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Home My WebLink About01-0316 FX~+IcCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Bankers Trust Company of California, N.A., As Custodian or Trustee 10790 Rancho Bernardo Road San Diego, CA 92127 v. Calvin L. Bull 2 Wheatfield Drive Carlisle, PA 17013 and Deborah K. Bull 2 Wheatfield Drive Carlisle, PA 17013 Attorney for Plaintiff Cumberland County Court of Common Pleas Number Q~ - ~~~ ~U~C CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE You have been suetl in cwrt. tt yw wish to tlefentl againrt the claims set forth in the fOllowi h9 p@9es. you must take attton witni0 tw@nty (ZB) days after Lois complaint an0 notice are servetl. by entering a written appearance perswal ly o~ by. attorney ono filing in writing with the cwr[ ywr Defenses or ghgect~ons to the claims set forth against you. You are warnetl that if you fail to do so the case may Proceed without you antl a jUtlgment may he enY.eretl against you by the Cart without further notice for any mosey cl aimetl m the canplaint or tar any other claim or relief requesteo oy the plaintiff. You may lose money or Oreperty or other rights important to yw. AVISO l¢ han DemandaDO a ustetl en la Corte. Si listed quiere D¢fenderse de estas demandas ex-puestas en las paginas siguieMes, usteD gene veinte (Zg) Oias tle pLazo al partir tle la Pecna de to tlenantla y to noti ficaci w. Hate folio asentar lino canparencia escrita o en persona o con un ahggatloy entregar a la torte en Pons escrita sus Oefensas o sus oojectones a las tlanantlas en corrtra tle su ppersona. Sea avisado que si ustetl no se tlefientle, la torte tomara metlitlas y puetle coirtinuar la oenanoa en milts suya sin orevfo aviso o noti ficacign. Ademas, la torte puetle tlecitlir a favor tlel tlenantlarrce y requiere apue listed curpla can totlas las pprovisioner tle esta dananda. listed pueQe pertler tlinero o sus propietlaaes u otros tlerechos importantes pars ustetl. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. Cumberlantl Cwnty Bar Association 2 Liherty Avenue Carlisle. PA 77013 (717) 249-3166 LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO ALA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIlt ASISTENCIA LEGAL. Cumoeridnd Cgglity Bdr A5s¢Ctati on 2 Liberty Avenue CAN isle. PA 17813 (717) Z49-3166 McCABE, WEISBERC, AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Bankers Trust Company of California, N.A., As Custodian or Trustee 10790 Rancho Bernardo Road San Diego, CA 92127 v. Calvin L. Bull 2 Wheatfield Drive Carlisle, PA 17013 and Deborah K. Bull 2 Wheatfield Drive Carlisle, PA 17013 Attorney for Plaintiff Cumberland County Court of Common Pleas Number p 7- .314 t_,e,~x.x 7.~<,w~-. CIVIL ACTIONIMORTGAGE FORECLOSURE 1. Plaintiff is Bankers Trust Company of California, N.A., As Custodian or Trustee, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Calvin L. Bull, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and Yiis last-known address is 2 Wheatfield Drive, Carlisle, PA 17013. 3. The Defendant is Deborah K. Bull, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 2 Wheatfield Drive, Carlisle, PA 17013. 4. On October 25, 1996, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Advanta National Bank USA which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1349, Page 650. 5. The aforesaid mortgage was thereafter assigned by Advanta National Bank USA to Bankers Trust Company of California, N.A., As Custodian or Trustee, Plaintiff herein, by Assignment of Mortgage which will be duly recorded in the Office of the Recorder of Cumberland County. 6. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 2 Wheatfield Drive, Carlisle, PA 17013. 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due September 2000 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following amounts are due on the mortgage: Principal Balance $145,062.56 Interest 8/1/00 through 12/31/00 $ 6,087.87 (Plus $39.79 per diem thereafter) Attorney's Fee $ 7,253.13 Late Charges $ 317.16 Corporate Advances $ 7.75 Escrow Advances $ 820.48 Cost of Suit Appraisal Fee Title Search GRAND TOTAL $ 225.00 $ 125.00 $ 200.00 $160,098.95 9. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 10. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. X403) and notice required by the Emergency Mortgage Assistance Act of 1983 has been sent to Defendant by certified mail on the date set forth in the true and correct copies of such notices attached hereto as Exhibit "B." WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $160,098.95, together with interest at the rate of $39.79 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgage property. '~ TERREN McCABE, ESQUIRE Attorney for Plaintiff VERIFICATION The undersigned, Fran Cullins, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within action, k eXS ~'~ J S ~_ COvn~1'JGr-tivy Q~-~ cc~ - , and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. X4904 relating to unsworn falsification to authorities. r ~~~ FRAM CULLINS Z ~,~ ~~0 5/>I.k.,. ~~~v~ S~ ~ ,... NAEN RRCORDED, NAIL T0: , .. Advanta National Hank IISA w ~= ~+ n 16675 NRST HERNRRDO DRl'VE ~ ~~ n ,n f^ v r. SAN DIRCO, CA 91127 '' 'r cv _. ATTNr DOCWffiNT CONTROL ?~ r^ ... r . Faecal Numbu: _ ~ ~ __ C G P .. m .. [Space A6ave 7hie Line Fm Recording Data] 1~ ~ ~ ~_ MORTGAGE ,v ' ~' THIS MORTGAGB ("Security Insfnunent") is given on October 25, 1996 .1'he mortgagor is CALVIN L HOLL and DBBORAH R eDLL ("Borrower"). This Security Instrument is given m Rdvanta National Hank DSA which is Organized and existing undef the laws of fH7ITSD STATHS OF AMERICA ,and whose address is C/O 16875 -PEST eRRNARDO DRIVE, SAN DIEGO, CA 92127 ("Lando").Borrower owes Lender the principal sum of ONE HONORED FORTY RIGHT THODSAND SEVEN H7NDRRD TNENTY FIVE 6 00/100 Dollaza (US. $ 145, 725.00 ), This debt is evidenced by Borrowu's note dated the same date as this Security Insuumen[ ("Nate"), which provides for monthly payments, with the full debt if not paid eazlier, due and payable on November i, 2026 .This Securiry Inattum:nt secures w Lender: (a) the repayment of the debt evidenced by the Note, with interest, and aU renewals, extensions and modifications of the Note; (b) the payment of all other sums, with inures[, advanced under paragraph 7 m protect the security of this Security Instmment; and (c) the perfofmance of Borrowu's covenants and agreements undo this Security Instrument and the Note. Fnr this purpose, Borrower does hereby mortgage, grant and convey m Lender the following described property located in eumberland County, Pennsylvania: All that tract or parcel of lanfl as shorm oa Schedule °A° attached hereto which is iacorporated herein and made a part hereof. which has the address of 2 -7HEATPIRLD DRIVE CARLISLE Pennsylvania 17013 [lap Caael ("Property Address"); PENNSYLVANIA • Single Family • FNMA/FHLMC UNIFORM IN54PUMENT Form 3999 9199 ®•6H(PA)(9s+oi pmendadl2/93 sooK~349ra (i VMP MOaTGAGE FOaM3 ~i000i521-7291 /J.q(1 Page +of6 Inalalz: T)C P~ EOLL [Sreeq Cityi, .1 a TM073787-., ii .~ , ~w .»a,.~m... a n.. s;+w ,.. ... - P"'. ~. .~ 7'OfiETHER WITH aB the improvements now or hereafter eror.'ted mro ,da, ;{acgeryy,. aad'.all easements, appurtenances, and . future's now or hereafter a part of the property, Alt replacements and a9d'ttirn,b:atraftl:Alme ila.eatveied by this Security Instmmen[. All of the foregoing is nferced m in this Security Instrumem as the"tTuagiaaM1y-° BORROWER COVENANTS that Borrower is IawfuLLy seLced of ~ xsrdm!br~:F~ amrnxsyed and has the right m mortgage, grant and convey the Nioperty and that the Property is unencumbexeds ~xcefatror enouuthraeaa of record. Bortower wartants and will defend generally the fide m the Property against all claims and demands,.subject mauevcsa,umbrances of record. THIS SECURI'T'Y INSTRI1IvfENT wmbines uniform covenants for aafional sesE atra§ rant-uniform covenants with limited variations by jurisdiction m rgnafimre a uniform security instrument coversrtg real propeaav UMFORM COVENANTS. Bturower and Lender covenant and agree ss follows: I. Payment of 1"r'mcipal and Interest Prepayment aad Lete Charges. Bormwa~ slkall prompdy pay when due me principal of and interest on the debt evidenced by me Note and any prepayment and late cheegw,s due under the Nom. 2. Fonda For Taxes and Imsorance. ~ Subject m applicable law or m a written .waiver by Lender, Bortower shall pay m Lender on the day monthly payments are due under me Nom, until me Nom is paid in ttiB, a sum ("Funds") for: (a) yearly taxes and assessments which may attain priority over mis Security InSWmem as a lien on the Property; (b) yearly leasehold payments or ground rents on the Property, if any; (e) yearly hazard m property insurance premiums; (d) yearly flood insurance prettdums, if any: (e) Yearly mortgage insurance premiums, if any; and (t) aay sums payable by Bonawer m Leader. in accordance wim, the provisions of paragraph 8, in lieu of me payment of mortgage insurance premiums. These items are called "Escrow Items." Lender may, ac any time, collect and hold Funds in an amount not m exceed the maximum amount a lender for a federally related mortgage loan may require for Borrower's escrow account under the federal Real~Esmm Settlement Procedures Act of 1974 as amended Cram time m time, 12 U.S.C. Section 2601 et seq. ('R&SPA"), unless anotherJaw that applies m the Fords sets a lesser amount II an, lender may, et any time, collect and hold Funds in an omount not m exceed the lesser amount Lender may estimam the amount of Funds due on the basis of torten[ data and reamnable esdmams of expenditures of fugue Escrow Items or oherwise in accordance with applicable law. The Funds shall beheld in an insfimtion whose deposits are roamed by a federal agency, insuumentality, or entity (including I.ender. if Lend¢ is such an institution) m in any Federal Home Loan Bank. I.enda shag apply the Ftmds m pay the Iscrow Items. Lender may not charge Borrower for holding and applying me Funds, annually analyzing the escrow account. or verifying the Escrow Imms, unless Lendea pays Borrower intense on the Fords and applicable law permits Lender m make such a chazge. However, Landes may require Borrower m pay a onetime charge for an independent teal estam tax reporting service used by Lender in wmecdon with mis loan, unless applicable law provides otherwise. Unless an agrcemeat is made or applicable law requires interest m be paid, Lender shall not be required m pay Borrower any interest or earnings on tie Funds. Borrower and Lender may agree in writing, however, mat interest shall be paid on the Funds, Lender shag give to Borrower, without charge, an annual accounting of me Funds, showing aedits and debits m me Funds and me purpose For which each debit m me Funds was made. The Funds are pledged as additional security fm alt sums seemed by this Security Instmment If me Funds held by Lender exceed me amounts permitted m be held by applicable law, Lender shall account m Bortower Cor me excess Funds in accordance wim me requirements of applicable law. If me amount of me Funds held by Lender at any time is not sufficient m pay me Escrow Items when due, Lender may so notify Borrower in writing, and, in such case Bortower shall pay m Lender me amount necessary m make up me deficiency. Borrower shag make up me deficiency in na more than twelve monhly payments, a[ Lender's sole discretion. Upon payment in fuB of aG sums secured by mis Security InstmmenG Lender shall promptly refund m Bortower any Funds held by Lettder. If, under paragraph 21, Lender shall acquire m sag me Property, Lender, prior m me acquisition ar sate of the Property, 5ha11 apply any Funds held by Lender at me time of acquisition ur sale as x credit against me sums seemed by mis Security Instrument 3. Application of Payments. Unless applicable law provides oherwise, all payments received by Lender under paragraphs 1 and 2 shall be applied: fast, m any prepayment charges due under me Nom; second, m amounts payable under paragraph 2; m'vd, m interest due; fourth, m principal due; and last, to any late charges due under me Nom. 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines and imposifions attributable m me Property which may attain priority over this Security Instmmen4 and leasehold payments or ground tots, if any. Borrower shall pay mesa obligations in me manner provided in paragraph 2, or if no[ paid in mat manner, Borrower shall pay mein on time directly m me person owed payment. Bortower shall promptly famish m Lender all notices of amounts m be paid under mis paragraph. If Bortower makes mere payments directly, Bortower shall promptly famish m Lender receipts evidencing me payments. Boaower shall promptly dischazge any lien which has priority over mis Security Instrument unless Hortowee: (a) agrees in writng m me payment of me obligation secured by me lien in a manner acceptable m Lender, (b) contests in good faim me Tien by, m defends aga¢tst enorcement of the lien in, legal pcacezrGngs which in the Lender's opinion operate m prevent the enforcement of me Gen; or (c) secures from me holder of me Tien an agreement satisfacmry m Lender subordinating the Tien to mis Security Instrument If Lender determines that any part of me Property is subject m a Lien which may attain peiority over mis Security Instrument, Lender may give Borrower a notice identifying me lien. Borrower shall satisfy me Gen or take one or more of me actions set form above wimin 10 days of me giving of notice. , rI)Ra Foam 9099 9/ n ~'~+-6H(PA)leatal Paa•z oie 1q ~p t~,~ CCS Inine~c~,~i ~'rJ soaK J VVJJ HIILL SM073787 ~' " Yz~ryFY3w.. '.^i'tr i:r'...~.. 3 :. a:=.~r`i .-..:.:. .. ~rmN~- ......-_.~.~..-,-.e..+.+~..._ Vie'.-.W ~.s~iSY'?'NKV.~w.~.r.~.rt 5. Hpzard or Property Insurance. ~~ Borrowersdell keep the impravemeuts now vx!iutine u~r hereafter erected on [he Property Insured against loss by foe, hazards included within the term "extended soveragr." :au:~ :aie7other hazazds, including floods or flooding, for which lender requires insurance. This insurance shag be maiNaioed a tikre:armrunts and for the periods that Lender requres. The insurance carrier providing the insurance shall be chosev fiy'Btasxwm ubq.~a as: Lender's approval which shall nor be unreasonably withheld. If Borrower fails m maintaiir.wverage descn'eed ;etraec. lratfler may, at Lender's option, obtain coverage m protect Lender's rights in the Property in accordance with paragraph 9.. All insumtrce policies and renewals shalt be acceptable m Lender and sbald ircJfude a•smadard mortgage clause. Lender shag have the,righ[ m hold the policies and renewals. IF Lender requires, Bormwer shah pnrmN~'Y give m Lender all receipts of paid premiums and renewal notices. in the event of loss, Borrower shall give prompt notice m'the insurance tarsier and Lender. Lender _ may melee proof of loss if not made prompfly by Borrower. Unless Lender and Boaower otherwise agree in writing, insurance proceeds sda0 be applied m resmration a repair of the ~~ ~ Property damaged, ff dre resmration or repair is economically feasible and Lender's security is not lesswed. If the msmration or repair is mteconomiratly feasible or Leader's security would be lessened, the insurance proceeds shall be apphed m the sums secured by dris Security Instrument. whether or not then due, with any excess paid m Borrower. if Borrower abandons the Property, or does not answer within 30 days-a notice from Lender that Ida insurance carrier has offered m settle a claim, then Lender may collect the insurance proceeds. Lender rosy use the proceeds m repair or msmre the Property or m pay sums secured by this Security Instrument. whether or not then due. The 30-day period wID begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds m principal shall not extend or postpone the due date of the monthly payments refeved m in paragraphs 1 acid 2 or change the amount of the payments. IF under paragraph 21 the Property is acquired by Lender, Borrower's right m any insurance policies and proceeds resulting from damage m the Prop¢ty prior m the acquis¢oon shag pass m Lender m the extent of the'sums secured by U»s Security Instrroment immediately prior m the acquisidon. 6.Ottvpmey, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, esmblish, and use the Property as Borrower's principal residence within sixty days after the execution of [his Security Instrurrrent and shall continue m occupy the Property as Borrower's principal residence for az least one year after the dare of occupancy, uNess Lender otherwise agrees in writing, which consent shall not 6e unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impav the Property, allow the Property m dereriomte, or commit warm on the Property. Borrower shall be in default if any forfeuum action or proceeding, whether civil or criminal, is begun that in Lender's goad faith judgment could result in forfeiture of the Property or otherwise materially impair the lien meated 6y this Security Instrument or Leader'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 yr the Property or othu material impairment of the lien created 6y this Security Inswment or Lender's security interest Borrower shall also be in default if Borrower, during the town application process, gave materially false or inaccurate information m statements m Lender (or failed m provide Lender with any material information) in connection with the loan evidenced by the Nom, including, but not limited m, representations wnceming Borrower's occupancy of the Properly as a principal residence. IF this Security Instrument is on a leasehold, Borrower sha0 comply with all the provisions of the lease. If Borrower acqu"vas fee doe m the Property, the leasehold and the fee title shall no[ merge unless Lender agrees m the merger in writing. 7. Protection oP Leader's Righfs in the Property. If Borrower fails m perform the covenants and agreements contained in this Security Instrumen4 or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in baNaupmy, probam, for condemnafion or forfeiture or m enforce laws or regulafions), then Lender may do and pay For whamver is necessary m protect the value of the Properly and Lender's rights in the Property. Lender's actions may include paying any sums secured by a lien which has priority over dris Secudty Instrument, appearing in wort, paying reasonable attorneys' fees and entering on the Property m make repays. Although Lender may take action under this paragraph 7, Lender_ does rat have m do so. Any amounts disbursed by Lender under dtis paragraph 7 shag become addidonal debt of Borzower swured by this Security Insmrment Unless Borrower and Lender agree m oNer terms of payment, these amounts shag bear interest From the date of disbursement at dte Nom rate and shall be payable, with interest, upon notice from Lender m Borrower requesting payment 8. Mortgage Insurance. If Lender requited amrtgage insuraztce az a wndition of making the loan secured 6y Ihis Security Instmment, Borrower shall pay the premiums requ'ved m maintain the mortgage insurance in effect If, for any reason. the mortgage insurance coverage required by Lender lapses or ceases m be in effect, Borrower shall pay the premiums requted m obtain coverage substantially equivalent m the mortgage insurance previously in effect, at a wst substantially equiva]ent to the wst m Borrower of the mortgage insurance previously in effcet, from an alternate mortgage insurer approved by Lender. lF subarantially equivalent mortgage insurance coverage is no[ available, Borrower shall pay m Lender each month a sum equal m one-twe]fth of the yearly mortgage insurance premium being paid by Borrower when the insurance wverage lapsed or ceased m be in effect Lender will accept, use and retain these payments as a lass reserve m lieu of mortgage insurance. Loss reserve C Farm 3099 ®-BH(PA)ieaioi Pege3 alb BOON~349 PAGE 6J2 '"""''~ BULL 17/0737137 -, . r-- payments may no longer be required, at the option of [,ender, If mortgage instvazae covsage (in the amount and for the period Otat Lender requires) provided by an insurer approved by Lender again becomes available err[! is obtained. Borrower shag pay the premiums required m maintain mortgage insurattcein effect, a m provide a floss reserve, until the requirement for mortgage insurance ends in accordance with any written agreement between Borrows and`Lender,orrap,,n!icable law. 9.I¢spection. Lends or its agent may make reasdgabie entries upon and inspexti[sas of the Property. Lends shall give Bortows notice at the time of or prior m an inspection specifying reasonable cause;for theiuspstion. 10. Condemnation. The proceeds of any award or claim for damages, dittrs sc ~^smsequenial, in connection with any condemnation or oths taking of any part of the Property, or for ronveyance in lien ~of ~condemnadon, are hereby assigned and shall be paid m Lends. In the event of a mist taking of the PcopeRy, the proceeds shatl be applied m die sums secured by this Security Instrument, wheths or not then due, wim any excess paid m Borrows. In the event of a pamal taking of the Property in which the fair market value of the Property immediaely before the taking is equal m or greater than the amount of the scone secured by this Security Instrument immediately before the taking, unless Borsows and Lends othewise agree in writing, the sums secured by this Security Instnunent shall be reduced by the amount of the proceeds multiplied by the following fmcion: (a) the coral amount of the sums secured immediatety before the taking, divided by (b) the fav market value of the Property immediately before the taking. Any balance shall be paid m Borrows. In the event of a partial faking of the Property in which the fair market value of the Pmperty immediately before the taking is less than Ote ameum of the sums secured immediately before the taking, unless Borrows and Lends oherwise agree in writing or unless applicable law otlrerwise provides, the proceeds shall be applied m me sums secured by this Security Instmment wheths or not the stuns are then due. If me Property is abandoned by Borrows, s if, after notice by Lends m Borrows that the condemnor offs m make an award or settle a claim for damages, Bortows Fads m respond m Lends within 30 days efts the date the notice is given, Lends is authorized m wllst and apply the proceeds, at its option, either m resmmtion or repay of the Property or m the sums secsed by this Security Instrument, whems s not men due. Unless Lends and Borrows otherwise agree in writing, any application of proceeds m principal shall no[ extend or postpone the dm date of the monthly payments refersed m in paragraphs 1 and 2 s change the amount of such payments. 11. Borrower Not Released; Forbearance Hy Lends Not a Waiver. 13xtension of the thne for payment or modification of amortization of the sums secured by this Security Instrument granted by Lends m any successor in interest of Borrows shat] not opsam m release the liabWty of the ocigittat Borrows s Borrows's successors in inrerest Lender shall not be required m wmmence proceedings against any successor in interest or refuse m extend time for payment oc otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by me original Borrows or Borsows's successors in interest Any forbearance by Lends in exscising any right or remedy shall not be a waive of or preclude tite exercise of any right or remedy. 12, Susessors and Assigns Bound; Joint and Sevval Liability; Co•sigoers. The covenants and agreements of this Security Inshwnent sha0 bind and benefit the successors and assigns of Lends and Borrower, subject m the provisions of paragraph 17. Borsows's Covenants and agreements shall be joint and several. Any Barrows who co-signs this Security Instrument but does not execute the Nom: (a) is co-signing this Security Instrument only m mortgage, grant and convey that Borsows's interest in the Property under me terms of this Security Instmmen[; (b) is not personally obligated m pay the Sums seared by this Security Inswmen[; and (c) agrees that Lender and any other Borrower may agree m extend, modify, Forbear or make any accommodations with regard m the terms of this Security Instrument or the Note without that Borsower's consent 13. Loan.Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan chazges, and tba[ law ks fmally interpreted so that the interns[ or oths loan charges collected or m be colleted m connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary m reduce the charge m the permitted limit; and (b) any sums already colleted from Borrows which exceeded permitted limits will be refunded m Borrows. Lends may choose m make this refwd by reducing the principal owed under the Note or by making a d'trect payment m Bonows. If a refund reduces principal the reduction wiB be treated a9 a partial prepayment without any prepayment charge ands me Nom. 14. Notices, Any notice m Borrows provided for in this Security Instrument shall be given by dehvering it or by mailing it by Fvst class mail unless applicable law requires use of another method. The notice shall be dusted m the Property Address or any odts address Borrows designates by notice m Lends. Any notice m Lender shall be given by First class mail m Lender's address stated hsein or any omu address Lender designates by notice m Borrower. Any notice provided for in this Security Instrument shalt be deemed m have been given m Borrows or Lends when given as provided in this paragraph. I5. Governing Law; Severability. This Security Instrument sha0 be governed by fedsal 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 oths 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 m he severable. ®®•6H(PA)leaial BALL OOOKZ3~9PAGE 6.Ja) Formsas~e Sao„ Page aot6 , InNlal ~l~ 1RE0737a7 ' 16. Borrower's Copy. Borower shall be given one conformed copy nY•dse'Nnrs and cyf ~ktis Security Instnrmeel. - 17. Transfer of the property or a Benetidal Interest in Borrower. If all m any p"arttif the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or ransfeaed and Bortolaer is no[ a natural person) without Lender's prior written consent, Lender may, at its option, require immediaze payment ~ fuRrof all sums secured by this Security Insmument However, this option shall not be axemised by Lender If exercise is prefdtatod -•by federal law as of the date of this Security 1rl8hmneRC If Lander exercises this option, Lender shall give Borrower nodce of accelera'don. The noflce shall provide a period of not less than 30 days from the date the nodce is dehvered m mailed within which Boaower must pay aU sums secured by this Security Instrument II Borrower fails m pay these sums prior m the expiration of ttds period, I.enderrnay invoke any mmedres permitted by this Security %nstmment wthout further tmdce or demand on Borrower. 18. Borrower's Right to Re®sfate. If Bursower meets cCrfain conditions, Borower shall have rice right m have enforcement of title Sectmty Insrument distwndrrued az any time prior m the earlier of: (a) 5 days (or such other period as applicable law may specify for reinstatement) before sale of the Properly pursuant m any power of sale wnmined in this Security InsrumenC or (b) en off ajudgment enfoming this Security Insrument Those condifmns aze tlrat Botmwer. (a) pays Lender all sums which then world 6e dm under this Security Ins[nunent and the Note as if no acceleration had oceursed; (b) cures any defaoh of any other covenants or agreements; (c) pays a6 expenses incurred in enForc'urg this Security Instnunen4 including, but not limited m,-reasonable atmmeys' fees; end (d) takes such action as Lender maY reasonably require m assure that the lien of this Security Instrrment, Lender's rights in the Property and Borrower's obggatlon m pay tite sums secured by thisSecurity Instrumeat shag continue nnchanged. Upon reinstatement by Bormwer, this Security Insumnent and the obligations secwed hereby shall remain fogy effective as if no acceleration had accursed. However, this right m reinstate shah no[ apply in the case of accelemtion under pazagmph 17. 19. Sale of Note; Change of Loan Servicer. The Note or a partial Itrterea[ h1 the Nom (mgerher with this Security Instmmenl) may be sold one or more times without prior notice m Borsower. A sale may result in a change in the entity (known u dte'T:ofler Seavica") that wllects monthly payments due urrdea tire Note and this Security Instruunwt There also may be om or moro changes of tire Loan Servirxx unreiaaxl m a sale of the Note. If there is a change of the Loan Servrcer, Borrower will be given written nodce of the change in accordance with paragraph 14 above and applicable law. The notice will stem the name and address of the new Loan Servicer and the address m which payments should be made. The nodce will also contain any other :hate¢cea. Borrower shah ant cause a ggumtt the gresence, use, disposal, smmge, m release of any on or in the Pmpeny. Borrower shag not do, nor allow anyone else m do, anything affecting the Property ny Environmental Law. The preceding two senterrces shall not apply m the presence, use, of smmge on the tildes of Ilarsrdous Substances tlrat are generally recognized m be appropriate m normal residential uses Borower shall promptly give Lender written nodce of any investigation, claim, demand, lawsuit m other action by any governmental m regulamry agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borsower has actual knowledge. If Borrower teams, or is notified by any govemmenml or regulamry authority, maz any removal m other remediadon of any Hazazdous Substame affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in tins paragraph 20, "Hazardous Substances" are those substances defined as mxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or mzic petroleum products, mxic pesticides and herbicides, volatile solvents, materials containing as6esms or formaldehyde, and radioactive materials. As used in tlris paragraph 20, "Envhnmental Law" means federal laws and laws of the jurisdiction where the Property is located Nat relate m health, safety or envhonmental protection. NON-UNIFORM COVENANTS. Borower and Lender furher 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 mw provides otherwise). Lender shah notify Borrower of, among other things: (a) the defauk; (b) the action regnired to cure the defanh; (c) when the defantt must be cured; and (d) that failure to cure the default as bpedfied may result in acceleraKo¢ oP the sums secured 6y this Sernrity Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the rigfit to reincmte after acceleration and the right to assert in the Poredos¢re proceeding the uomexistence of a default or any other defense oP Borrower to acceleration and Poredosure. IF the defauR a ant cured as specified, Lender, at ifs option, may require immediate payment in EuB of al! sums secured by this Security InsWment without further demand and may foreclose this Security Instrument 6y Judicial proceeding. Lender shah be entitled to rnBect a6 expenses incurred in pursuing the remedies provided i¢ this paragraph 21, including, but not limited m, attorneys' fees and costs of title evidence to the extent permitted by applicable law. 22. Release. Upon payment of a6 sums secured 6y this Security Instmmen[, this Security Inshwrtent and [he estate conveyed shall terminate and became void. After such occurrence, Lender shag dischazge and satisfy this Security Insrument m Borrower. Borsower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instlumen4 but only if the fee is paid to a third party for services rendered and the chazging of the fee is permitted under applicable law. 23. Waivers. Borrower, m the ez[ant permitted by applicable law, waives and releases any error or defects in proceedings m enforce this Security Instmment, 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 ezempdon. aonKi349rar,~ 654 Form 30//3~9~g/~gaL~, (~•BH(PA)fab101 Pere 5018 , Inumle: y;Gp~,P1.J eavc 1R56737a7 ~-- -, ' 24. Reivstatemeut Period. Borrower's time to reinstate provided in pazagraph 18 shah extend m one how prior to the Bommeatcement of bidding et a sheriff s sale or other sale pmsuan[ m this Security Instrument. 25. Purchase Money Mortgage. ff any of the debt secured by this Security Instrument is tent m Borrower m acquire dde to the Property, Ws Security Instmment shall be a purchase money mortgage. . 26.Intereat Rate Atkr Judgment. Bortower agrees thaz the interest mte payable after a judgment is entered on the Note or in an acdon of mortgage foreciosttre shall be the rate payable from time m time ands the Note. 27. Riders to this Security Instrument. If one oc more riders ace executed by Borrower and recorded together with this - ..Security Instrument, the covenants and agreements of each such rider shall be inwrpomted inm and shall amend and supplement 'the boyenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument _ ~Clieck ae~ ]icable box(es)] LJ'Adjdstable Rate Rider ~ Condominium Rider [] I.4 Family Rider ~] Gradrieted Payment Rider ~ Planned Unit rtevelopmen[ Rider ~ Biweekly Payment Rider ~~BaBoonRider ~ ORate Improvement Rider []Sewnd Home Rider ,;~~ ~,[~ VARider~ ~ Other(s) [speciFY7 BY SIGNING BBLOW, Borrower accepts and agrees to the terms and cove ~ ntained iry this Security Instrment and in ' ~ any rider(s) executed by Borrower and recorded with it ///~J///J Witnesses: i BALL .Hortower D&eORAR K BALL -Borrower •Bartower -Borrower Certititate of Residence I. , do hereby certify that the correct address of the wiliiln-named Mortgagee is , Witness my hand this day of ^ ~I~1 Agent of YioM1gagee COMMONWEALTH OF PENNSYLVAMA, ~c1u.rYt...,, County u: On this, the ^ VV~ ,~ S day of t7GF ~ q 9 6 ,before me, the undersigned officer, personatly appeared n ~ n . r .D. ~)~j f !~~ t ~..3. „/' lt~a~ of I-~ ren a.,b, t lYk/ known m me (or satisfacmrily proven) m be [he person 5 whose name~T 0.1ti subscribed to the wiNin instrument and acknowledged [hat executed the same for the purposes herein contained. IN WITNESS WI~REOF, I hereunto set my hand and official seal. My Commission Expires: eFy~,~t ra5.('rdl~cm ~i Ja~~ 1~ c~t ~R y '. i-~° ~'~ NOTAflIAL SERI -_'®° a"o :~,~ Tide ofOfftcer f;ardsUurg 0suphlnCounty `t`-- ~ ' ''' °~" R1y CBmmissldn Eirplraa Ntlv, 7,1087 -6H(PA)(anel ~,~~ "y.~; •,~G,` PaBeeore , arm 6 ~~~'~c[ °""""BOdH13QyPAGE 655 27d0737H7 ;~, ~-_„v ILLEGIBLE L1AIGlNAL _ . -;.. ..: ;;.:, + _ ~- _- 'J81,- i'S.. rCp 2:ir .. n ';`. n..L.~. ° .. ..._.a s ...... .. ... .Y. ~t^ ..Sx.wv r'^N.4. ~'j.+j-1r. _ ':9;] n A 4t-T'~N'1.,: e ,. , s. !i2:.. 3v '(iliiii•i:.n a'i SPfr .^.7I3>•C.''?::~ SE•-?t~; t;' ._...._. - ,..:.a r~>-' ^_•' q.3~r.-,3 z.q.- ;n ~r+`' ;.G. raCa',(:r•?,'. c V:r.J''i'~:'CAd:gCi :ry: ,•~~s^•a"d:7E ~'!~.-^, ii:i ^:(:?;f:sr9~~d£.Y3:=t.•' . -:•t?:=a::;8.`.=~~:~:sc;:<~~;_'•3.A's, .sst 2.a -SsC^x:a:s.era'issiyar:csr Gr°sr:^arix c?;:^~u,+s: £1?e ::~sr„t;o. q•~r~^.. - ~. !q ..a n:r:'^.'v:'+':~~''^ d~5:'~. ?.'~,+;'.'+3c'. r..C:'acv.~'.''~.°.5":Yu~f6.^,i.:e:a.^,"a'2:e"v 2w3:E"S::'.,fa'.:?_~t i'It/`'~r r?i: i:'a~:caL.: - °a-t'?4':": '3:l:ZG%ia:F::7~~33'i::\: '._C,~=~ ~;YvM -'mss+r~:_y.3,_•, :~~ li::. _•`E''ieq f.~4'~.:i~? :~C:: Y.i £ ~'- 2: °.^. i _ : i °_?:n ^.Gvi ,ria~n•E3:r i^"..S 'i F ~ c .~ w 2ry:"i3FV7?;n5~.q a +„~~+BC• O', j ~'±r __^i, ~^::~:?•'.$Li 3L'~~:."£.. _ _x`~c,.~.r.._"a"~~>~u;~e^'.8^:'s^^.ilv:0i=~:>v~:~°.y+953r :.:'4"::Y=°~': a'5:fpr. ~. ~`JSEn a C"w cd_ °3: ~i^k". c~. ...y. ; _ . ^si i x:. w 'a ^." .':'c .'. s-,a fiC:f°--':3^ :.'~:~F il`t,•.rcV 'F?a :r~3£ : :.j -''. 3:ii.Sr c~:£'..ru.i':~.u'''sea'--.`iw:L', UrN;7 'r~°: }: pe ;} '. uwSuC?f5,'"'?ij'K~sC.iir:_i:2fi :.uJo SII3 us~"9[3S$•. _... ~£.'"': P.S"9r v_3'.s' 2i, u'S:i?~5 v' _~': i:'3 ~ T^s: ..6!`t:';:52u"33 ;'S'.tss'6i F53?"t?:: at '<^::~: ' Z:'~:0 'iv`.-'£f:"e;6%G':', D`1~A~6i~'} .i.2 r,~'."i£r`°:1x~-k.:Ye ?: a :~.,_ ii1 L:=+?~=?~:i'S."s.-'v'; :~~i£~ i:E'd ~Y_ i.::2-•i .. '.•~a.] 3C'~t•Gf,v, ~?'^`i: :;.i^t~e21i ~•=, ^-3:': ~3e. 7,•E ~SJ`s£z`%:'}'"aG^.':'n:' "4'vx _::.4'i'~:li:. i?'-'~ -_5 ^i tY:a ~:;v'F4C ~?Sj 43Yi .K 3: •'. i?:';yi.:.' i::::'c?j;: n. c,.. cr9'i0Z Y5 (."-",:::6 ~~~.". i ;~n`2a'. SJ ` R •;~?•~: 6i' 3'cii :c $>~w:L .2§3 .._.:^z::. - `: P:~.c9 ^iS~if;'L: $nYS 909, '^'~; :.':£3i' .5 E:. -:.. "C.BaC:GFS wGnaJ .3:9r_ jf.'ny, : ;x~ -: ~i+~ _av4..n. ~:`£::^3 AU^_,: ~e.3~'a^- i. _ `'?'.'... 2's7i:?(?: ,.?_~~.. _.. ...., .....`i'~... y's :c ,?.. e:C..u .:;i. +=7i: ~C:'wr~'.'.'3:. °!i<£!: v._Ga<; ,. ...'if. 'G'~ ILLEGIBLE ORIGINAL ~`~p~ - to ~f Pennsylvania ~ "~4rty of Cumberland 7 ded i the oHrce for the rewrd+ng of Desds sand berlandCoen , ao VoT_Pegs ~~rm my hand eal of oiFl ~ `~;rtisle, PA thia day Of 1~_. A B~OKZ3~uPA6f SS6 Advanta ~Q~O//~n/T/~® Mortgage P.O. 2nx if:JJ] I San Ciaao. CA P97F0~80 tr t0~JD Fancha 6emamu Ae xl San Diaoo. CA J?r^' DEBORAH K BULL 2 WHEATFIELD DRIVE CARLISLE PA 17013 DATE: November 2, 2000 RE: Loan number 2180719 NOTICE OF INTENT TO FORECLOSE ON MORTGAGE YOU ARE IN DEFAULT OF YOUR OBLIGATION TO YOUR LENDER, the present holder of the Loan and Mortgage referenced by the above identified loan number. ADVANTA Mortgage Corp. USA is the servicing agent for the holder authorized to act on its behalf. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO PAY installments of $1,456.78 each, commencing September O1, 2000 and subsequent installments thereafter. Late charges have also accrued to this date. Late charges are assessed if the monthly payment is not received within the grace period set forth in your Loan. Your monthly late charge is $77.49. Other charges may have also accrued which are due in order to cure your loan. AS-OF THE DATE OF THIS LETTER, THE TOTAL AMOUNT NECESSARY TO CURE THE DEFAULT IS AS FOLLOWS: Payments of $1,456.78 each commencing September O1, 2000 through November O1, 2000: (Corporate Advances included) $ 4,378 .09 Current Late Charges $ 154 .98 Deferred Late Charges $ 7 .20 Current Return Check Fees $ .00 Deferred Return Check Fees $ ,00 Advances by Servicer $ .00 Advances by Investor $ ,p LESS: Partial Payments/Forbearance $ .00 Misc. Unapplied Funds ~ $ .00 TOTAL AMOUNT TO CURE DEFAULT: $ 4,540 .27 YOU MAY CURE THIS DEFAULT within 30 days of the date of this letter by paying to us the amount of $4,540.27 plus additional installment payments that come due and any late charges and other charges or fees which have accrued or have been paid on your behalf during that time. Such payment must be made in the the form of cash, certified or bank check, or money order, payable to ADVANTA Mortgage Corp. USA and delivered to the following address: ADVANTA Mortgage Corp. USA Collection Dept. #350 10790 Rancho Bernardo. Rd. San Diego CA 92127 If you do not cure the default within 30 days, we intend to exercise our right to accelerate the mortgage. This means that whatever is owing on the original amount borrowed will be considered due immediately and you will lose the chance to pay the original mortgage in monthly installments. If ,y u the default within 30 days, we intend to instsgEt u' a start a lawsuit to foreclose on the mortgaged. e e mortgage is foreclosed upon, your mortgaged pr~p$ i sold by the County Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up ii ~' LLLiPYiA'os Advanta iQ~~//~n/j"/~° Mortgage P.O. 9m' 509011 NOTICE OF INTENT TO FORECLOSE ON MORTGAGE s,n ~lege. i.a autit~9on DEBORAH K BULL 1e,-9ogarnYroBe:nanlogco Page Two san wegu. ca 9z1z~ to $50. However, if legal proceedings are started against you, you will have to pay the actual incurred reasonable attorney's fees, even if the fees are more than $50. All attorney's fees will be added to whatever amount you owe us, which may also include our reasonable costs. IF YOU CURE THE DEFAULT WITHIN THE THIRTY-DAY PERIOD YOU WILL NOS BE REQUIRED TO PAY ATTORNEY'S FEES. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. However, if you have filed a bankruptcy and this mortgage debt was discharged, we cannot sue you personally. If you have not cured the default within the 30 day period and foreclosure proceedings have begun, you will have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid amount due plus any interest and late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff`s Sale of your Premises could be held would be approximately 90 days from the date foreclosure preceedings begin. This is just an estimated date. 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 will be by calling us at (800) 548-7916, between the hours of 5:00 a.m. and 8:00 p.m. Monday through Friday, 6:00 a.m. and 3:00 p.m: Saturday and 6:00 a.m. and 12:00 p.m. Sunday, Pacific Standard Time. You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's Sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS DEBT. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. YOU HAVE THE RIGHT TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER SHE PREMISES SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WOULD CURE THE DEFAULT AND ASSUME THE MORTGAGE DEBT PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE TIME OF SALE. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to cure a default more than three times in any calendar year. Collection Department #350 ADVANTA Mortgage Corp. USA WP12 /ACT6CPF File Copy ITlTR16A'Oi Advanta ADI//INTi4° Mortgage P.C. Box 509011 San Diego. CA 921549011 10790 Rzncho Bemamlo Roatl San Diego. CA 92127 DEBORAH K BULL 2 WHEATFIELD DR CARLISLE PA 170139004 DATE: November 2, 2000 RE: Loan number 2180719 NOTICE OF INTENT TO FORECLOSE ON MORTGAGE YOU ARE IN DEFAULT OF YOUR OBLIGATION TO YOUR LENDER, the present holder of the Loan and Mortgage referenced by the above identified loan number. ADVANTA Mortgage Corp. USA is the servicing agent for the holder authorized to act on its behalf. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO PAY installments of $1,456.78 each, commencing September O1, 2000 and subsequent installments thereafter. Late charges have also accrued to this date. Late charges are assessed if the monthly payment is not received within the grace period set forth in your Loan. Your monthly late charge is $77.49. Other charges may have also accrued which are due in order to cure your loan. AS OF THE DATE OF THIS LETTER, THE TOTAL AMOUNT NECESSARY TO CURE THE DEFAULT IS AS FOLLOWS: Payments of $1,456.78 each commencing September O1, 2000 through November O1, 2000: (Corporate Advances included) $ 4,378.09 Current Late Charges $ 154,98 Deferred Late Charges $ 7.20 Current Return Check Fees $ ,00 Deferred Return Check Fees $ ,00 Advances by Servicer $ .00 Advances by Investor $ .0 LESS: Partial Payments/Forbearance $ .00 Miec. Unapplied Funds $ .00 TOTAL AMOUNT TO CURE DEFAULT: $ 4,540.27 YOU MAY CURE THIS DEFAULT within 30 days of the date of this letter by paying to us the amount of $4,540.27 plus additional installment payments that come due and any late charges and other charges or fees which have accrued or have been paid on your behalf during that time. Such payment must be made in the the form of cash, certified or bank check, or money order, payable to ADVANTA Mortgage Corp. USA and delivered to the following address: ADVANTA Mortgage Corp. USA Collection Dept. #350 10790 Rancho Bernardo Rd. San Diego CA 92127 If you do not cure the default within 30 days, we intend to exercise our right to accelerate the mortgage. This means that whatever is owing on the original amount borrowed will be considered due immediately and you will lose the chance to pay off the original mortgage in monthly installments. If you do not cure the default within 30 days, we intend to instruct our attorneys to start a lawsuit to foreclose on the mortgaged premises. If the mortgage is foreclosed upon, your mortgaged property will be sold by the County Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up Advanta /~~V~{Nr140 Mortgage P.O. Box 509011 NOTICE OF INTENT TO FORECLOSE ON MORTGAGE San Diego. CA 82150-9011 DEBORAH K BULL imso Rancho eeme,do ROel Page Two san c~ego, ca sziz~ to $50. However, if legal proceedings are started against you, you will have to pay the actual incurred reasonable attorney's fees, even if the fees are more than $50. All attorney's fees will be added to whatever amount you owe us, which may also include our reasonable costs. IF YOU CURE THE DEFAULT WITHIN THE THIRTY-DAY PERIOD YOU WILL NOT BE REQUIRED TO PAY ATTORNEY'S FEES. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. However, if you have filed a bankruptcy and this, mortgage debt was discharged, we cannot sue you personally. If you have not cured the default within the 30 day period and foreclosure proceedings have begun, you will have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid amount due plus any interest and late or other charges then due, as well as the reasonable attorney's fees and coats connected with the foreclosure sale (and perform any other requirements under the mortgage). Tt is estimated that the earliest date that such a Sheriff's Sale of your Premises could be held would be approximately 90 days from the date foreclosure preceedings begin. This is just an estimated date. A notice o£ 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 will be by calling us at (800) 548-7916, between the hours of 5:00 a.m. and 8:00 p.m. Monday through Friday, 6:00 a.m. and 3:00 p.m. Saturday and 6:00 a.m. and 12:00 p.m. Sunday, Pacific Standard Time. You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's Sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS DEBT. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. YOU HAVE THE RIGHT TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PREMISES SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WOULD CURE THE DEFAULT AND ASSUME THE MORTGAGE DEBT PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE TIME OF SALE. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EBIST. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to cure a default more than three times in any calendar year. Collection Department #350 ADVANTA Mortgage Corp. USA WP12 /ACT6CMF File Copy ADV/1 NTAP DEBORAH K BULL 2 WHEATFIELD DRIVE CARLISLE PA 17013 AdvaMa Mortgage 20. Sex E080i1 Se.n Uisgo. CA 93750-8011 '107.°0 Rencno eema~no Roatd Sa~i UieAC. CA 8278; DATE: November 2, 2000 RE: Loan number 2180719 IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS. Your mortgage is in default because you have failed to pay promptly installments due for a period of at least 60 days. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO PAY installments of $1,456.78 each due 9/O1/00 and monthly thereafter as well as other charges. AS OF THE DATE OF THIS LETTER YOU ARE IN DEFAULT AS FOLLOWS: Payments of $1,456.78 each for September O1, 2000 through November O1, 2000: (Corporate Advances included) $ 4,378.09 Current Late Charges $ 154.98 Deferred Late Charges $ 7.20 Current Return Check Fees $ .00 Deferred Return Check Fees $ .00 Advances by Servicer $ .00 Advances by Investor $ .0 LESS: Partial Payments/Forbearance $ .00 Misc. Unapplied Funds $ .00 TOTAL DEFAULT: $ 4,540.27 You may be eligible fox financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this Notice, it contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for 30 days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of ADVANTA Mortgage Corp. USA, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. That meeting must occur in the next 30 days. If you attend a face-to-face meeting with ADVANTA Mortgage Corp. USA, or with a consumer credit counseling agency identified in this Notice, no further proceeding in mortgage foreclosure may take place for 30 days after the date of that meeting. You can contact a representative of ADVANTA Mortgage Corp. USA by telephoning our toll free number (800) 548-7916 between the hours of 5:00 a.m. and 8:00 p.m. Monday, 6:00 a.m. and 3:00 p.m. Saturday and 6:00 a.m. and 12:00 p.m. Sunday, Pacific Standard Time. The name(s), address(es) and telephone number(s) of (a} designated consumer credit counseling agency(ies) is (are) attached. 4T'LTPoJA~OS Advanta ADV~NTA® Mortgage P.O. Box 5no01f Saa C11BIS0, C '1 92 150 8 0 11 10'90 Rdncl;c 6_mRrio Roan Saa Oi>ga CA 9212T NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT DEBORAH K FULL PAGE TWO It is only necessary to schedule one face-to-face meeting. You should advise ADVANTA Mortgage Corp. USA immediately of your intentions. If you have tried and are unable to resolve this problem at/or after your face-to-face meeting, you have the right to apply for financial assistance from Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or postmarked within 30 days of your face-to-face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency or you must file it at the office of one of the attached designated consumer credit counseling agencies listed on the attachment to this Notice. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P.O. Box 8029, Harrisburg, Pennsylvania 17105. Telephone Number (717) 780-3800 or 1-800-342-2397 (toll free number). An application for assistance may be obtained from a consumer credit counseling agency or directly from the Pennsylvania Housing Finance Agency., It is extremely important that you file your application promptly. if you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance. Agency has 60 days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. La notification en adjunto ea de sums importancia, puss affects su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtanga una traducion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numeeo mencionado arriba. Puedes ser eligible pars un prestamo por el programs 1lamando "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ALL INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Collection Department #350 ADVANTA Mortgage Corp. USA Attachment: Consumer Credit Counseling Agencies WP12/ACT9ICP File Copy LtLTR 1JA~Oi ,auVnnrra9 CONSUMER CREDIT COUNSELING AGENCIES Cumberland County Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, PA 17101 (717) 234-5925 FAX )t (717) 232-4985 YMCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX # (717) 243-3948 0 0 N m M1 .-l M1 0' a Advanta Mortgage F.J. Gux 599911 San Oieoo, CA °?t5U-9Uti l9]A9 Ranohc Garnartlo Roatl San Diego. D.4 9312] ~ PosiwE T _ _ - -. PASTIAAAN DA RATE "_ o _ Feiuanl £ ELCIPT FE6iFICiE~CELIVEhY l \ ~ 6 f W . E F + CEWIFl ~ L P~ '~ ~ ! 0 SEPVIGE ENPX PELEU EC CEt T . ~ -~ 1Vid POSigpE >M1C EEEE ~ /7 J1~ 2 W SENT TO: IN E4 CE EPE EIS ~ umronwiiriwmorvaL Er°L ~ ~~ ~ "- WC ° o o `- , Y F a c o~ .. ~ y ~~': iii ~~ w u V~ ' .. .. .. _ ... ~ Gz N~ UQ 4W ~~ FS FDRM Aft~fl US Postal Service ~_ _ _ E We~wdo~sa avu ~ ~~~~1~~ ~B~ o s LT~LTFWA~o=_ ~. ADV/INTA° DEBORAH K BULL 2 WHEATFIELD DR CARLISLE PA 170139004 Advanta Mbitgags P.O. box 503011 San Diego. CA 92150-3411 10]90 Rancho aemaNo Road San Diego, CA 9212] DATE: November 2, 2000 RE: Loan number 2180719 IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS. Your mortgage is in default because you have failed to pay promptly installments due for a period of at least 60 days. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO PAY installments of $1,456.78 each due 9/01/00 and monthly thereafter as well as other charges. AS OF THE DATE OF THIS LETTER YOU ARE IN DEFAULT AS FOLLOWS: Payments of $1,456.78 each for September O1, 2000 through November O1, 2000: (Corporate Advances included) $ 4,378.09 Current Late Charges $ 154.98 Deferred Late Charges $ 7.20 Current Return Check Fees $ .00 Deferred Return Check Fees $ .00 Advances by Services $ .00 Advances by Investor $ ,p LESS: Partial Payments/Forbearance $ .00 Misc. Unapplied Funds $ .00 TOTAL DEFAULT: $ 4,540.27 You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1483 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this Notice, it contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for 30 days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of ADVANTA Mortgage Corp. USA, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. That meeting must occur in the next 30 days. If you attend a face-to-face meeting with ADVANTA Mortgage Corp. USA, or with a consumer credit counseling agency identified in this Notice, no further proceeding in mortgage foreclosure may take place for 30 days after the date of that meeting. You can contact a representative of ADVANTA Mortgage Corp. USA by telephoning our toll free number (800) 548-7916 between the hours of 5:00 a.m. and 8:00 p,m. Monday, 6;00 a.m. and 3:00 p.m. Saturday and 6:00 a.m. and 12:00 p.m. Sunday, Pacific Standard Time. The name(s), address(es) and telephone number(s) of (a) designated consumer credit counseling agency(ies) is (are) attached. LT{iP1 JA-05 ADV/1 NT.4~ Advanta Mortgage eo eox 5o9orr San Oiego. CA 92150-9011 f019o Rancho BemaMO Road San Oiego, CA 92x21 NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT DEBORAH K BULL PAGE TWO it is only necessary to schedule one face-to-face meeting. You should advise ADVANTA Mortgage Corp. USA immediately of your intentions. If you have tried and are unable to resolve this problem atjor after your face-to-face meeting, you have the right to apply for financial assistance from Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or postmarked within 30 days of your face-to-face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency or you must file it at the office of one of the attached designated consumer credit counseling agencies listed on the attachment to this Notice. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P.0. Box 8029, Harrisburg, Pennsylvania 17105. Telephone Number (717) 780-3800 or 1-600-342-2397 (toll free number). An application for assistance may be obtained from a consumer credit counseling agency or directly from the Pennsylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The counseling agency will help you to fill out the application, The Pennsylvania Housing Finance Agency has 60 days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. La notification en adjunto ea de soma importancia, puss affects su derecho a continuar viviendo en su casa. 5i no comprende el contenido de seta notification obtanga una traducion immediatamente llamando seta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes sex eligible Para un prestamo pox e1 programs llamando "Homeowner's Emergency Mortgage Assistance Program" el coal puede salvar su casa de la perdida del derecho a redimir su hipoteca. THIS SS AN ATTEMPT TO COLLECT A DEBT AND ALL INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Collection Department #350 ADVANTA Mortgage Corp. USA Attachment: Consumer Credit Counseling Agencies WP12/ACT9ICM File Copy LT LTPV.MpS ADV/1 NTA° CONSUMER CREDIT COUNSELING AGENCIES Cumberland County Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2D00 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, PA 17101 (717) 234-5925 FAX # (717) 232-4985 YMCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX # (717) 243-3948 apsceGE PETUPN xESiPILTED pELIVERY ~ _ nENTFIep PEC+PENPN P[CEIFi SERVICE ' M1 iOTN. P05@GE MID FEE9 .~ xp xs xc cov'x navlD D- .a SENT TO: Di FDn wrexxnnpxnL rtuL ~ .a ~ ,... _:r 1,. W a PS FORM 3800 VS Postal Service Advanta Mortgage P.O. Bax 509011 San DiegD. C•A 92150-9011 10190 RancF,o Bernardo Road San Diego, CA 9?12i RR RATE - ~~ °-~- A O \O jN J n wrc 0 a pQ U6 W 6F ~e~eopt f®r ~~R°~OfB~fa ~~6~ o g LTITPIAAOS .Y:~ _ Advanta ADV/1 NTA° Mortgage P.O. Boa 509017 San Oieyo. CA 92150-9011 10190 Rancho Bernardo Read San Oiego. CA 921Z] CALVIN L BULL 2 WHEATFIELD DRIVE CARLISLE PA 17013 DATE: November 2, 2000 RE: Loan number 2180719 IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS. Your mortgage is in default because you have failed to pay promptly installments due for a period of at least 60 days. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO PAY installments of $1,456.78 each due 9/01/00 and monthly thereafter as well as other charges. AS OF THE DATE OF THIS LETTER YOU ARE IN DEFAULT AS FOLLOWS: Payments of $1,456.78 each for September O1, 2000 through November O1, 2000: (Corporate Advances included) $ 4,378.09 Current Late Charges $ 154.98 Deferred Late Charges $ 7.20 Current Return Check Fees $ .00 Deferred Return Check Fees $ .00 Advances by Servicer $ .00 Advances by Investor $ .0 LESS: Partial Payments/Forbearance $ .00 Misc. Unapplied Funds $ .00 TOTAL DEFAULT: $ 4,540.27 You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this Notice, it contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for 30 days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of ADVANTA Mortgage Corp. USA, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. That meeting must occur in the next 30 days. If you attend a face-to-face meeting with ADVANTA Mortgage Corp. USA, or with a consumer credit counseling agency identified in this Notice, no further proceeding in mortgage foreclosure may take place for 30 days after the date of that meeting. You can contact a representative of ADVANTA Mortgage Corp. USA by telephoning our toll free number (800) 548-7916 between the hours of 5:00 a.m. and B:00 p.m. Monday, 6:00 a.m. and 3:00 p.m. Saturday and 6:00 a.m. and 12:00 p.m. Sunday, Pacific Standard Time. The name(s), address(es) and telephone number(s) of (a) designated consumer credit counseling agency(ies) is (are) attached. LTiTAt 4A~05 ADV/1 NTA® Advanta MiJrtgage P.O. Box 509011 San OieSO, CA 92fo0-9011 f0i~0 Rancho Balnflftl0 Road San Oie9o, CA 92127 NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT CALVIN L BULL PAGE TWO It is only necessary to schedule one face-to-face meeting. You should advise ADVANTA Mortgage Corp. USA immediately of your intentions. If you have tried and are unable to resolve this problem at/or after your face-to-face meeting, you have the right to apply for financial assistance from Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or postmarked within 30 days of your face-to-face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency or you must file it at the office of one of the attached designated consumer credit counseling agencies listed on the attachment to this Notice. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P.O. Box 8029, Harrisburg, Pennsylvania 17105. Telephone Number (717) 780-3800 or 1-800-342-2397 (toll free number). An application for assistance may be obtained from a consumer credit counseling agency or directly from the Pennsylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has 60 days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. La notification en adjunto es de sums importancia, puss affects su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta not ificacion obtanga una traducion immediatamente llamando eats agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser eligible pars un prestamo por el programs llamando "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ALL INFORMATION OBTAINED WILL BE USED FOR SHAT PURPOSE. Collection Department #350 ADVANTA Mortgage Corp. USA Attachment: Consumer Credit Counseling Agencies WP12/ACT9IBP File Copy LtLTR14§116 ~/ aoVnnrra• CONSTSMER CREDIT COUNSELING AGENCIES Cumberland County Consumer Credit Counseling Service ' of Western Pennsylvania, inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services IInlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, PA 17101 (717) 234-5925 FAX # (717) 232-4985 YMCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX # (717) 243-3948 Advanta Mortgage P.O. box SOF011 Szn Oia9o. CA 92150-8011 10]90 Rancho Bernardo Roatl San Diego. CA 92t2i aEroarv flospaE flEF1PILiE POSTMA AiE o FECEPT p pE:IYEFV ~ NOr I- ..O $ER/ICE LEPPFIEpFEE +flEFUPNSECEWT ` , op ~ 1Ja a o N NWL M\Stp4[pryp FEES l ~y SENT TO: IuviEpa liniflumoni~mnli°- ~ '~~~ i] w ~ °S v] , o LLO ~ Q M1 ¢z ~ YO n. ~ -, €jx U~ QW JS nt PS FORM 3800 US Postal Service Re~e~p4f®r Cer~°sf~ed aa! o n I.-._.....~~._.. ..~...~...e. _..,.__.~_....~__...~.... _.._..~_--- ~_....__~.y ~,. ~__ _' --._.. LFLTFlt:a aS Advanta ADI//1NTA° Mortgage au box SePnn San lJie(~o. CA 4150-SOY 10?9U Bznchu eemade Fnad an D;erc. CA 9213; CALVIN L BULL 2 WHEATFIELD DR CARLISLE PA 170139004 DATE: November 2, 2000 RE: Loan number 2180719 IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCX MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS. Your mortgage is in default because you have failed to pay promptly installments due for a period of at least 60 days. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO PAY installments of $1,456.78 each due 9/01/00 and monthly thereafter as well as other charges. AS OF THE DATE OF THIS LETTER YOU ARE IN DEFAULT AS FOLLOWS: Payments of $1,456.78 each for September O1, 2000 through November O1, 2000: (Corporate Advances included) $ 4,378.09 Current Late Charges $ 154.98 Deferred Late Charges $ 7.20 Current Return Check Fees $ .OD Deferred Return Check Fees $ ,00 Advances by Servicer $ .00 Advances by Investor $ .0 LESS: Partial Payments/Forbearance $ .00 Misc. Unapplied Funds $ ,00 TOTAL DEFAULT: $ 4,540.27 You may be eligible for financial assistance that will prevent £oreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this Notice, it contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for 30 days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative o£ ADVANTA Mortgage Corp. USA, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. That meeting must occur in the next 30 days. If you attend a face-to-face meeting with ADVANTA Mortgage Corp. USA, or with a consumer credit counseling agency identified in this Notice, no further proceeding in mortgage foreclosure may take place for 30 days after the date of that meeting. You can contact a representative of ADVANTA Mortgage Corp. USA by telephoning our toll free number (800) 548-7916 between the hours of 5:00 a.m. and 8:00 p.m. Monday, 6:00 a.m. and 3:00 p.m. Saturday and 6:00 a.m. and 12:00 p.m. Sunday, Pacific Standard Time. The name(s), addressies) and telephone number(s) of (a) designated consumer credit counseling agency(ies) is (are) attached. LT{Tqi JA~Oa ,auunNra° Advanta Mortgage >?o. eo> soserr Szn Ole9u. CA 9.'1>0-:'01l 10'JC flancb^ Bzmsrtlu Fced 52n Diz~e. CA =32 r3- NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT CALVIN L BULL PAGE TWO Tt is only necessary to schedule one face-to-face meeting. You should advise ADVANTA Mortgage Corp. USA immediately of your intentions. If you have tried and are unable to resolve this problem at/or after your face-to-face meeting, you have the right to apply for financial assistance from Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or postmarked within 30 days of your face-to-face meeting. You must either mail your application to the Pennsylvania Housing Finance Agency or you must file it at the office of one of the attached designated consumer credit counseling agencies listed on the attachment to this Notice. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P.O. Box 8029, Harrisburg, Pennsylvania 17105. Telephone Number (717) 780-3800 or 1-800-342-2397 (toll free number). An application for assistance may be obtained from a consumer credit counseling agency or directly from the Pennsylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The counseling agency will help you to fill out the application. ThePennsylvania Housing Finance Agency has 60 days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. La notification en adjunto es de sums importancia, puea affects su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtanga una traducion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numeeo mencionado arriba. Puedes ser eligible pars un prestamo por el programs llamando "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ALL INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Collection Department #350 ADVANTA Mortgage Corp. USA Attachment: Consumer Credit Counseling Agencies WP12/ACT9IBM File Copy virr+iao-os ADV/1 NTA° CONSUMER CREDIT COUNSELING AGENCIES Cumberland County Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, PA 17101 (717) 234-5925 FAX # (717) 232-4985 YMCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX # (717) 243-3948 flERIgN flEETPIEiED DELM m' RECEIPT DEFtIFIED FEE ^fiENNN PEGEIVi p SERVILE ttM.L PDSfAGF PND FEES ~~ ~ SENT TO: DIxDT F°"'n°ie"""An~°""' A m r ra M1 P' d PS FORM 3800 US _. ... , s `. .... s 11 ~. Advanta Mortgage P.V. Bos 00,40 tY San D.aaa. GA 9315PP01f YOl9(I RaicM Herr~emc Aoad o'an Dizgc. C-0 5212; ~~ ~eCei~t ~®~° Certified iii g LT~Liaran-Ds Advanta ADV/1 NTA° Mortgage ea sox Sceatt esr, Olego. CA 82156BOY 1 f0i 90 A~nclai Bernardo Aoad Sm+~fego. CA5?1P~ CALVIN L BULL 2 WHEATFIELD DR CARLISLE PA 170139004 DATE: November 2, 2000 RE: Loan number 2180719 NOTICE OF INTENT TO FORECLOSE ON MORTGAGE YOU ARE IN DEFAULT OF YOUR OBLIGATION TO YOUR LENDER, the present holder of the Loan and Mortgage referenced by the above identified loan number. ADVANTA Mortgage Corp. USA is the servicing agent for the holder authorized to act on its behalf. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO PAY installments of $1,456.78 each, commencing September 01, 2000 and subsequent installments thereafter. Late charges have also accrued to this date. Late charges are assessed if the monthly payment is not received within the grace period set forth in your Loan. Your monthly late charge is $77.49. Other charges may have also accrued which are due in order to cure your loan. AS OF THE DATE OF THIS LETTER, THE TOTAL AMOUNT NECESSARY TO CURE THE DEFAULT IS AS FOLLOWS: Payments of $1,456.78 each commencing September O1, 2000 through November O1, 2000: (Corporate Advances included) $ 4,378.09 Current Late Charges $ 154.98 Deferred Late Charges $ 7.20 Current Return Check Fees $ .00 Deferred Return Check Feea $ .00 Advances by Servicer $ ,00 Advances by Investor $ ,0 LESS: Partial Payments/Forbearance $ .00 Misc. Unapplied Funds $ .00 TOTAL AMOUNT TO CURE DEFAULT: $ 4,540.27 YOU MAY CURE THIS DEFAULT within 30 days of the date of this letter by paying to us the amount of $4,540.27 plus additional installment payments that come due and any late charges and other charges or fees which have accrued or have been paid on your behalf during that time. Such payment must be made in the the form of cash, certified or bank check, or money order, payable to ADVANTA Mortgage Corp. USA and delivered to the following address: ADVANTA Mortgage Corp. USA Collection Dept. #350 10790 Rancho Bernardo Rd. San Diego CA 92127 If you do not cure the default within 30 days, we intend to exercise our right to accelerate the mortgage. This means that whatever is owing on the original amount borrowed will be considered due immediately and you will lose the chance to pay off the original mortgage in monthly installments. If you do not cure the default within 30 days, we intend to instruct our attorneys to start a lawsuit to foreclose on the mortgaged premises. If the mortgage is foreclosed upon, your mortgaged property will be sold by the County Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they ¢-ern ~:a.os Advanta A~V/UVTi4` Mortgage PO. BQx 503011 NOTICE OF INTENT TO FORECLOSE ON MORTGAGE BanDiegu.ca3?uo~3~n CALVIN L BULL roi3o Bancho 8emanio Aeai Page Two Sen Oiaao. CA 9?ill begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50. However, if legal proceedings are started against you, you will have to pay the actual incurred reasonable attorney's fees, even if the fees are more than $50. All attorney's Eees will be added to whatever amount you owe us, which may also include our reasonable costs. IF YOU CURE THE DEFAULT WITHIN THE THIRTY-DAY PERIOD YOU WILL NOT BE REQUIRED TO PAY ATTORNEY'S FEES. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. However, if you have filed a bankruptcy and this mortgage debt was discharged, we cannot sue you personally. If you have not cured the default within the 30 day period and foreclosure proceedings have begun, you will have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid amount due plus any interest and late or other charges then due, as well as the reasonable attorney's fees and coats connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's Sale of your Premises could be held would be approximately 90 days from the date foreclosure preceedings begin. This is just an estimated date. 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 exacCly what the required payment will be by calling us at (600) 548-7916, between the hours of 5:00 a.m. and 8:00 p.m. Monday through Friday, 6:00 a.m. and 3:00 p.m. Saturday and 6:00 a.m. to 12:00 p.m. Sunday, Pacific Standard Time. You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's Sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS DEHT. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. YOU HAVE THE RIGHT TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PREMISES SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WOULD CURE THE DEFAULT AMD ASSUME THE MORTGAGE DEBT PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE TIME OF SALE. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to cure a default more than three times in any calendar year. Collection Department #350 ADVANTA Mortgage Corp. USA WP12 /ACT6BMF File Copy ~r.~s4i.a.oe !~ Advanta ADI//INTA° Mortgage eo Bo :'.anon Sai Die9n. Cd a2150-fOn f0: n0 Fencho Bamuo. Fond Seln 012b]. L4 n?1?] CALVIN L BULL 2 WHEATFIELD DRIVE CARLISLE PA 17013 DATE: November 2, 2000 RE: Loan number 2180719 NOTICE OF INTENT TO FORECLOSE ON MORTGAGE YOU ARE IN DEFAULT OF YOUR OBLIGATION TO YOUR LENDER, the present holder of the Loan and Mortgage referenced by the above identified loan number. ADVANTA Mortgage Corp. USA is the servicing agent for the holder authorized to act on its behalf. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO PAY installments of $1,456.78 each, commencing September O1, 2000 and subsequent installments thereafter. Late charges have also accrued to this date. Late charges are assessed if the monthly payment is not received within the grace period set forth in your Loan. Your monthly late charge is $77.49. Other charges may have also accrued which are due in order to cure your loan. AS-OF THE DATE OF THIS LETTER, THE TOTAL AMOUNT NECESSARY TO CURE THE DEFAULT IS AS FOLLOWS: Payments of $1,456.78 each commencing September O1, 2000 through November O1, 2000: (Corporate Advances included) $ 4,378.09 Current Late Charges - $ 154.98 Deferred Late Charges $ 7.20 Current Return Check Feea $ .00 Deferred Return Check Fees $ .00 Advances by Servicer $ .00 Advances by Investor $ .0 LESS: Partial Payments/Forbearance $ .00 Misc. Unapplied Funds $ .00 TOTAL AMOUNT TO CURE DEFAULT: $ 4,540.27 YOU MAY CURE THIS DEFAULT within 30 days of the date of this letter by paying to ua the amount of $4,540.27 plus additional installment payments that come due and any late charges and other charges or fees which have accrued or have been paid on your behalf during that time. Such payment must be made in the the form of cash, certified or bank check, or money order, payable to ADVANTA Mortgage Corp. USA and delivered to the following address: ADVANTA Mortgage Corp. USA Collection Dept. #350 10790 Rancho Bernardo Rd. San Diego CA 92127 If you do not cure the default within 30 days, we intend to exercise our right to accelerate the mortgage. This means that whatever is owing on the original amount borrowed will be considered due immediately and you will lose the chance to pay off the original mortgage in monthly installments. If you do not cure the default within 30 days, we intend to instruct our attorneys to start a lawsuit to foreclose on the mortgaged premises. If the mortgage is foreclosed upon, your mortgaged property will be sold by the County Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up LLLTRWP~OS -..v. Advanta A~V~NTi4® Mortgage ..°.O. Eu;: SO.Jit NOTICE OF INTENT TO FORECLOSE ON MORTGAGE s.,~,oieyo.c.~~z,eaGan CALVIN L BULL ;e:~n Rarrcbn 5xrareh ~.oaa San Oiaoo. CA 97u' Page Two to $50. However, if legal proceedings are started against you, you will have to pay the actual incurred reasonable attorney's fees, even if the fees are more than $50. All attorney's fees will be added to whatever amount you owe us, which may also include our reasonable costs. IF YOU CURE THE DEFAULT WITHIN THE THIRTY-DAY PERIOD YOU WILL NOT BE REQUIRED ~TO PAY ATTORNEY'S FEES. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. However, if you have filed a bankruptcy and this mortgage debt was discharged, we cannot sue you personally. If you have not cured the default within the 30 day period and foreclosure proceedings have begun, you will have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid amount due plus any interest and late or other charges then due, as well as the reasonable attorney's fees and coats connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's Sale of your Premises could be held would be approximately 90 days from the date foreclosure preceedings begin. This is just an estimated date. 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 will be by calling us at (600) 548-7916, between the hours of 5:00 a.m. and B:00 p.m. Monday through Friday, 6:00 a.m. and 3:00-p.m. Saturday and 6:00 a.m, and 12:00 p.m. Sunday, Pacific Standard Time. You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's Sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THIS DEBT. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. YOU HAVE THE RIGHT TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PREMISES SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WOULD CURE THE DEFAULT AND ASSUME THE MORTGAGE DEBT PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE TIME OF SALE. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to cure a default more than three times in any calendar year. Collection Department #350 ADVANTA Mortgage Corp. USA WP12/ACT6BPF File Copy LLLTFIOA-e5 I: ~~.~ < ~ ~ ~ ~_ ~~ .~ 4 _ a~ r w ~ ~:~ y~ ~ ,. a CASE NO: 2001-00316 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANKERS TRUST COMPANY OF CA VS CALVIN L ET AL PATRICIA SHATTO Sheriff or Deputy Sheriff of Cumberland Count y,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BULL DEBORAH K the DEFENDANT at CUMBERLAND CARLISLE, PA 17013 DEBORAH K. BULL a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /a,P" day of -e.Qu,~.r.a..., .~-Fry / A . D . /n~ ~^ < ~2.e_. ~.t~. /GiQQI.iA 0~1, at 0012:50 HOURS, on the 26th day of January 2001 SHERIFFS OFFICE 1 COURTHOUSE SQUARE by handing to So Answers: ~? R. Thomas Kline 01/26/2001 MCCABE, WEISBERG & CONWAY By . ~:iGli~~ ~, ~!~~.rP~GLd Deputy Sheriff Pz'othonotary SHERIFF'S RETURN - REGULAR CASE N0: 2001-00316 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANKERS TRUST COMPANY OF CA VS BULL CALVIN L ET AL PATRICIA SHATTO Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE BULL CALVIN L DEFENDANT was served upon the at 0012:50 HOURS, on the 26th day of January 2001 at CUMBERLAND CO SHERIFFS' OFFICE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 CALVIN L. BULL by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service .OU Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscribed to before me this ~ day of So Answers: R. Thomas Kline 01/26/2001 MCCABE, WEISBERG & CONWAY By~~. _. s Deputy Sheriff .-~- a OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Calvin L. Bull 2 Wheatfield Drive Carlisle, PA 17013 Bankers Trust Company of California, N.A., As Custodian Or Trustee v. Calvin L. Bull and Deborah K. Bull NOTICE JUDGMENT has been entered in the above proceeding as indicated Pursuant to Rule 236, you are hereby notified that a below. X Judgment by Default CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-316 Civil Term 2.~ Curtis R. Long Prothonotary Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe, Esquire at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Deborah K. Bull 2 Wheatfield Drive Carlisle, PA 17013 Bankers Trust Company of California, N.A., As Custodian Or Trustee v. Calvin L. Bull and Deborah K. Bull NOTICE JUDGMENT has been entered in the above proceeding as indicated Pursuant to Rule 236, you are hereby notified that a below. X CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-316 Civil Term Curtis R. Long Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe. Esquire at (215) 790-1010. McCABE, PTEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Bankers Trust Company of California, N.A., As Custodian Or Trustee v. Calvin L. Bull and Deborah K. Bull Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-316 Civil Term ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Interest from 1/1/O1 through 3/23/01 TOTAL AND NOW, this a4,'~ $160,098.95 $ 3,262.78 $163,361.73 TERRENCE J. M,ECABE, ESQUIRE day of l~. ((~2cf~ 2001, Judgment is entered in favor of Plaintiff, Bankers Trust Company of California, N.A., as Custodian or Trustee and against Defendants Calvin L. Bull and Deborah K. Bull and damages are assessed in the amount of $163,361.73, plus interest and costs. BY THE PROTHONOTARY: MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Bankers Trust Company of California, N.A., As Custodian Or Trustee v. Calvin L. Bull and Deborah K. Bull Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-316 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA The undersigned, being duly sworn according to law, deposes and says that the Defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendants,Calvin L. Bull and Deborah K. Bull are over eighteen (18) years of age, and reside at 2 Wheatfield Drive, Carlisle, PA 17013. _ SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY /7~c~ d~`~C~ TERRENCE J MCCABE, ESQUIRE OF 2001. Attornev for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Bankers Trust Company of California, N.A., As Custodian Or Trustee v. Calvin L. Bull and Deborah K. Bull Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-316 Civil Term I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the Complaint and is calculable as a sum certain from the Complaint. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the parties against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. True and correct copies of the notices pursuant to Pennsylvania Rule of Civil Procedure No. 237.1 are attached hereto and marked Exhibit "A". TERRENCE J. f c ABE, ESQUIRE Attorney fo~~ Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS ~~~DAY OF M~C~ 2001. The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. A Q ~c TERRENCE J. M CABE, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 LAWRENCE E. WELKER Prothonotary February 16, 2001 To: Calvin L. Bull 2 Wheatfield Drive Carlisle, PA 17013 Bankers Trust Company of California, N.A., As Custodian Or Trustee v. Calvin L. Bull and Deborah K. Bull CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-316 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the Court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. Yau should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personalmente o por abogado y por no haber radicado por escrito con este Tribunal sus defensas u objeciones a los rectamos formulados en contra suyo. Al no tomar la action debi da dentro de diez (10) dias de la fecha de esta notification, el Tribunal podra, sin necesidad de comparecer usted en torte u oir preuba alguna, dictar sentencia en su contra y usted podria perder bienes u otros derechos importantes. Debe llevar esta notification a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero sufici ente para tal servici o, vaya en persona o flame por tetefono a la of icing, nombrada para averi guar si puede conseguir asistencia legal. Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire MCCABE, WEISBERG AND CONWAY, P.C. First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 TJM/11 OFFICE OF THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 LASNRENCE E. WELKER Prothonotary February 16, 2001 To: Deborah K. Bull 2 Wheatfield Drive Carlisle, PA 17013 Bankers Trust Company of California, N.A., As Custodian Or Trustee v. Calvin L. Bull and Deborah K. Bull CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 01-316 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the Court your defenses or objections to the claims set forth against you. Unless ydu act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personalmente o por abogado y por no haber radicado por esc rito con este Tribunal sus defensas u objeciones a los reclamos formulados en contra suyo. Al no tomar la action debida dent ro de diez (10) digs de la fecha de esta notification, el Tribunal podra, sin necesidad de comparecer usted en torte u oir preuba alguna, dictar sentencia en su contra y usted podria perder bienes u otros derechos importantes. Debe llevar esta notiticaci on a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suf iciente para tal servicio, vaya en persona o Name por telefono a la of icing, nombrada Para averiguar si puede conseguir asistencia legal. Court Administrator Cumbarland County Courthouse Carlisle, PA 17013 (717) 240-6200 Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. First Union Building 123 South Broad Street; Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 TJM/11 c~ c_ ~~` n r, ~ ~ ~` < ~..: ~ ti ~.~J `, ~ ~.dz Y ~. ~\ 'G° ~ ~ y ~ ~ ~~ ~W :~~ s -~ ~ .u `j ~! ) '^,t _ - i .~ ) ~, <a :< McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Bankers Trust Company of California, N.A., As Custodian Or Trustee v. Calvin L. Bull and Deborah K. Bull Attorney for Plaintiff Cumberland County Court of Common Pleas i Number 01-316 Civil Term PRAECIPE TO MARK JUDGMENT SATISFIED AND DISCONTINUE AND END TO THE PROTHONOTARY: Kindly satisfy judgment and mark the above-captioned matter discontinued and ended, without prejudice, upon payment of your costs only. ~ ~ ___- TER ENCE J. cCABE, ESQUIRE Attorney for Plaintiff t'~ r..~ CY q ~ n`,..--. ~ ....~ ~ S ~ rn N ~~;° v 'ra ~~~ ~ `- ~, j n _ -•r ~ - a v ~ U -~ ~' '~V~