrs Is v siring, oleo root amuod by tNs Savrity Insunssl aball d RAerad y cur &memo of de praadt wedriplkd by to hbwlt 11 wdwl: (el dm toll aomome .if dim dud nausid imsedisab before Wo sldsgy "d by 0) die foes Rm" scion of door Prep dry Wwom ly edam die isldae. Ally bskree dol be paid m Rumme. Ig Oro sue of a "I oft of dw Property In owl lab rite hk onsubt vets or the Property idew&*Iy bfoew dso"u lot d1Y dos rooms, of do cute wurod lsnsedls" y kRme dw slldm, usdrp Borme r and LAdr amerwin ality in wridt m uder applksble law edmMrv peeldw. dm pro seeds sWl be spplkd to du ssmp saved by Wk Swslry W ntm em odtethcr m amt me wtom w the rise. It she hsoperty Is sbeetdaoad by Renewer, or If, char setla by loader to Bdsmsseir msr rite or Idemes O&n to melon cue award a soft a el" fee dignspa, BWMM ills to rgesd Is leader wllWe 30 days alter dw del r tW sedat In gives. Isds,r It audtortud to rulers and eppy Wt pNCdd?, Of 14 dpdY, anew to wtmallen or tcpmk of die Pn,xM or to Ibt sums aotltrd t,y"Security looms, whsher a om fat due. Unless Lemdar and Barsaear olbnwlIC rpm le wAdet. UV spplimiea of ptmemmds a pdsnclysl hall lot canero m pipes; nbo due des; of the nwW* pyrrnsest rsfwted so An "room 1 and Z of c"o se aims else! I oysmes. IL. Bonvwm NA Rskwd: [arbsrena h Under Not to Welliver. EaWlsien of dm ribs I x linnet or medllleuieo roof smdstaatas of at ruam aomed y two SesWlty Im miti m gromd by uuu a 11w M=Mot 11 Imcm e(bmmner limn root operaso to elm- des WWI(W d Lt.e ar(iplal So w.itt or RlwowdsY stebnessen in !moss. L& des ahml gods be repdwd to consomme ptwowdlop ageism sty MOMW In bum of Mbse m owd die No pstyrmtd of other else modlly mpld=um v( ., _ nit Irons secured by girls Setnwily Irssmrss by wesoe of alb' dewed wads by die eriosl Burrows r or borro w's mcceson in Ideran. Apy raebeuarlp by Leader In asilry{ep any d& or pnedy WWI not be a waiver of w pedlude One eaue4e of any right a Ias*. 11.19 - good Asltim Beund: told Ind Ssir" Lability; (prippsa. 71w wi asemd fed tOeertamU of lhk sec.wlty Intervenes aWl blood WW beeln it aaesimm Ws, melgm er Lodi ad Summer, I dtlem w nee provWeem of t-AMPWh 17. Berswer'1 avenues Red apaetnestb droll be jolm and teverel. Amy Berserner, rte p44M drip Security Iminsom bur des oral ssseuns die Nam: (a) Is Is,-Iraq dda Srwdq bWSmedt ode to mm" lit. post Yd nowt dot bonnswer'm Imcrat In Ow hw(W w*v rite krvw of two 3O sky blow a mi: (b) q so PMSYmO:' Wymidt se ley nM slum astUred by f.it SwAu* ImWwm: w (e) mAlas down Leader ud eq edw Beerowar may aces b catei mod(ly, beam a babe sow wwwwdedom with nWd w she seems of 01 Sww* Idotdat or me Nee Mama As Borrower's carmen. U. Les CltdrBw. I(lhs ba rental y eels Sodolty lermttwsM ls lslijwt u a Isw weW t w oaslsnls brI therga, and that low is finally ii ss.p.aW b dint mm isomn or edw ism eltwgn aAocled or w be contests in camradoa Mlb dim lout .;load des pcslsad lids. 16m: h) now ha k" Asp olmll be NdK d y des mom metedssq to rodoca dm 6" is the peneisee tinrt: w (b) will, Posts a4eady, eaWeted from Barrow wkkb uaadsd p mwd*W limiw w 0 be vdyndrd to stainer. Lender air eberees to sake 16ls refund by rafting ate pdwou owed trdtr des Now m by m atlt a dint psysrisi to Bonewer. If a refund roved" pryppel, des redustan will be trmted as a prdd PeO4rrnant veld two wp prepoyroenl owl. UOPer ft New. 1t. Nalleego. Any rout. so Berssovcr provided fort In dal Smw* bstsdtds BmB In oved y e env"" It er by Mali" to toy first West oat Ylest epplemble now rgWrm use o(wtofwr erOed. Toe Rodeo thdl be Akers a nee Papery Add- or my edge address Boneaev daelpatm by sotk- is baler. Amy wiles, to (Anndar shat be given by Arm else and to Lender'. AMU caries ttemin m wry Odw Wdrtw Ldgodrr drNNm(n by Radom m Remover. Any tsstlta p nMOd for Is this Sorority, enter oorrlt Ihak bn designed to bab boa sired w Do I er a Under orka diva to pwMed in Us t wad..plt. IS. Covering Law, 56 so Mop. Tb4 Security Imiesew hell in wanted by rodent Ids cad dw Ian er fm judedlet" in iivto I ft pmpm(y le least. to tR ovew tool any provllim cur chime of this am db Instrument w the Noe imnAhss wide appllcabk kw, oath reaAkt shall gom aAkt e0sr pcwAskm of d.4 Ssw9ty (Tlrud1e t or at was .Wee can be. Iiw,, effect winli un tie eanflledsg pr.r41un. To this wee dim pevv;uam of this Security Xw W=nI I Rd dW NOW in distend to in sevesble. ? ..ARIM? Mna p~ ]ma? gars ?.rr.: rowc1527?gc' 21 16012 YJug? -• r 1 1 ?ft!12!almm r r r . 04/26/2007 15:48 FAX 2158251201 CUSTOMER SERVICE 0013 Id. hafowet4 Copy haeroaer ahaY be gam ems edaNfMN mpy nt eb Node and o/ rids Seewrlq Imtrvlrevt. 17.7Mwlhr r Iw w A ioteflr>.1 [rtsant r emu. It dl or act par11 tad to hops ty er airy itmraes in ib 'r raid at uwAxred (or If a be=&W Interval In harrower to raid or Yaarhnoit and ai rtvwa? is not r rmel l pateae) wldmar Lavkr'r prior wom emwarq Loader may, at is soon. layman Iavadliar paymw In loll of all rim sensed y` rats' So urity Ir¦"ononaL However, ibis gdar shall not be tUft eg by Balder If axmdK is pgNblted by Waal L w u of The dots of ads sm,ft Irsirdn". It Lender carmlaea ride oision, Lelda shpt gin 8orrvww notice of ewaltn6oa. i10 rtodee Mall pt uldc a period of not ILLS. duo IO rips (=a ere due The make Is d 5mad or railed widds mhlith Ilenewer not pay al tan .cared" ado Stctairy INarueeaL 1f heflower tab to pay deer awe prior to •e expired" at aria period, Lcadrs arty in.otr May ream" p mkkd by this 3eadt , IronubnerM widow furaw mdca or demand en honvwer. 11, lwrewarra Rlgbt to Rabolak. If hornvosr now eeraale ran diWau. Bid Owl altbll h eve the right to have entowcoro t or tide 3aoarb Governed drwmumrd r aay dm petor ea the artier W. (q ! days or such ahcr period a., applicable has nwy rpaelry toe idmO? berm Wa at me Aapeny p?rpaa?? b AV power d rare c mained Insecurity Irwtrwrdlnt; at ?) maesRyy or a JlydVrme Ask" rhk AMWIy tmawwrw. ties.lenders a- tent limo ear. W pay. fender an "woo wMeb 60 waoM he de vier We SmHW hrrmaea alp de Nm an If m aeoduaion had raafnd: (b1 claim any delhvlr of way ad0r wvwmo or ameaoao; k) P" alt aynma tkon" In antordeg Ohio Savrlry k liniment. irchsding. but rat limited w, ateroobk vim" -,7s' for, ad (p ubnt awh 9911114 110 Leader Way MUMMY «golre be a loft 11011ad flan of this drawly Imirwo rla. LANw'a Agra in ht ltaporly and 1111"m is olllSatten n Jay live aau a and by rhk Security Iestrowrd A" easlow wwww". Upon rdalNmm by bnawee. this Sccbrd0r hwbnmeer and doe ebmpdone ..cued hereby anal tvolm hl(y 9ffW9ve a its= acwebatbv had oeand. However. rids right tow relatale she' I rot apply In d.G earo or raaelenllw later paryrapb 17. it. Sol* J No* Choose of /.nea Sarpar, 77re Noe at a podw Intarmrt is du Now (iol tier with baba Saorriy IntnroveAo may be sold ante or mule door wimma prior adoc b tlarrvwvr. A oak logy revolt In a Can on in fa early onnews were 'Lads servkcr') ho alkats memhly payloads do mda lk Note ud this Socuily Irruuawnt. ' hue ere rttg be One or more wraagm of tic Lead tdr*w uarclowd to • We of is Note. V dwae it a elop at a0 Lawn L vleet, harrower will be gives wrlan mdse or /e ehaege N amid= wih pmn?oph Id New AN BRIkaMe law. The Notice wpl slab rho rwnc and Address of the raw loan Servleer W der address to Nddr panreas should he&. ?ha wide rep rbe contain awry other Intaaostkn nowirad by apycaMa law. 70. IYfsMrr /uhsfdow. lerrawer doll err ranee err preset ak pnmatre. woe, disposal. or wage. or release of any Nruedas Smbatnas an or in it prgQy, lwnew shat rot do. we abar "not she is do. bu a last It to ...ladder at my Raesraamenol Law. The parody two saallessi era bra tpgy a me paten a mot, of tlwn ? ee Nsfeaty of ,rill( gaAantlp of Hmttloro SVbrrrsea tut Am b w %Yy ftaglired WTI appropriate k mrmd raldentkl door and to malaeamce of the tlopely. sonewer shall to 9 PA give larder welmen nodose of wry hvnttlgsloo. c(dre, deword, towail or other action by am, govetmmenw or R lay Army of privaa parlor involving Iba poopaq pd my twaf/aw SVbaaaaa of Fnvkmmkfbal Law o/ wMch hailer Ibaa scbW Ioawwdw, If honerwa lamoo. or k raYlaa by ay p irvese s" or legal guy whahy. dot airy rew l M odeor reamdtodan of Any Haaslda" gvbsoawe aNallle do IRoprra b ftoe eery. lorrowe • .hall pra"lly tare all aceamry rooadk) wale tow to wxordara with Elplrwttwlwalol Law. As wed in W¦ parabpb 20. 'Hal¦rdaa Son ,tea time Williams demmd m toxic of I amrelow rubnom by 11"0110101al law and the Ibllowbbg wbsWcn: /ualiae. lmftaer0, a11wr fantrook OF toxic R relevwr producer, texie rmhelda std let rMddn, vokdk solvesto. M"Ala emaWng snooks err fmtoolsi ile. old radisacu no rwmsriar. At used in IMs panuaph 20, 'Wpm--m of law• mranl federal tows And Isws of dk jor(rdkdon vent the prop my it laested tW rcJre to hsltb. a" Or cavltamsrasl pr•occltm. NONUNIFORM COVENANTS, Borrower And Lewder Ihmhhr tavaono nW state a (blows: 21. AcceJenllr; Raaadles. LAndar shad live nodix 1• lmrwwr prior to mar aluldw [allowing /orrtrwar's breath of cry ortmal or sg?Aemoaa in Wh Sosrrlq instrument (but no odor to asoeksvllaw wbder proarsph 11 micas applicable low prlovids aWerwbN, rwnder pall natty lod- was of, uoeag alker ttbp: (a) lbs, lefbull: (b) the action requil ed to con Iho etohmlt (e) where ere ddawk not M and; wad (d) Ihwt Idiom to lira IPA de blot u apaellad may mull In eecehrelwn of lea raw eosvng by Ode formally lukum f. Madswel ?y Jwdlelal Prot tsding stet "Is or the property. Leedar oral farther lairs RAnvvrer at the rlght to relrado4 they aoultmon said au right to sawn In the rer"Woues prole "Sibs nosadskaee ar A defAWC err aIq attar fbt[alre trf layrower r amNerwt m tad fendoun. If ono de?.fo..W..t4k.. not and All spalkdr Leadort lit Ib eptlm, any robmhe hwtwdtole peyment In IWI of all rune seeand by Ihb S+oon* IImlrlwmraa wllAeul furflow darAnW and perry NrWw thin Ssoully Imlrla atom b; JudlcIM prweadbtg. Leader o l be .mold go edlect alt expenses laturrod la gawrmlag the mor des prwAdled IN this ps vgnpb 21, Including, but not Ilmhod to, anonkM' top and nrO of Igfa epdeom Is 110 mlmt pwml fd by appaobk Iaw. 21 Redeem. Upon pgwwa at al mum wnn,l by iris serwsiry taswimear. ads seculry Ia alma it end obe estate conveyed Allen krrrllaw u d brcatk veto. APer such Omfic cc, Later .hall diftl rga and utrly IN$ 3ecurly Instmrwn whhar large to Bormawer. ffwmw sill pop any rec ndolbA cats. 23. WmIna. larrewer, to the exielrt pcreniasd by ¦pptablo tow, walva and reltarea any ajar or kfrell in prottedings to cAraae fast Swinly InAWAkaa, lad benby VAIM flow batefk of say pettln or Nmle towl provldle I fa stay of cuatiat, exwuinn or time. exompdon from ahochworw, kvy ad ode, lad bwnwwad awnpnlon. A -AX(PA) 0.0 PA Farm 3W 51001527nce 22 ?'J'? -? .r 11 1 04/26/2007 15:48 FAX 2158251201 CUSTOMER SERVICE I t .n . iu.i .. , 21. RrJleYbwtrtt ?0110- Borraasr'a rhea to tobrum provided to prwW 11 .halt "K td w eft baw prior to dK catteimeeaaR0 of Olddiy m a thrriQY sale or "m 'AN @ellt+a to Oda 9earYy 1n.nmKet. Be[leeltr b legato rils la 2.1. pv.&.I a ManMt WSL lr awd e daemad y riOadlfy bufumm V lent t to pmpaq. Ode Sm rtW kwwmm "I be a pombac raoW VW WW. 26. IrearM Rasa Ahw 7edpemt. eoetoe: WM dee lM lNOW tote pyrr afar a jd ILK N efaetod aA due Nok or hien aetlon or monpde wadotwe -hall bs dr totepy/ble from Lima to fore u der the f10fe. 27. Riche re ebb Security Imbi m"L Ir one or imre ddcm us tx=o w !y Dourer" Y 1 Twmad loport wldl m 3cmdrl remamed• uN tvrmew vol vmmuft of weir wdh rider "be k mgdmd INO erd -bell urraed std uypkmea the eerefro m rd apeemwoso of ride Swurby I!@Ym1Y U It ft Itdup) Rue a pn Of title dewlty lrtranRte. CAeak Is" box(es)) ( AUttINN Raw Rider ? cadeodrert Rider l-A ' --ud{y Rider Oraduetd hwmos Wrier ? FlWo Vitt Oralop-mi "I Dies tkly h7won Rider BlJtom Alder Rah 6tProvetttenl Rider Sam ad Nom Rider VA Rifler 04-0) (IpmIry] Sy S1oN(No www. Bortotrer w o ad mr- la 69 arm and teas twain" in d ie securiq lannmml sod If ?N rido(o) eaeeumd by Aetmm pd tototdtd rids h. w'itmeceo (Sett) KAM h eTM •asrrea+t Tlh= L SOLDIM W..uatr tlrap (leap -'laser .1or"vr cant a at RIidom n+ar L: ?•ya•?l- 1 as Ivey x mlfy OW dr maeN.dderaa of , duviWM M lrela 3d7 !, 111rv..:nslaa-'71?•r 04, b.ae ,T46 i9eyt wluw my MW tide /e /A day d M.,-C$L • A4r AP04104 IPau comma WBALTu OF rPoo LVANIA, PJ/ eat b4'(ie"'d totally o pn tde, oK 1o cut dey or reaede ] 9!! bt bn me. OK wdcrt p cd *f @ccr, p-may app-A Kamm x 12TU end T W=. L eOLbR pwretd' whoea damtd lebedrild to do a.e AW We amt ht ate oerpotet kttln ooalabazd. „ Re wn?gw wweneor, l hmuuer to q WTI My Comde.MR 8apiew. ; ' Imewd N is (a adommilly reveal m be On end eelmrvrltdpd dter "At rev nM ]ale WN 12014 " I4011527nd a 23 Select Portfolio Servicing, Inc. PO BOX 9003 Temecula, CA 92589-9003 7113 8257 1472 3355 3386 Payment Address: Select Portfolio Servicing, Inc. Attn: Remittance Processing P.O. Box 65450 Sall Lake City, UT 84165-0450 Correspondence Address: KAREN A ETTER Select Portfolio Servicing, Inc. 207 SHUGHART AVE CustomerService BOILING SPRINGS, PA 17007 P.O. Box 551 170 20070302-55 Jacksonville, FL 32255-1170 LRO64 ' ?? 1 I {[ I X111 '??' lY lI ,? ? • ?' LI Y '1?JIB .l ? \\II„ ,,?+ 0 Ilk ., t PRESORT First-Class Mail U.S. Poslage and Fees Paid WSO sps,?, 03/01/2007 KAREN A ETTER CERTIFIED MAIL 207 SHUGHART AVE 7113 8257 1472 3355 3386 BOILING SPRINGS, PA 17007-9783 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in defaulit. and the lender intends to foreclose Specific Information about the nature of +he default is provided In the attached pages, The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM fHE P) 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 hen liThe name, address and phone number of Consumer Credit Counselina Aaenries seryina you 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 f800) 342-2397. Persons with Impaired hearing can call f717) 780-1869. Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUSTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COPRENDE 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 PROBRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Homeowners Name: KAREN A ETTER, Property Address: 207 SHUGHART AVENUE BOILING SPRINGS, PA 17007 Loan Acct. No.: 2086763972 Original Lender: Current Lender / Servicer: Select Portfolio Servicing, Inc 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 nrr_I IR WIT141KI T4JC wlvvT i?n? n--- ,.- _ __.. _ -__ __ _-- LR064 PAGE 1 of 4 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 counseling agencies for the county in which the property 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-to4ace 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 (Brine it up to date) NATURE OF THE DEFAULT: The mortgage debt held by the above lender on your property located at: 207 SHUGHART AVENUE BOILING SPRINGS, PA 17007 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Payment of $1,121.44 per month due from 12/15/2006 through 02/15/2007 payment (a total of 3 months): (Mortgage payment includes Escrow Payment of $180.29 per month): $3,364.32 Accrued Late Charges: $282.30 Non-SufficientFunds (NSF) / Return Check Fees $0.00 Escrow Advances for Hazard Insurance, Real Estate Taxes and/or Municipal Liens: $0.00 Other Advances (Property Preservation) $0.00 Funds On Account: ** Total Amount Due: 51.86 $3,594.76 Funds on Account typically represent a partial payment of principal and interest received that cannot be applied to the loan. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use If not applicable): 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 $3,594.76, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashiers check certified check or money order made payable and sent to: Select Portfolio Servicing, Inc. LR064 PAGE 2 of 4 PO BOX 65450 Salt Lake City, UT 84165-0450 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 attorneys' 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 Sheriffs sale. You may do so by paying 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 writing by the lender and by performing any other requirements under the mortgage. 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: ADDRESS: PHONE NUMBER: FAX NUMBER: CONTACT PERSON: Select Portfolio Servicing, Inc. P.O. Box 65250 Salt Lake City, UT 84165-0250 (800) 635-9698 (801) 293-2600 Desiree Phillip 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. A'bUMF I ION OF MORTGAGE - Under the terms of your mortgage and note, it may be possible 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 find out at any time if your loan is assumable by contacting your lender as provided herein. YOU MAY ALSO HAVE THE RIGHT TO- ¦ SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBTOR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ¦ HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ¦ 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 RIGHTTO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ¦ ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ¦ SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. itc 16%k LR064 PAGE 3 of 4 If you wish to dispute your delinquency, you may do so by providing a written dispute to SPS at the following address: Select Portfolio Servicing, Inc. Attention: Consumer Advocacy Department P.O. Box 551170 Jacksonville, FL. 32255 You also have the right to bring a court action if you claim that the loan is not in default or if you believe that you have any other defense to the acceleration and sale, including the failure to send proper notices of the acceleration and foreclosure sale. We are also required by law to inform you that if you notify us that you do not wish us to contact you by telephone at your place of employment, then no such contact by telephone will be made. If you are represented by an attorney, SPS will work with your attorney. We will also work with housing counselors, consumer debt counselors and other representatives with your written authorization. If you are represented by an attorney, this letter is being mailed to you to forward to your attomey. We will release information to your attorney without further authorization. If you wish to have information regarding you account provided to individuals or groups other than your attorney, your signed written authorization (including your social security number) is required. If foreclosure is initiated, additional amounts for attorney fees and costs may be incurred. These sums can be significant and will be added to amounts due. This may reduce your equity, if any, in the property. SPS provides consumer assistance programs designed to help resolve delinquencies and avoid foreclosures. These services are provided without cost to our customers. You may also be eligible for a loan workout plan or other similar solution. If you would like to learn more about these programs, you may contact a SPS representative at (888) 818-6032 during the following hours: Monday through Thursday, 9 a.m. to 10 p.m. Friday, 9 a.m. to 7 p.m. Saturday, 9 a.m. to 1 p.m. Eastern Time Sincerely, Select Portfolio Servicing, Inc. This is an attempt to collect a debt. Any Information obtained will be used for that purpose. APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY Aoom Housing Adams County Interfallh CCCS of Weslem PA 14 S. 131h Street Harrisburg, PA 17104 Housing Authorily 40 E High Street 2000 Linglestown Road 717.213.0150 Gettysburg, PA 17325 Harrisburg, PA 17102 888.511.2227 717.334.1518 Community Action Loveship, Inc. Maranalhe Commission of Capital Region 2320 North 5th Street 43 Philadelphia Avenue 1514 Derry Street Harrisburg, PA 17110 717 232 2207 Waynesboro, PA 17268 Harrisburg, PA 17104 . . 717.762.3285 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 LRO64 PAGE 4 of 4 Select Portfolio Servicing, Inc. PO BOX 9003 Temecula, CA 92589-9003 Payment Address: Select Portfolio Servicing, Inc. Attn: Remittance Processing P.O. Box 65450 Sall Lake City, UT 84165-0450 Correspondence Address: Select Portfolio Servicing, Inc. Customer Service P.O. Box 551170 Jacksonville, FL 32255-1170 7113 8257 1472 3355 3515 TERRI L HOLDER 207 SHUGHART AVE BOILING SPRINGS, PA 17007 20070302-55 LRO64 PRESORT First-Class Mail U.S. Postage and Fees Paid WSO N 03/01/2007 TERRI L HOLDER CERTIFIED MAIL 207 S HUG HART AVE 7113 8257 1472 3355 3515 BOILING SPRINGS, PA 17007-9783 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the mortaaae 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 paaes. 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 Counselina Aaencv. The name. address and phone number of Consumer Credit Counselina Aaencies servina 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 (800) 342.2397. Persons with Impaired hearina can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUSTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COPRENDE 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 PROBRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Homeowners Name: Property Address: Loan Acct. No.: Original Lender: Current Lender / Servicer: TERRI L HOLDER, 207 SHUGHART AVENUE BOILING SPRINGS, PA 17007 2086763972 Select Portfolio Servicing, Inc. 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 LR064 PAGE 1 of 4 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 coi-inselona county in which the property 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 Ad. 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 (Brina It up to date) NATURE OF THE DEFAULT: The mortgage debt held by the above lender on your property located at: 207 S HUG HART AVE NU E BOILING SPRINGS, PA 17007 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Payment of $1,121.44 per month due from 12/15/2006 through 02115/2007 payment (a total of 3 months): (Mortgage payment includes Escrow Payment of $180.29 per month): $3,364.32 Accrued Late Charges: $282.30 Non-SufficientFunds (NSF) / Return Check Fees $0.00 Escrow Advances for Hazard Insurance, Real Estate Taxes and/or Municipal Liens: $0.00 Other Advances (Property Preservation) $0.00 Funds On Account: ** Total Amount Due: 51.86 $3,594.76 ** Funds on Account typically represent a partial payment of principal and interest received that cannot be applied to the loan. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use If not applicable): n?„rv ?, ?.urt H 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 $3,594.76, 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 monev order made payable and sent to Select Portfolio Servicing, Inc. LR064 PAGE 2 of 4 PO BOX 65450 Salt Lake City, UT 84165.0450 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 attorneys' 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 Sheriffs sale. You may do so by paying 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 writing by the lender and by performing any other requirements under the mortgage. 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: ADDRESS: PHONE NUMBER: FAX NUMBER: CONTACT PERSON: Select Portfolio Servicing, Inc. P.O. Box 65250 Salt Lake City, UT 84165-0250 (800) 635-9698 (801) 293-2600 Desiree Phillip EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs 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, - Under the terms of your mortgage and note, it may be possible 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 find out at any time if your loan is assumable by contacting your lender as provided herein. 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. ¦ HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ¦ 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.) ¦ ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ¦ ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. L ¦ SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. LR064 PAGE 3 of 4 If you wish to dispute your delinquency, you may do so by providing a written dispute to SPS at the following address: Select Portfolio Servicing, Inc. Attention: Consumer Advocacy Department P.O. Box 551170 Jacksonville, FL. 32255 You also have the right to bring a court action if you claim that the loan is not in default or if you believe that you have any other defense to the acceleration and sale, including the failure to send proper notices of the acceleration and foreclosure sale. We are also required by law to inform you that if you notify us that you do not wish us to contact you by telephone at your place of employment, then no such contact by telephone will be made. If you are represented by an allomey, SPS will work with your attorney. We will also work with housing counselors, consumer debt counselors and other representatives with your written authorization. If you are represented by an attorney, this letter is being mailed to you to forward to your attorney. We will release information to your attorney without further authorization. If you wish to have information regarding you account provided to individuals or groups other than your attorney, your signed written authorization (including your social security number) is required. If foreclosure is initiated, additional amounts for attorney fees and costs may be incurred. These sums can be significant and will be added to amounts due. This may reduce your equity, if any, in the property. SPS provides consumer assistance programs designed to help resolve delinquencies and avoid foreclosures. These services are provided without cost to our customers. You may also be eligible for a loan workout plan or other similar solution. If you would like to learn more about these programs, you may contact a SPS representative at (888) 818-6032 during the following hours: Monday through Thursday, 9 a.m. to 10 p.m. Friday, 9 a.m. to 7 p.m. Saturday, 9 a.m. to 1 p.m. Eastern Time Sincerely, Select Portfolio Servicing, Inc. This is an attempt to collect a debt. Any information obtained will be used for that purpose. APPENDIX C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES %.umaCrcLAlVlu L;UUNTY Acom Housing 14 S 13th Street Adams County Interfaith CCCS of Westem PA . Harrisburg, PA 17104 Housing Authority 40 E High Street 2000 LI lestown Road 717.213.0150 Gettysburg, PA 17325 Harrisburg, PA 17102 888.511 2227 717.334.1518 Community Action Commission of Capital Loveship, Inc. Maranatha Region 2320 North 51h Street Harrisburg PA 17110 43 Philadelphia Avenue 1514 Derry Street , 717 232 2207 Waynesboro, PA 17268 Harrisburg, PA 17104 . . 717.762.3285 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 LR064 PAGE 4 of 4 VERIFICATION The undersigned, an officer of Fidelity National Foreclosure Duly Authorized Officers on Behalf of Select Portfolio Servicing Inc. the instant Plaintiff, or its servicing agent, being authorized to make this Verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are taken from the records maintained by persons supervised by the undersigned who maintain the business records of the Mortgage held by 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. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Dated: t 3t) a©n OQOL- Name : c vxC i 5f rl q7" 4n Title Supervisor Company: Fidelity National Foreclosure Duly Authorized Officers on Behalf of Select Portfolio Servicing, Inc. 1V w O 1 d N 1 N t._J l.? CD O T M-71 f N SHERIFF'S RETURN - REGULAR t *tASE NO: 2007-02533 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS VS ETTER KAREN A ET AL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ETTER KAREN A the DEFENDANT , at 1753:00 HOURS, on the 15th day of may , 2007 at 207 SHUGHART AVENUE BOILING SPRINGS, PA 17007 KAREN ETTER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge "'qw1e) I ?;, 18.00 4.80 .00 10.00 .00 ? 32.80 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 05/16/2007 BARBARA FEIN By. A. D. SHERIFF'S RETURN - REGULAR Z C...'ASE NO: 2007-02533 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS VS ETTER KAREN A ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE HOLDER TERRI L was served upon the DEFENDANT , at 1755:00 HOURS, on the 15th day of May 2007 at 207 SHUGHART AVENUE BOILING SPRINGS, PA 17007 KAREN ETTER, ROOMMATE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing Service 6.00 00 le Affidavit .00 'I ' Surcharge 10.00 R. Thomas Kline .00 6)301 i ? ? 16.00 05/16/2007 I BARBARA FEIN Sworn and Subscibed to By: before me this day D ut Sheriff of A.D. THE LAW OFFICES OF BARBARA A. FEIN, P.C. Barbara A. Fein / I.D. No. 53002 Kristen D. Little / I.D. No. 79992 Jacqueline F. McNally, Esq. / I.D. No. 201332 425 Commerce Drive, Suite 100 Fort Washington, PA 19034 (215) 653-7450 Attorneys for Plaintiff MANUFACTURERS AND TRADERS TRUST COMPANY, as Trustee, on Behalf of the Holders of the Home Equity Loan Pass-Through Certificates, Series 1999-3, Plaintiff, V. KAREN A. ETTER and TERRI L. HOLDER, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 07-2533 Civil Term PRAECIPE TO SETTLE, DISCONTINUE, AND END TO THE PROTHONOTARY: File No. 02-9132 Kindly mark the above referenced matter settled, discontinued and ended without prejudice to Plaintiff. Date: September 11, 2009 THE LAW OFFICES OF BARBARA A. FEIN, P.C. BY: Barbara A. Fein, Esquire Attorney for Plaintiff Attorney I.D. No. 53002 RLEU--(;,H,'iCE OF THE P?C;+9jr,)NIOTARY 2009 SEP 14 PM 2.4 0