HomeMy WebLinkAbout08-0077
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
1310 INDUSTRIAL BOULEVARD
1ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
ATTORNEY FOR PLAINTIFF
VALUE HOME LOAN, INC.
5959 TOPANGA CANYON BOULEVARD,
#201 WOODLAND HILLS, CA 91367
PLAINTIFF
VS.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
1059 A YORK ROAD
DILLSBURG, PA 17019
DEFENDANTS
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 68, 77 Civil, Term
COMPLAINT IN
MORTGAGE FORECLOSURE
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the court your defense or objections to
the claims set forth against you. You are warned that if you fail to do so the case may proceed without you
and a judgment may be entered against you by the Court without further notice for any money claimed in the
complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
800-990-9108
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF.
IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE
VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN
EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT
FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE
NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD
THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO
CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT
UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
1310 INDUSTRIAL BOULEVARD
1 IT FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
ATTORNEY FOR PLAINTIFF
VALUE HOME LOAN, INC.
5959 TOPANGA CANYON BOULEVARD,
#201 WOODLAND HILLS, CA 91367
PLAINTIFF
VS.
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
STEVEN M. ZEIGLER NO.
MARSHA J. ZEIGLER
1059 A YORK ROAD COMPLAINT IN
DILLSBURG, PA 17019 MORTGAGE FORECLOSURE
DEFENDANTS
CIVIL ACTION MORTGAGE FORECLOSURE
1. Value Home Loan, Inc. (hereinafter referred to as "Plaintiff") is an Institution conducting
business under the Laws of the Commonwealth of Pennsylvania with a principal place of
business at the address indicated in the caption hereof.
2. Steven M. Zeigler and Marsha J. Zeigler (hereinafter referred to as "Defendants") are
adult individuals residing at the address indicated in the caption hereof.
3. Plaintiff brings this action to foreclose on the mortgage between the Defendants and itself
as Mortgagee. The Mortgage, dated June 13, 2006, was recorded on June 28, 2006 in the
Office of the Recorder of Deeds in Cumberland County in Mortgage Book 1956,
Page 2234. A copy of the Mortgage is attached and made a part hereof as Exhibit `A'.
4. The Mortgage secures the indebtedness of a Note executed by the Defendants on
June 13, 2006 in the original principal amount of $150,000.00 payable to Plaintiff in
monthly installments with an interest rate of 11.49%. A copy of the Note is attached and
made a part hereof as Exhibit `B'.
5. The land subject to the mortgage is 1059 A York Road, Dillsburg, PA 17019. A copy of
the Legal Description is attached and made a part hereof as Exhibit `C'.
6. The Defendants are the Record Owners of the mortgaged property located at
1059 A York Road, Dillsburg, PA 17019.
The Mortgage is now in default due to the failure of the Defendants to make payments as
they become due and owing. As a result of the default, the following amounts are due:
Principal Balance $129,433.21
Interest to 12/18/2007 $7,285.54
Accumulated Late Charges $901.67
Cost of Suit and Title Search $550.00
Attorney's Fees $1,000.00
TOTAL
$139,170.42
plus interest from 12/19/2007 at $41.31 per day, costs of suit and attorney's fees.
8. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchase at Sheriff's
sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be
charged.
9. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a
defaulting mortgagor with a Notice of Homeowners' Emergency Mortgage Assistance
("Act 91 Notice") 35 P.S. Section 1680.403c.
10. The Notice of Homeowners' Emergency Mortgage Assistance was required and Plaintiff
sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to
the Defendant by regular and certified mail on November 16, 2007. A copy of the Notice
is attached and made a part hereof as Exhibit `D'.
11. The Mortgage is not a residential mortgage under 41 P.S. Section 401 because the
principal amount of the Mortgage is in excess of $50,000.00 and, therefore, Plaintiff was
not required to send the Act 6 Notice of Intention to Foreclose.
WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the
mortgaged property in Plaintiff's favor and against the Defendants, in the sum of $139,170.42 together
with the interest from 12/19/2007 at $41.31 per day, costs of suit and attorney's fees.
Law offices of Gregory Javardian
BY:
Gory Ja rdia
ttorney ID N 5669
Attorney for Pl ntiff
EXHIBIT `A'
10/31/2007 14:34 8184441912 LOAN SERVICING PAGE 06/13
Recerding Requested By &When Recorded
riidi]"'1'u
Value Hoine Loan, Inc.
5959 Topanga Canyon Blvd. #201
Woodland Hills, CA 91367
Loan No. 51977
ThIc Order No.
(F?fl •. d L
Space above this lira for rcrrxda's use
LONG FORM DEED OF TRUST AND ASSIGNMENT OF RENTS FOR
HOME EQUITY REVOLVING LINE OF CREDIT
THIS DEED OF TRUST, made this 13th day of dune, 2006, between Steven M- Zeigler & Marsha J. Zeigler, heroin called
TRUSTOR, whose
address is 5959 Topanga Canyon Blvd., suite #201, Woodland Hills, CA 91367
COUNTY RECORDS RESEARCH., a California corporation, I - rcnr called TRUSTEE and VALUE HOME LOAN, INC., a
California eorpomiiocy CFL #_6038218_ whose address is 5959 Topanga Canyon Blvd 0201 woodland Hills , CA 91367, herein
called BENENCIARY.
Witnesseth, That TRUSTOR IRREVOCABLY GRANTS, TRANSFERS AND ASSIGNS to TRUSTEE IN TRUST, WUH
POWER OF SALE that property in Cumberland County, Pennsylvania described as (the "Property") .
TOGETHER WITH the rents, issues and profit thercot SUBJECT HOWEVEIR, to the right, power and authority given to and
conferred upon Beneficiary in Paragraph 10 below to collect and apply such rents, issues and profits.
FOR TEM PURPOSE OF SECURNG:
(A) Perforrnatlce of each agremient of Truster contained in tills Deed of Trust.
(13) Payment of the indebtedness evidenced by a Home Equity Credit Line Revolving Loan Agraetnetlt (horeinafter
referred to as "AGREEMENT-) of even elate herewith in the initial principal Mount of $150,000.00, but subject to increase to a
inaxin mr of 5150,000.00, executed by Trustor in favor of Beneficiary or order, and any extension or renewal thereof Ile
AGREEMENT is a revolving lime of credit c nabling the Truster to redraw stuns previously repaid, to be secured hereby, pursuant to
the tcrrns of the AGREEMENT and this llccd of Ttust.
STATEMENT OF OBLIGATION: Beneficiary may collect the
for liurrishing a statement of obligation. then rnsicittn>zn fbc provided by Section 2943 of the California Civil Code
TRANSPER: If Truster voluntarily sells or conveys the above-(ksenl)ed property, frilly or partially, or any interest in it or, by sorne act or
means divest thernselves of title tD the Property without obtaining the written emsent of Beneficiary, Trustoir shaft be in default and
Beneficiary may, at its option, declare the entire un*d balance of the loan and sinned but unpaid interest irmoediately due and payable.
TO PROTECT THE SECIlItPI'lt OF THIS DEED OF TRUST, TRUSTOR ALSO AGREES:
(1) To keg the Properly in good condition and repair; not to remove or dcmotish any building thereon; to complete or restore promptly in good
and workmanlike manner any building which may be consmicted, damaged or destroyod thereon and to
requiring pay when due all claims for labor p of to>co and
materials fumi*M therefor, to comply with all laws affecting said Property &fmd
nuni requiring any alteration or improvement to be made thereon; not to %x
or Permit waste thereon- not to co
do all other acts which iirOm the c}taracter permit any act upon said Property is violatitro of law; to cultivate, irrigate, fertilize, fumigate, pnme and
or use of said Property may be reasonably necessary, the specific en
(2) To provide, maintain aW deliver ro Bonoficiary fire m unable ton herein not excluding the generpe
under any fast or other instrrartcc policy may be applied by )3en & ? satisfactory with 0 ?6 payable to Beneficiary. The amount collected
r-by in us and such order as Beneficiary may
determine, or at option Of Beneficiary, the entire amount so eollcuted or any secured ha
to Truetor. Such application or release shall not
cure or waive any default or notice of dcthult ?eindcr or invalidate any ad M done ? purssuauent may
to y be such h micased notice.
(3) To appear in and defend any action or proceeding purporting to alter the security hereof or the rights or pawed of Beneficiary or 7tustee;
and to pay all costs and expenses, including com of evidence of title and attorneys fees in a reasonable suet in any such action or proceeding in which
Beneficiary or Trustee may appear, and in any suit brought by Beneficiary to enforce this peed of Trust
ZO • Hobe Deed of Truet 5112 x5r11 7?J15r7 ! Pagel e l -t of
or
finC9Z
10/31/2007 14:34 8184441912 LOAN SERVICING PAGE 07/13
. (4) To pay at least ten days beffor : delinquency all taxes and assts aging said Property, including assessments on appurtenant water
stock, anthem due, all etcurnbraeus, charges and fiats, with interest, on said property or any 15011 thereof, which appear to be prior to or
tee
a'td all costs, fees and experues of this Trust. Should Tnotor fail to makecto;
?pay superior her
-but without obligation so to do and without notice to or demand tupat or to do any act as herein provided, then 13tahpfictacy or "Irtustee,
the same in such manner and o such extent as either to upon Trustor and without releasing 11rustor fi+orm any obligation hereof, may make or do
upon aeid Psuc ray far such may deem necessary to protect the security hereof; Beneficiary or Trustee being authorized to enter
Beneficiary rop rty o[, pay, puTose, appear
se, contest m and defend any action or proceeding purport to afteet the security hereof or the rights or powers of
superior hereto, and in era, ' an such or eompmarise any aaoumbrartce, charge or hen which in the judgment of either appears to be proper or
y power, , pay necessary Capenses, employ counsel and pay his reasonable fees.
(5) To pay immediately and without demand all suers so expended by Beneficiary or Trustee, with f umce fiorn date of
the appiiftble Annual Percentage Rate in the AGREEb(ENT, and to pay for any smtamerrt provided by ha 8es tacgar& g the
obligation sectntid hereby any amount demanded by Beneficiary not to exceed the maxtrawn allowed by law at laws
the in titrm e at the date hereof is demanded. the
time when said statement is demanded.
(6) That ady award of damages
assigned and shall be in connection with any condemnation Cot public use of or injury to said property or any plat thereof is hereby
paid to Batc£rciary who may apply or release such honeys received by him in the same nw mcr and with the same effect as above
provided for disposition of proceeds of fire or other insurinw-
(7) That by accepting psytrmt of any sum secured hereby after its due date, Beneficiary does not waive his right either to require
paymcnt when due of all other sumo so secured or to declare default for failure so to pay. prompt
(8) That why time and f am time to time, withmot liability therefor and without notice, upon written request of Beneficiary and presentation of
this Deed of Trost and said AGREEMM for endorserttent, and without affecting the personal debitity any person fbr segued hereby. Trustee may. reconvey any part. of said Properly' consent to the making of any map or plat of e payment of the meat tro,
or join in any extension agreement or any thereof; join in granting any casement the rcort
agrecrte tt subordinating die nc fl liea or charge hereo£
(9) That upon writtert request of Beneficiary slating that all stuns secured hereby have beat paid, and upon surrender of, this Deed of Trust and
said AGRl WENT to Thistec for canmustioo and retention and upon payment of its fees, Trustee shalt reeonvey, without wactanty, the Property then
held hereunder. The recitals in such reconveyarm of any matters of &ct shall be conclusive proof of the truthfulness thcrrof. The grantee in such
reeonvoyance nay be described as, "the person or persons legally entitled thereto.' Five years after issuance of such full mconveyance, Trustee may
destroy said AGREEMENT and the Aced of Trust unless directed in such request to retaitt them
these (10) That as additions) security, TPntatpr hereby given to and confers upon Bedcficiary the right, power and authority, during the continuance of
Trusts, to collect the rents, issues and pmfits of said Property, reserving unto Truster the right, prior to any default by Ttuetor in payment of any
indebtedness secured hereby or in performance of any agreement hereunder, to collet and retain such rents, issues and profits as they become due and
payable od to any th such default, Beneficiary my at any time without notice, either in person or by agatt, or by a receiver to be appointed by a court, and
without adequacy of any security for the indebtedness hereby spouted, enter upon and take
his own name we for or otherwise collect such possession plsaid Property s any part hereon: in
of ?6 issues and profits, including those pest due and unpaid and the seine
operation and collection, including attomey's fees upon any indebtedness secured y ,less costs and expenses
entering upon and taldm hereby, and in such order as Beneficiary may determine. The
g possession of said .Property, the collection of such rents, issues and profits and the application thereof as aforesaid shall not cure
or waive any default or notice of default hereunder or invalidate any ace done pursuant to such notice.
(11) That upon default by Tr;rstor tinder the AGREBM M, Beneficiary may declare all sums secured hereby roan edistely due and payable by
delivering to Trustee a written declaration of default and demand for sale and a written notice of default and election to cause to be sold said Property,
which notice Trustee shall cause to be filed for record. Beneficiary also shall deposit with T}ustee this Deed of Trust, the AGREEMBNT and all
documents evidencing cxpEndiycrca secured herein. Aria the lapse of such time as may then be required by law following recordation of said notice of
default, and notice of sale having been given as then required by law Trustee, without demand upon Truster, shall sell the Property at the time and place
fixed by or in said notice of sale, either as a whole or in separate parcels, and in such order as it rosy detetrune, at public auction to the highest bidder for
cash in lawful money of the United $rates, Payable at time of Sale. Trustee may postpone sale of all or any portion of said
announcement at the eitttc fixed by the preceding postponernetrt- Truster shall deliver to such purchaser its decd conveying ?? by public
covenant Or watatHy, express or implied. The recitals in such deed of any matters of Set Shall be cot othe the Properly, but without
of
person, including Mustor, Tmshec, or Beneficiary, as hereinafter defined may sale- Purchase at such After deducting proof of the truthfulness thereof. s Any
educting ail costs, fps and expenses of
Trustor and of this Trust, including oom of evidence of title in connection with sale, T stor shall appl the of
expended under the terms hertot not then repaid, with accrued finance chirps at tic a y proceeds in the sate to payAGpayment MFent NT , of all sums
sums then secured thereby. $? tiled thle Attttua! Percentage Rate in till other
and the rennainder, if any, to the person or puraons lily entitled thereto.
(1z) Beneficiary or any successor in ownership of any indebtedness seared hcrtb ma from time to tisubstitute a successor or successces to any Tnme named herein or acting hereunder, ereuroe, in an y instrument in writing,
, which u instruments ?? by Beaefciary and duly acknowledged
and recorded in the offitx of the recorder of the county or
successor Trustee or Trustees, who shall, without ? yan?frm the Tty? ? is situated, shall be conclusive proof of poops substitution of such
instrutrrerd mast contain the name of the original Truster, Trustee and Beneficiary hereunder, the book its g title, estate, this Dee, pow and duties. Such
the nacre and address of the new Trustee. page when this Deed of Trust is recorded and
(I3) That this Deed of Trust applies to, inures to the benefit of and binds aU parries hereto, their hats, legatees, devisees, administrators,
executors, successes and assigns. The tam Beneficiary means the owner and holder, including plus, of the AGREEMENT secured hereby, whether
or not mooed as Beneficiary herein. In this Decd of Trust, whenever the context so requires, the masculine gender includes the feminine and or neuter,
Rod the singular number includes the plural.
(14) That Trustee accepts this Trust when this Deed of Trost, duly executed and acknowledged, is made a public record as provided by law.
Trustee is not obligated to notify any party hereof of a pending sale raider any otter deed of trust or of any action or proceeding in which Ttustor,
Beneficiary or Trustee shall be a parry unless brought by Trustee,
(15) If this Dccd of Trust is secumd by eondomirtiazA community apartment stock cooperative leasehold or planned unit devele
agrees to comply with all recorded declaration of covenants, conditions and restrictions, association b la
? pmeno Truster
upon written request from Beneficiary, to enforce the same as against other owners in such developments and association rules and regulations, and,
(16) If the Deed of Trust is scarred by a lease. Truster agrees not to wicr d, change, modify or waive his or her interest thaCin, or ag= to do
so or to breach the lease without the written consent of Beneficiary. If this Covenant is breached am the security for this Dom of Trust is materially and
20 - Heloc Died of trust ate x I7 nr Fagg 2aW
.10/31/2007 14:34 8184441912 LOAN SERVICING PAGE 08/13
advea"eiy sffio4eri, BenefWojy shall have the option to declare all =W Owed under the AGRFBMP,NT And this lid of n st, immediately due and
parAle in W.
TRUSTOR REQU THAT A COPY OF ANY NOTICE OF DEFAULT AND OF ANY NOTICE OF SALE BE MAILED TO TRU .
AT TRUSTOR'S ADDRESS SET FORTH ON TOE FRONT OF TIEIQS DEED OF TRUST. STOR
IN ACWRDANCE WITH SECTION 2924b OF TIM CAL FORNIA CIVIL CODE, SUM IS HEREBY MADE BY THE TRUSTOR THAT A
COPY OF ANY NOTICE OF DEFAULT AND A COPY OF ANY NOTICE OF SALE UNDER DEW OF TRUST RECORDED ON
Recordeu's Serial Number is Book Page Official Records of County (or bled for record with
of same Conntyj California afferxin the Property deems-W on the A=t of this instrument
aunded by as TnwW in which is named as Beneficiary,
and - as Trustee, be mailed to County Records Research at 4952 Warner Ave. #105 Ifunti
CA 92649. nBtan Beach,
SIGNAT UM OF TRUSTORM:
6It-rlej b
80. 0"a Sheen IL Z Dane
QzMajke J. Pate
State ofRwwmj8_ t'&a-'CLq(l1Q'; Q- )
cowty of 0tL•-be-o0---'LS )35.
atmeaturd 2VP M / . r. n . _ u r _ ?- _ a oozy public, personally
personally known to me (or proved=nrr the basis of satTsfactiory a ce) to be -the person(s) wbQ5C mettle(s) Ware subscribed to
the wider insftnent and acknowledged to tnc that be/she/they executed the same in his/her1b0ir authorized capacity(ies), and that by
leis/ =MXir sigpnature(s) on the instrument. the person(s), or the entity neon behalf of the person(s) =4 executed the instrument.
WLTNBMS my hand and official seal. A)y &M "Ss; 0,-, 6x p'-i re-1- ' /% 1/O F
SUu re
COMMONWEALTH OF PENNSYLVANIA
N&AW Seal
Ulds M. 8eeaub, Notary PUbfie
Hampden TwR,. Gxnbadard county
My CGMM'WW Expires Oct 21, 20M
Member, Pennsylvania Association of Notarlaa
(SMI)
2a - Heloc vend of Tnrt am x41X79p,? l
EXHIBIT `B'
.10/31/2007 14:34 8184441912 LOAN SERVICING PAGE 10/13
HOME EQWTY CREDIT LINE REVOLVING LOAN .AGREEMENT
Jun 13, 2006. This is an agreement containing the terms and disclosures which apply to your home equity line of credit
account ("Account") with Value Home Loan Inc, whose address is 5959 Topanga Canyon Blvd., suite #201 Woodland Hills CA
91367., a California corporation, CFL # $038218. The words "we" or "us" refer to the lender named in the previous sentence. The
words "you" or "your" mean the pmon or persons who use or authorize the use of the Account, jointly and severally.
1. How You May Use Your Account. Dining the first 36 months of the Account ("Draw Period), you can borrow money ("Cash
Loan') from your Account by nag a written request to us up to your maxinmm credit limit. After the Draw Period you will not be
petted to borrow money but mist repay your Account in full over a 180 month period ("Repayment Period'). Your Account is a
revolving line of credit. You cannot request money in excess of the available credit (the difference between your outstanding balance
and your maximum credit limit) on your Account. You may not request less than $1,000.00 at any one time- Requests for money mast
be in writing sent to us at an address we will give you. We will respond to it within 5 business days after receipt of your request. For
the first 30 days after your Account is open, you will not be permitted to draw more than 80% of your initial credit limmit, nor draw
more than $5,000.00 in any 30 day period. You cannot make more than one draw request per 30 day period
2. Maximum Credit Limit. Your initial credit limit is $150,000.00, of which your first Cash. Loan shall be 5120,000.00. You agree
that we can change your credit limit at any time at our sole discretion but it shall never exceed $150,000.00. You also agree that we
are not obligated to extend further credit to you for arty amount that would make your outstanding balance exceed your initial credit
limmit, or for any amount if your outstanding balance is already over the initial credit limit. We may disburse funds from your available
credit and assess the cash advance fee to cure any default related to your property. Any increases in your initial credit limit you request
will require that you make a written appbcetion for our approval. You will pay any amounts that exceed your maximum credit limit
upon demand. We may reevaluate your financial condition if you request a higher credit limit; or at any other time, and this may
include obtaining a current credit bureau report, and/or asking you for current financial information. We ma
obtain additional Cash Loans when.: (i) the value of your y suspend your right propm-ty bas the
Account was opened, (ii) we reasonably declined more than 20% from the appraised value at the time the
cause n of was
material adverse believe that you will be unable to fulfill your .repayment obligations under this Agreement
A
be a
holders nests such change in your financial circumstances, (iii) you file a banikauptcy petition, (iv) one of the Account
reQ suspension or (v) governmental or court action- If you believe that one of the conditions is no longer present, we
will reinstate your ability to obtain Cash Loans if you so request in writing and we confirm that the condition is no longer present.
3. Monthly Statement. If you have an outstanding debit or credit New Balance of $1.00 or more, or if there is any finance charge
imposed during a billing cycle, we will send you a statement 20 days prior to the payment due date. You agree to pay us for all Cash
Loans, fees and charges, if any, and Finance Charges on your Account, all payable in United States Dollars according to the terns and
conditions of this Agreement no later tha, the payment due date. The payment due date will be the same date each month which, is
thirty days after the original fiwding date of your loan.
4. Finance Charge on Your Account Balance. We will determine and impose a SCE CHARGE b a 1 'n a dail
rate of 0.03192% to the daily unpaid Y pP Yr g y periodic
principal balance for the nurnber of days that balance remains unpaid in the billing cycle. The
daily periodic rate is the Gof I IA9 /° divided by 360. The Annual Percentage Rate is subject to
change as explained w section 5 below. To get the daily unpaid principal balance, we will take the Ire
any new debits or Cash Loans and subtract any payments or credits. The Annual Percentage Rate does not include costs each dbed in
this Agreement other than interest. A portion of the Finance a will be figured MO% of each Cash Loan to each cash loan after the firsts Cash by applying a cash advance fee (a transaction fee)
Finance charges accrue on a new Cash Advance and the related cash adLoan, the date the new vance fee as soon as the Cash dvancpeois made your
Amours we.
must pay to protect the security of our Decd of Trust will earn finance charges at the Annual Percontage gaze applicable during default
as soon as we make the advance.
5. Changes in the Annual Percentage Rate. The Annual Percentage Rate on your. Account may change based upon changes in the
value of an Index. During the Draw and Rcpayrnent Periods, the Index is the Wall Street Journal Prime Rate. If the Index is no longer
available, we will choose a new Index that is based upon comparable information and will ive
Percentage Rate may only change once 8 you notice of this choice. Your Annual
per year, on June 1 a. The first adjustment will not occur until the third year of the loan. To the
Index value as of the first business day in the preceding May, we will add a margin of 4.5%- The sum of the Index value and the
margin will be your new Annual Percemge Rate, subject to the limits described in the remainder of this section. You will pay
periodic Finance Charge at the new rate starting with the following July l" payment. The ma
apply during the Draw and Repayment Periods will be 10.0% ercenta ximum Annual Percentage gate that can
minimum Annual Percentage Ratc that can apply during the Draw and Repayment pouts over the initial Annual Percentage Rate. The eri
the initia are tzo other limits on how much the Annual Percentage Rate can change at anoe annual adjustment A ?1 Percentage fiate. 'fh.ere
Applied suelnesz $*ggre. Inc. (800) 833.3343 5e -
19 - Mc,bc Nde8r/157 PA90d of 4, nqL
•10131!2007 14:34 8184441912 LOAN SERVICING PAGE 11/13
6. -IMInlinum Payment. You agree to pay either the entire outstanding balance ("New Balance") indicated on your monthly statement
or in monthly payments. During the Draw period, the minimum
Monthly Poi nt ("Mirtitraim Payment Due") you must pay will be
equal to just the interest at the then applicable Annual Percentage Rate that accrued during the billing cycle, without an
reduction of the unpaid principal balartm. You can always pay more if you wish. Y Provision for
you have paid the unpaid principal balance in full Dunning the Repayment Period and continuing until
. your Minimum Payment Due will be fixed at each adjustment of the Annual
Percentage Rate at an amount sufficient to fully repay what you owe in equal monthly installments by the end of the 180 month
Repayment Period. Each July 1 during the Draw and Repayment Periods, changes in the Annual Percentage hate will result in
changes to the amount of your Minimum Payment Due_ If you default and we must advance other sums to protect the security of our
Deed of Trust, you agree to pay these armwnts in full together with the next tegularly scheduled Minimum Payment Due.
7. Fees.
(a) ,late Payment Fee: Your Minirnuai Payment Due will be past due if it is not received by us on or before the Pa
Date shown on each monthly statement. A late charge of 10.0% of the yrnent Due
Account, if at least the Minimum Pa pay meztt with a minimum, of $25,00 will be charged to your
Date ynnent Due, including unpaid payments, is not received by us within 10 days after the Payment Due
(b) Fee for Documents: If you request a copy of a statemwt, Cash Loan request or other document not in connection with a
billing error, we will charge your Account the sum of $15.00 for each copy.
(c) Annual or Initial Fees: You agree to pay, by a debit to your Account, the following initial, non-refundable fees to set up
this Account.
17 gkdon
Title insurance Amu-at
$395.00 (estimated) motion Amount
Recording Fee
$45.00 (estimated) Escrow Fees
Loan foe
$395.00 (estimated)
Appraisal Fee $200.00 POE:
Other: Loan Setup 12.0% of initial advance
5795.00
You agree to pay the exact amount of any initial fee that is estimated. There are no annual lees on this Account, but you will pay a
cash advance fee for new Cash Loans.
(d) Returned Payment Check Fee: If you make payment by check and a check is returned unpaid for any reason, your Account
will be charged 525.00 for each returned checlc
8. Draw and RepaYnwnt Periods. During the Draw Perin ?
RS you own Your property and you ar?C not a default. You may add Cash Coatis to your Account for up to 36 months so long
Payment unto the Pro ert Balance is paid t full. On vvxi , to You the RMaytnent Period, you must pay at least the Minimum
but we are not obligated to do so. Y? can extend your brew Period or your Repayment Period,
9. Application of Payment. We will determine the method of applying your payments and credits to your Account.
10. Security. All of your obligations under this
1059 A York Road Dillsburg PA 17019. meat an secured by $ deed of trust (`heed of Trust") on your property located at
You may buy Property insurance from anyone that is acceptable to us. You will provide proof you are insured under the policy.
The Decd of Trust allows us to declare a default if you sell or transfer your property without our prior written consent
"Trrrstor," we are the "BeneficiaM,, and the ,pWpCtW, is {you are the
TR.INS'FBR• If Tn4mr Vela rtarll seb's or con Yom mop in the following quotation):
? the aboy&daa!bad Prop0?V f ly or partially, or any imeresr in it or, by some
actor nAwnsdi> 4t thenrsdt+rss o title to the Property without obtaining the wtittert consent
aa? idwy may, at its apiid" • 'lure the smirr unpaid balanoe of the hate and a `ar}' Tramor shall be in defarelt
Yapaid Interest lmmediamly due
1 i. Events of Default. You will be in default under this Agreement if any of the following events occurs: a if
with the Minimum Payment or any other tCrrns or conditions of this Agreement; { } you fail to comply
an Account holder survives we (b} if you die and you are the only Account holder or if
you, deem I., security for the Account adversely affected; (c) you sell or transfer your property; (d) if
you fail to maintain the insurance mired by the Deed of Trust' (c) if a lien senior to our Deed of Trust on
( your property forecloses;
Yom proY is taken by emineut domain; (g) if you commit waste or otherwise destructively use or fail to maintain your
Property such that the action adversely affects the security of our Deed of Tract; (h) if You use
subjects Your Property to seizwe by govetrnherttai a„tl,orities i) if Your Property illegally and such use
affects the security for the Account; and
; ( you move out of your property and your non-occupancy, adversely
the Deed of Trust (i) You fail to Pay Property taxes and other assessment liens on your property that are senior to
12. Entire Balance Due. If you are in default, we may do one or more of the following: (i) require that
oat tanding balance with interest due on 16 balance, at the Annual. percentage Rate you immediately pay the
ten3tinate your right to obtain additional Cash Loans. We may exercise one of these provided above, until paid, or (ii) can
options without giving up our right to cxe xercisc
+SPpBad sushkfts 9a11Nwra. Mc. icon) 833-spa
JS1577151e77l teWgrl S ?
12 - Haim Mote Peyc 2 or 4
- ?
.10/31/2007 14:34 8184441912 LOAN SERVICING PAGE 12/13
another option if your default comtinm. If we demand full payment of the outstanding balance and you fail to immediately make
payment, You agree to pay all collection costs, including our attorney's fees.
13. Transfer of Account. You cannot transfer or assign your Aceotmt to any other petson.
14. Notice to Joint Applicants. Path applicant has the right to use this Account to the extent of the Maxinmm Credit Lunit and may
be liable fot all amounts extended under this Account to any joint applicant.
15. Change of Address or Telephone Number. You agree to advise us promptly if you change your mailing address or telephone
number. All written notices and statements from us to you will be considered given when placed in the United States mail, postage
prepaid, and addressed to you at your current address as it appears in our records.
16. Irregular Payments. We may accept late payrnents or partial payer or checks, drafts or money orders marked "Payment in
Full" without losing any of our rights under this Agreement.
17. Amendments. We may make insignificant changes to this Agreement at any time or changes that unquestionably benefit you, as
long as we give you advance written notice as required by law.
18. Cancellation. You can cancel your Account at any time by giving us notice and paying in full all sums due on your Account.
Your obligation under this Agreement, including our security interest in your property, and any changes made under, this Agreement
prior to cancellation will continue to apply until you have paid you all the money you owe on the Account
19. Other Provisions, Each of you who signed this Agreement or use the Account is individually and jointly obligated for all
payments due under this Agreement. The Account has been applied for, considered, approved and issued in the State of California and
all extensions of credit are being made from the State of California. You agree that this
interpreted under California and Federal law, If any part of this Agreement shall governed by and
agreement is not valid, all other parts will remain en nforceable.
20. Tax Consequences. You should consult a tax advisor about the deductibility of interest and other charges under this Agreement.
YOUR BILLING RIOTS - KUP 'HIS NOTICE FOR FUTURE USE
This notice contains important information about your nights and our responsibilities under the Fair Credit Billing
Act.
Notify Us In Case Of Errors or Questions about Your Sill.
If I think your bill is wrong, or if 3,ou need more information about a transaction on your bill, write to us on a
separate sheet at the address listed the bill We must hear from you no later than 60 days after we sent you the first
bill on which the error or problem appeared you can telephone us, but doing so will not preserve your rights.
In your letter, give us the following information,
Your full name and Account number.
The dollar amount of the suspected error.
Describe the error and explain, if you can, why you believe there is an error. Jf you need mere information,
describe the item you are not sure about.
If you have authorized us to pay ycw bill automatically from your savings or checking account, you can stop the
payment on any amount you think Is wrong. To stop the payment your letter must reach us by three business days
before tine automatic payment is scheduled to occur.
Your Rights and Your Responsibilities after We Receive Your Written Notice.
We must acknowledge your letter within 30 days, unless we have correetcd the error by then. Within 90 days, we
mast either correct the error or expl.a'n why we believe the bill was correct.
Amer we receive your letter, we cacnot try to collect any amount you question, or report you as delinquent. We can
continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount
against your credit lirnit. You do not have to pay any questioned amount while we are investigating, but you are still
obligated to pay the parts of your bill that are not in question.
Apole1 DuaM !! SuftwNe. I„c. (aoo) 833-3343
1 B • Helot Nole?771F1e ape a o? SY
,10/31/2007 14:34 8184441912 LOAN SERVICING PAGE 13/13
If we find that we made a mistalm on your bill, you will not have to pay any finance charges related to any
,gdestioned amou d. If we didn't wake a tuistake, you may have to pay finance charges, and you will have to make
up any missed payments on the questioned amount. In either case, we will send you a statement of the amount you
owe and the date that it is due.
If you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation
does not satisfy you and you write to us within ten days telling us that you still refuse to pay, we must tell anyone we
report you to that you have a question about your bill. We roust tell anyone we report to that the matter has been
settled between us when it finally is.
If we don't follow these rules, vm. can't collect the first $50 of the questioned amount, every if your bill was correct.
21- Csyforufia Notice. California law requires that we notify you that if you fail to fulfill the term of your credit
obligation, a negative credit report reflecting your credit record may be submitted to a credit reporting agency,
22. Early Closure Fee. This agreement is subject to an "Early Closure Fee." If you close your Lane of Credit and requested a
release of the security instrument securing your Property within 36 months of the loan agreement you will be required to pay an
"Early Closure Fee" in the amount of, $495.00. This Early Closure Fee is due wbetbcr said closure is voluntary or involuntaryas
in acceleration whether due to transfer or non-payment.
13y signing below, you agree to all of the above terms and conditions and certify that you have received a completed copy of this
Agreement and two copies of a Notice of Right to Caneel this Agreement on the date shown below.
t:11
Dale UNWN J. Zwgkr
CFb IMders dWA below:
[ ) FOR INFORMATION CONTACT THE DEPARmENT OF CORPORATIONS, STATE OF
CALIFORNIA
AppUpd aullnm sellwwa. ftn4 ,eoo) ea:3,saea
J51arrl519T71 zagW
,s-HaloeNote PW4d4
EXHIBIT `C'
ALL 7NATCMAIN tout of bad s+ is d* Txreldip xf i&wzoa, Cmaety ofewulh land.
aad Caaamweahh xfP-V]V k Ldat amee pwalY banded and described as Mom.
to wiz
BEGINNM at a pdr of sioaea d cugmw cf kmk now w fcr? xf nmia N* Mum= aml
Gantt S Sk=* heia: dance Saco lu 446mes 07 m6wl k West a disyaoc o f 1 A9J5 feel
alma loads saes ar y ofGeolsa B Sank bees lea ric of a wwr dw4e Nw& 2 dwo=
46 atistmes Wet a diftem 095949 tees dm %Ind. peewar f0lout ' Qf W. Hobow m a Pile of
rmci dw- Na4 $3 dgreea 67 yea em a dhwA, of MA6 fief dcmc lode aaw or
f-?Y afG. W-Ir 3%vdc so a plc ofal mq Ibaaee Sash 21 dWm 45 wdaalea Easy a
d«ranoe Of"MOO fat aloa=1am. - xr fv wgdy ofHawy A. Sebullz and Mama N. Mum ata
a a pile of slonca and ptace OMBOiNNM
CONTAMING IM acm is acooedibmw wit} aLwvcrpnquuxd {pr pqyect E. SiMcr. RAcaizicrod
SurftM. and dosed Sepua6er 31.1464.
&-m 155 t4 262
EXHIBIT `D'
I?
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
November 16, 2007
STEVEN M. ZEIGLER, A/K/A STEVEN M. ZEIGLER, A/K/A
STEVEN ZEIGLER STEVEN ZEIGLER
1059 A YORK ROAD 4909 LOUISE DRIVE, SUITE 104
DILLSBURG, PA 17019 MECHANICSBURG, PA 17055
MARSHA J. ZEIGLER MARSHA J. ZEIGLER
1059 A YORK ROAD 4909 LOUISE DRIVE, SUITE 104
DILLSBURG, PA 17019 MECHANICSBURG, PA 17055
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
This is an official notice that the mortgage on your home is in default and the lender intends to foreclose
Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save
your home. This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet the
Counseling Agency.
The name, address and Rhone number of Consumer Credit Counseling Agencies serving your County are
listed at the end of this Notice. If you have any Questions you may call the Pennsylvania Housing Finance
Agency toll free at 1-800- 342-2397 (Persons with impaired hearing can call (717) 780-1869)
This notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. IS NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADA ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDA SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER
CURRENT LENDER/SERVICER:
STEVEN M. ZEIGLER, A/K/A STEVEN ZEIGLER
AND MARSHA J. ZEIGLER
1059 A YORK ROAD, DILLSBURG, PA 17019
51877
COUNTY RECORDS RESEARCH, AS TRUSTEE
FOR VALUE HOME LOAN, INC.
VALUE HOME LOAN, INC.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE
YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE
PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE.
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of
foreclosure on you mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -If you meet with one of the consumer credit
counseling agencies listed at the end of this notice the lender may NOT take action against you for thirty
(30) days after the date of this meeting The names addresses and telephone numbers of designated
consumer credit counseling agencies for the county in which the property is located are set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately
of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default). If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out
sign and file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO
NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Agency of its decision on you
application.
NOTE; IF YOU ARE CURRENTLY PROTECTED BY THE FILING
OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT
TO COLLECT THE DEBT
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date)
NATURE OF THE DEFAULT- The MORTGAGE debt held by the above lender on your property located
at 1059 A YORK ROAD, DILLSBURG, PA 17019 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due 8/22/2007 through 10/22/2007, one payment of which is due at a rate
of $1,263.38 per month, one payment of which is due at a rate of $ 1,305.40 per month, and one payment of
which is due at a rate of $ 1,317.46 per month.
Monthly payments plus late charges accrued: $ 4,143.12
(Suspense) ($0.00)
TOTAL AMOUNT TO CURE DEFAULT $ 4,143.12
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable):
N/A
HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DAYS of the date of
this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 4,143.12
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE THIRTY (30) DAY PERIOD. Payment must be made either by cashier's check certified check or
money order made payable and sent to: 5959 Topanga Canyon Boulevard Suite 201, Woodland Hills CA
91367: TELEPHONE NO. IS 1-818444-1930• CONTACT: GUSTAVO CARAVANTES
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter. (Do not use if not applicable) N/A.
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means
that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclosure upon your mortgage property
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay
off the mortgage debt. If the lender refers your case to its attorney, but you cure the delinquency before the
lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees
that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will
have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount to the lender, which may also include other reasonable costs. If
you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees
OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to
cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by
paying the total amount then past due, plus any late or other charges then due reasonable attorney's fees
and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as
specified in writing by the lender and by performing any other requirements under the mortgage Curing
your default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such a Sheriff's
Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of
this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER-
5959 Topanga Canyon Boulevard
Suite 201
Woodland Hills, CA 91367
CONTACT: GUSTAVO CARAVANTES
TEL NO. 1-818444-1930 ext. 262
EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE- You ____ may or XX may not (check one) sell or transfer your
home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale that the other requirements of
the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT
TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED.
Very truly yours,
?ou? ?aa-azaG?a,1.
ATTORNEY FOR LENDER
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS
OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C §
1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE
DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING
WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN
VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE
VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT
OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)
THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY
(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING
YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT
YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT
TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU
HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF
THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR
WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT
OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS
(THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE
MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS
IN THIS SUIT.
CUMBERLAND COUNTY
Acorn Housing
14 S. 13th Street
Harrisburg, PA 17104
717.213.0150
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
is ,
VERIFICATION
The undersigned hereby states that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge, information and belief. The
undersigned understands that the statements therein are made subject to the penalties of 18
Pa.C.S. Section 4904, relating to unworn falsification to authorities.
oo C r?
-
f { r1
93
r.. ,
? 1 rn:r7
?
Lo a rM
f
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
Attorney I.D. #23705
e-mail: lawoffice(a)epix.net
VALUE HOME LOAN, INC.,
Plaintiff
V.
STEVEN M. ZEIGLER and
MARSHA J. ZEIGLER,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-77 Civil Term
PRAECIPE TO ENTER APPEARANCE
To: Curt Long
Prothonotary
Please enter my appearance on behalf of Defendant, STEVEN M. ZEIGLER, in
the above captioned matter.
Date: 02 a
Gregory R. Ree , Esquire
Attorney for Defendant
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
Attorney I.D. 23705
pc: Gregory Javardian, Esquire
C ?v
t
_- CIO
?. CLa rr?
rs r r?
N ? rra
?f
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
e-mail: lawofficeL&epix.net
VALUE HOME LOAN, INC.,
Plaintiff
V.
STEVEN M. ZEIGLER and
MARSHA J. ZEIGLER,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
: NO. 08-77 Civil Term
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this Complaint
and Notice are served, by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment may be entered
against you by the court without further notice for any money claimed in the Complaint or for
any other claim or relief requested by the Defendant. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford St.
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas quese presentan mas adelante en las siguientes paginas, debe toma accion dentro de
los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte
por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier
otra reclamacion o remedio solicitado por el demandante puede ser dictado en constra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos
importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A
PERSONAS QUE CUALIFICAN.
Cumberland County Bar Association
32 S. Bedford St.
f
Date:
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
Gregory R. Reed, Esq ire
Attorney for Defendant Steven M. Zeigler
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
Attorney I.D. No. 23705
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
e-mail: IawofficeCt epix.net
VALUE HOME LOAN, INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
STEVEN M. ZEIGLER and
MARSHA J. ZEIGLER,
Defendants
NO. 08-77 Civil Term
ANSWER AND NEW MATTER
AND NOW, this i4d -day of February, 2008 comes Defendant, Steven M. Zeigler,
by and through his attorney, Gregory R. Reed, Esquire, and files an answer and new
matter, as follows:
1. Admitted.
2. Denied in part. Marsha J. Zeigler does not reside at the above referred to
address and has not resided there for a substantial period of time.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. It is specifically denied that the mortgage is now in default. Plaintiff was
illegally and erroneously charging defendants compound interest. Plaintiff acknowledged
the error and Jeffrey Keyser, an employee of plaintiff, granted defendants a six (6)
moratorium for the payment of the mortgage obligation. As such, said mortgage is not in
default, the interest claimed is not due and in the alleged late charges are unwarranted and
inaccurate. Also, the claim for the costs of suit, title search and attorney's fees are not
due because there is no default.
8. Defendant's answer to paragraph 7 hereof is incorporated herein by reference
as though fully set forth herein.
9. Admitted.
10. Admitted.
11. Neither admitted nor denied.
WHEREFORE, defendant, Steven M. Zeigler, respectfully requests this court
to enter judgment for both defendants and against plaintiff.
NEW MATTER
12. Defendant's answer to Paragraph 7 hereof is incorporated herein by reference
as though fully set forth herein.
WHEREFORE, defendant, Steven M. Zeigler, respectfully requests this court
to enter judgment for both defendants and against plaintiff.
Date:a
egory R. e , squi
Attorney for defendant teven M. Zeigler
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
Attorney I.D. #23705
I, Steven M. Zeigler, hereby verify that the statements made in the attached
Answer and New Matter are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements are made herein I am subject
the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
?1p
Date: U
Steven M. Zeigler
CERTIFICATE OF SERVICE
AND NOW, this __40 day of February, 2008, I, Gregory R. Reed, Esquire, Attorney for
Defendant, Steven M. Zeigler, does hereby certify that I have this day served by first class mail a
copy of the attached Answer and New Matter, to the following address:
Gregory Javardian, Esquire
1310 Industrial Boulevard
I" Floor, Suite 101
Southhampton, PA 18966
Gregory R. RvCd, EsOire
Attorney for Defendant, Steven M. Zeigler
3120 Parkview Drive
Harrisburg, Pennsylvania 17111
(717) 238-0434
Attorney I.D. 23705
cz)
),W,
CJ
=-c
! . w
CASE'NO: 2008-00077 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
VALUE HOME LOAN INC
VS
ZEIGLER STEVEN M ET AL
JESSICA HERMANSEN
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
ZEIGLER STEVEN M
DEFENDANT
was served upon
the
, at 2047:00 HOURS, on the 22nd day of January , 2008
at 1059 A YORK ROAD
DILLSBURG, PA 17019
STEVEN ZEIGLER
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.64
Affidavit .00
Surcharge 10.00
.00
a?c7?bp 36.64
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
01/29/2008
GREGORY JAVARDIAN
By:
?oj D ty Sh riff
A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-00077 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
VALUE HOME LOAN INC
VS
ZEIGLER STEVEN M ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
ZEIGLER MARSHA J the
DEFENDANT
, at 2006:00 HOURS, on the 28th day of January , 2008
at 405 FRONT STREET
BOILING SPRINGS, PA 17007
MARSHA J ZEIGLER
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
4.80
10.00 R. Thomas Kline
qv-716 ? 20.80
Sworn and Subscibed to
before me this day
01/29/2008
GREGORY JAVARDIAN
By:
Deputy 'Sheriff
of A. D.
r'
THE LAW OFFICES OF GREGORY JAVARDIAN
BY: JAMES P. KENNEDY
ATTORNEY I.D. # 86614
1310 INDUSTRIAL BOULEVARD
,IT FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
Attorney for Plaintiff
VALUE HOME LOAN, INC.
Plaintiff
vs.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
Defendants
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
No.: 08-77 Civil Term
PLAINTIFF'S ANSWER TO DEFENDANT STEVEN M. ZEIGLER'S NEW
MATTER
12. Admitted in part and Denied in part. Plaintiff denies that the interest was
illegally and erroneously charged. The interest was charged in accordance
with the terms of the Mortgage and Note. At no time did Plaintiff's
representative acknowledge an error regarding the calculation of the interest.
Plaintiff admits that there were negotiations with the Defendant regarding a
possible deferment agreement. The offer of the deferment agreement was
made as an accommodation to the Defendant to help the Defendant with the
monthly mortgage payments. The Defendant failed to execute and return the
deferment agreement. Without an executed deferment agreement, Plaintiff
could not authorize the deferment. (A true and correct copy of the Deferment
Agreement sent to the Defendant is attached hereto and marked as Exhibit
«A„
WHEREFORE, Plaintiff prays for judgment in its favor and against Defendant.
s P. Kennedy, Esquire
DATED: February 22, 2008
s
VERIFICATION
The undersigned hereby states that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge, information and belief. The
undersigned understands that the statements therein are made subject to the penalties of 18
Pa.C.S. Section 4404, relating to unworn falsification to authorities.
Exhibit "A"
RIN=ff AGREBWJVr
THl Ply Wi't' A 7 msssle spa at VAOM by ad b ` t vehe Ilse Look hr,
RoWdwy,wd dee??al?.zdldfer?t . rsomme)
mwbmmd" it it Tw&eRW [ mor h IV" *Wbat*
s Am
A, Yatoc aawsL?t, ib dae o*arc. #bal?rac i paot a mlc sad4wd cfvw /
k?10 7 e "d of "ftmod b Ai Bow
C c Soto wea agar d t Vetpe Ham ASS. ?stc, e+aewr i?pro tau a all I.tsa MU fcPrimesms
is ate, Ysirss t aam, bra t M1* Sonmw and dam gme fa t p q p,,"
Mdse ieta? p?dd tslt?Ii.
I, Cat 'lf?i wR?wRf a?OiCNID?'?pYFC??1as.
Ali f pv *** be ow v vs k4 Ram L*O W-Psi wMbodu mhUmm
cOmmooft MOW tirtlMe?[aqslllaflMO11Mk1M#;d1tM?Ci"4Mdet
wroft Won*" dealt 7544 i '1<w%t0( ? '! III ?Y1!?1?1i
? t!1iMra ? i?agigr lrilll? d kor ?1i rie+ll?t• ?>.
Sm+own id s snssatrr 11s?r ,'1[ssss?j itertbsrlt?,
"To"W !n "W a'1reAww"Ovoid and k Wftfw l p sa V" Dow Look y,e o"LwssE:p"w
Drtioytitrt 1'?Prrgr Tma ?? ya ? gaud t?;?4a?t+?+hpr pier #e? Wax' bask etMe daft eE1?SiF
Rr g"j4 %imm V&k c Hosea G>rw br- itsssst 6ar?omra ifa >3or ie'r l
dSWmsdartenowmod,dwAOMM/m, VW* tAllautboinfAimm=dd& t kioc*
wE ftftbwms? d=is<abe o= = kw o dw Bw =sb to *am ?$Mob
and bsikstrpt mw4 tf sdty. :t f* red ofth m woo(ft beet pyrat?mt cmdaft%MMOK
said* is p drah,vsiaaHamcLaekinc$*0 offifts*ft **Pao*$to #(my.
IsA 62 ft- t emq Of Ox e0r pq=M in [ M I& UWANY aaao40c BMW** % Ad bC in dcftk bea
1%w vsdne 4 OM* 1 ee>F, br- ee lpBsese otx oo+dm
x
Steven K 7&tgkT & Mmba J. U&r
--
Value Hvm I t t (PleM Print Name Aged Siga)
3Tcp?er?pr+C?n ?! ?ii?, t?18'1?T'
81&742-0010 t 224 Far 81 8444 346
bs des for ids ? ?, mlaoa? wb?ai? ' ?i wQroaaeat
" paiftVskeRomtoom.bC: bemp dtaa cm*wgtiw dom dnshAb%*m =detTo
andDad ofImI Mmop itpwp*m*ftdaaLEft soma ar mftdwaip ars
Hifr??ds?teadd4ett4+w7r?tb?ddciw ?A'???,
apa.?eea?rslt sffi? b a ssodt amet a?? asSaw a?tmat?e:mdp?sm .
hitespffat**ldmfta=drlpri o** effdo"kao=mat w brydie aftwows o(my I *I
vwtc 1to wadcno arks tpmd get ftD5tsmru ApOOMMsW w0t+e oftcdm udm exwoiw by *t
baa *oAm od V4m &= EvwA6 f=zpm
It is e?era? and wjrisod?uttibne k aasi a?3f ba sE?r at ? aac6 P?
!n tie erode b,? Bea mfr peasa9sgk? Eat w¢t?CaR.
A it arm* =&WMdmd spmod *9 ft ft zk==%V*&d*(O &kmmK dt Wro bo awwdt ko4w,
bLi Grams ? ?+4?t++id'tlrc fio?t? ? t8'mcd`ar?c.
Baaotrs?te+aaraortam?f a?ec dwout iin adslaerp dor p iFwe?iorw ? #ta?q ++i;l war be
Imp,
ar baptaoty ycaeaad,:wwd drwrpole 1edirr'aewc?aaf 6?rktler?A?neaw3er
bit retslwnd3wwdsxaawki elrmii wider drrmw at i6it asd aaxle a ?mdrs
? breseav obk?aian!?rsfatd a? wr aigps# tdw?h 1?oae?as. lla?#ae7maptramr? by
k?der tae ? ??w ?wEt E?e.,ppiod 1a]Da?t , #mrmw?ri?' ev?af' C? pm+ookw?e
?? ? ia? . ?.kaedrr adder a[ Imd?,a?in ist wore
9aux'?bc ?wbic ??* imna?t by s atioa?aaia gods d? m
oaewr d?;oQ dds pig.
x
Sty- K aier & mm-Ata.I. Z:ew,:,
x
Value HOMO_ tom evmftdve (Mcm Paint Name And Sign)
t ?ir?BFrd?1?1 tiAtpd f?'9i3?&7'
818-742-0010 e)d 224 Fmc 818444-4
>r
THE LAW OFFICES OF GREGORY JAVARDIAN
BY: JAMES P. KENNEDY
ATTORNEY I.D. # 86614
1310 INDUSTRIAL BOULEVARD
11T FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
VALUE HOME LOAN, INC.
Plaintiff
vs.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
Defendants
Attorney for Plaintiff
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
No.: 08-77 Civil Term
CERTIFICATE OF SERVICE
TO THE PROTHONOTARY:
I hereby certify that a copy of Plaintiff's Answer to Defendant's New Matter was
mailed to the following individuals by regular mail, first class United States mail, postage
prepaid on the date set forth below.
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
Attorney for Defendant, Steven M. Zeigler
Dated: February 22, 2008
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 0,an&
DAY OF p , 2008.
NOTARY PUBLI
com,-VwWTALTH or
NOTAIFI-WL
E! Novr-
es P. Kennedy, Esquire
f
,?.?
.,
" , ,
r°
s;-y ?
`? ? '? _? '1't
_ C?
,- ?
?? l
s: _: ? .? }
{:
.. ? ??-_
?;,:
C`? ',:?:
?_ C f"•
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
I ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
VALUE HOME LOAN, INC.
5959 TOPANGA CANYON
BOULEVARD, SUITE 4201
WOODLAND HILLS, CA 91367
VS.
STEVEN M. ZEIGLER
1059 A YORK ROAD
DILLSBURG, PA 17019
MARSHA J. ZEIGLER
405 FRONT STREET
BOILING SPRINGS, PA 17007
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-77 CIVIL TERM
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against MARSHA J. ZEIGLER,
Defendant, for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof
and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows:
*****DAMAGES TO BE ASSESSED AT A LATER DATE*****
I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown
above, and (2) that notice has been given in accordance with Rule 237.1, copy attached.
GRE R JAVARDIAN, ESQUIRE
Attor y f r Plaintiff
Damages are hereby assessed as indicated.
DATE: MA" 4j/ _
PRO. ROTHY
ti
' VALUE HOME LOAN, INC.
Plaintiff
V.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
TO:
Defendants
MARSHA J. ZEIGLER
405 FRONT STREET
BOILING SPRINGS, PA 17007
Cumberland County
In The Court of Common Pleas
No. 2008-77 Civil Term
DATE OF NOTICE: 2/19/2008
---------------
NOTICE, RULE 237.1
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 se
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. 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 179,131
(800) 990-9s?`' f ; f
(717) 249-316 /0-dn-,
Gregory Javardian, Esquire
1310 Industrial Boulevard
1 S` Floor, Suite 101
Southampton, PA 18966
(215) 942-9690
Attorney for Plaintiff
Usted se encuentra en estado de rebeldia por no haber tomado la accion requiida de su
parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de
esta notificacion, el tribunal podra, sin necesidad de compararecer usted en Corte o
escuchar prueba alguna, dictar sentencia en su contra, usted puede perder bienes y otros
derechos importantes. Debe llevar esta notificacion a un abogado immediatemente si
usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o
flame por telpfono a ]a oficina, cuya direccion se encuentra escrita abajo para averiguar
donde se puede conseguir assistencia legal.
"NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATI
OBTAINED WILL BE USED FOR THAT PURPOSE" ON
cc: Bradley L. Griffie, Esquire
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
VALUE HOME LOAN, INC.
vs.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-77 CIVIL TERM
VERIFICATION OF NON-MILITARY SERVICE
GREGORY JAVARDIAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) Defendants, MARSHA J. ZEIGLER, is not in the Military or Naval Service of the
United States or its Allies, or otherwise within the provisions of the Servicemembers' Civil Relief
Act of Congress of 1940, as amended.
(b) Defendant, MARSHA J. ZEIGLER, is over 18 years of age, and resides at 405
FRONT STREET, BOILING SPRINGS, PA 17007.
(c) Plaintiff, VALUE HOME LOAN, INC., is an institution conducing business
under the Laws of the Commonwealth of Pennsylvania with an address of 5959 TOPANGA
CANYON BOULEVARD, SUITE 4201, WOODLAND HILLS, CA 91367.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
GREGORY V RDIAN, ESQUIRE
w
? 11M
1?,
yy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
VALUE HOME LOAN, INC.
Plaintiff
vs.
STEVEN M. ZEIGLER and
MARSHA J. ZEIGLER
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 08-77 Civil Term
PLAINTIFF'S MOTION FOR SUMMARY
JUDGMENT
Filed on behalf of. Plaintiff,
VALUE HOME LOAN, INC.
Counsel for Record for this Party:
Gregory Javardian, Esquire
P.A.ID# 55669
1310 Industrial Boulevard
1St Floor, Suite 101
Southampton, PA 18966
(215) 942-9690
Counsel for the Defendant
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
t. %
THE LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ATTORNEY I.D. # 55669
1310 INDUSTRIAL BOULEVARD
,IT FLOOR, SUITE 101
SOUTHAMPTON, PA 18966 Attorney for Plaintiff
(215) 942-9690
VALUE HOME LOAN, INC.
Plaintiff
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
VS.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
Defendants
No.: 08-77 Civil Term
AFFIDAVIT IN SUPPORT OF PLAINTIFF'S
SUMMARY JUDGMENT MOTION AGAINST DEFENDANT
I, G us1AVo CARAVAN i es , of full age being duly sworn according to law,
depose and say that:
I. I am a LOAN M ANAGER at VAIUW Roo Le ko#YJ and have personal
knowledge of the facts set forth in this Affidavit.
2. The attached payment history is a true and correct copy of Defendants' payment
history.
3. On June 13, 2006, the Defendants entered into a Mortgage in favor of Plaintiff.
4. On the same date, the Defendants executed a Note in the principal amount of
$150,000.00, the indebtedness of which is secured by the Mortgage.
5. Said Mortgage is now in default as a result of Defendants' failure to make
payments pursuant to the terms of the Mortgage and Note and to thereafter cure said
default.
K
6. The Notice of Homeowners' Emergency Mortgage Assistance was mailed to the
Defendants on November 16, 2007.
7. As of December 18, 2007, in accordance with the filed Complaint, the following
amounts are owed on said Mortgage:
Principal Balance $129,433.21
Interest to 12/18/07 $ 7,285.54
Accum. Late Charges $ 901.67
Cost of Suit and Search $ 550.00
Attorney's Fees $ 1,000.00
TOTAL $139,170.42
8. The per diem rate is $41.31 for each day after December 19, 2007 that the debt
remains unpaid until the date of judgment plus costs of suit and attorney's fees.
9. Plaintiff has credited and applied all payments which were properly tendered by
the Defendant. Proper amortization of the principal and interest amounts have been
calculated.
10. All interest calculations have been correctly calculated from the date of the
default and all accumulated late charges and fees have been properly assessed.
11. Despite demand, the Defendant has failed to cure the debt as it is presently due
and owing.
(jL aw
Sworn to and Subscribed
Before me this 1+45 day
Of Ma(Gk , 2008
Francisco V Pena - sr-f Ai A&CD ?U?A?
Notary Public
CALIFORNIA JURAT WITH AFFIANT STATEMENT
Q See Attached Document (Notary to cross out lines 1-6 Below)
M See Statement Below (Lines 1-5 to be completed only by document signers, not Notary)
2
6
4
5
Signature of Document Signer No. 1 Signature of Document Signer No. 2
State of California Subscribed and Sworn to (or Affirmed) before me on this
I SS. day of M W r , Zoos By
County of ?OS AP?J{S
Cara yun4es
Name of Signer
Qx Proven to me on the basis of satisfactory evidence
FRANCISCAV. PENA to be the person who appeared before me (and
Commission # 1601151
r'6Xtx
@MY Notary Public - CallfomlaLoa Angeles County 2Comm. Expires Aug15,2 Name of Signer
Qx Proven to me on the basis of satisfactory evidence
to be the person who appeared before me.
-?? V, ?4 *IU0D lS? t(s loll
Notary Stamp Signature of Notary Public License Number Expires
OPTIONAL
Though the information below is not required by law, it may prove valuable to persons relying on
the document and could prevent fraudulent removal and reattachment of this form to another document.
Description of Attached Document
Affidavit in support of
Title our Type of Document: pj@intifrs summaiv judgment
motion aeainst defendant
Document Date: 03/07/08
Number of Pages 3 pages
Right Thumb Print Right Thumb Print
of Signer 1 of Signer 2
Signer(s) Other Than Named Above:
1
L
rr
1
a
¦
!
1
!
O 80 0 0. 0 O 'o 0 0 0 0 0 0 0 0 0 0 0 '0 O O o 1 1 o 0 0 0 0 00 0'0.0
Co. co CD ' OD V' V- V CA O O M 0 (AW' co N' N ` ` i N N ` i ` 0 (D CO : OD OD V V ` V W W
{ N O }U N O N N N N N O O N O N W N O !? O N O O N N N N O N N N N N N N N N N N ,7
CO W fD - CT N (D co ` O co A N W N C\O OO (\O C\T Z' ` co \A. . A (D : O) co \ (D W N CD N CO A A -+ Co. N ,.
0
N N N N N N N- N N N N N N N N N. N N N N N. N N N N N N N N N N
N N. N N N! N N N
0 0 0 0 0 0 O; O O O O O 0 0 0 0 0: 0 O. O 0 0: 0 O: O O O O O O O 0 0 0 O 0 0 O: 0 < Cp
O O O o O! O 0 0 O O O O O O. 0 0:0 O O O 0 0 0 O! O O! O O O O 0 0 0 0 0:0: O O O (D
V V V; V V V -4,-4 V V V V V V V V V! V V V V V V a) - 0 O: CD) (3) a) CA 0) 0 W W CD) O 0 (7) ',. O d
-' i O O O O 0 0 0 0 0 0 0 0 0'0
O: O O O O O O
O OO (D V CD : OD ` O) V W (\ (z (A A A W W N N\ \ i N N . r 0 0 0 0 0 0 OO O O
OO CD CA OD: V V V V O O)
O N N O N N : N N N N O N N N . N N N N- N N O (D N N
O. 0 N N N N N N N N N N
N N- N N: N
(D W to N N :. CO (D ' N- O (D N N CO N Cp N (D N V N (D A A co . N CD N N- (\D co N O N C`D A A3 N N N N N N N- N. N N N N N N N: N N N N N N N- N N N N N N N N N. N N N N - N i23 ; N (p
010 O O O: O O. 0 0 O O O O O O O O O O! O O O, O O O O O O O O 0 0 O. 0 O 0 0 O O N
O O 0 0 O Co OO 0 0 O O O OHO Oi_O V O O 00 ?,8-? ?: ?;? 81
00 ^,0
--W ! W D .. W (n W W .V ?j
i .... p i -p p ?i D' O CNO CND- N N D N C. ..
0 O w
:A O C CA co co co -w c" C." T : O OD co !OOAD cn O - N.
CAA CD
:
m
3 3 a N 7 7 a4 7 c LU 3 7 7 7 (D 7(D (D 7 7 (D 7 (D 7 .f Qtp
9: 9 co co to (Aa 9 (a (a -7 a) (a
(a ca =r co (a fm Cc (C) co co (a (D AD cc co to co (D
,cc (a cc
69 69 w :4A fA - _ 69 EA (A: 69 fA
i i i i
N N. Cj co N N W ! W N W N N N D
69 ; 69 69 W 69 . 69 EA W 69 69 EA 69 0:69 ' A 69 : OD 69 CD 69 69 69 69 A 60, . O A. 69 69 A 69 L" - 69 69 69 O 6w : 69 <
. O O CD O O O CD O O W O 0 0 0 V O: O O: co 0 P. P O: O O O A O O O O (T P :P O. O O- o m
O; O O W 0:0 O W O O N O O V O A O N) 0 A 0 0 0 0 N 0 OD 0 0 0 0 0 -4,0 O O; - O C
O
O O O N O: O O N O O N O O (O O N O ".0 . OD O O_ O O: OD O CD V 0 0 0 0 0 Cl 0 O! O 0 1 0
! 69 619 69 4A 69 : 69 : 69
69 '., 'p
i i .71
N 0 N A .71 '71
69 69 69 . W 69 69 0 W ! EA b9 (fl
CNCpp EA (N}? 63 ? b9 ' OD 69 co 60 fA EA 69 A 69 O 69.69 A - EA (n ' 40 : 69 EA T FA 69 N G.
O;O O (O OHO O 0.0 O A O O A O-N O'cn O m 0 0 0 0.O) O'D) A O O 0" 0 CT O.0 0 w O O
O O O W O: O O W O O W O O 6 O: N O N O: A O O O O N O OD CD 0 0 0 O V 0:0:0 : -'0 . O O
O: O 0! N O; O O N: 0 O UC O O O 0 0 0 O (D 0 0 00. 0 0
O O O(D O C0 000 O (b V 69 D
EA - EA ! N 'O
O
49 O U). O '40
6969 p .? .? ?.
69 69, 6w 64 4A 69 69 69. EA 69 di 69 i 69 w 69 69 fA EA EA EA 0 69, 0 69 0 EA 69 69 O EA O 69;69 0 69 fA 0 ? a
O O O: O 0 0 0 0 (D 0 0 0 O N O CJi 0 0 0 0 0 0' 0 O: O 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 m
0 0 0 0 0 O O O W O O O O? O N 0: 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 '. O O! 0 O 0 - O
0:0 O -: o 0 0 O O V 0 0 0 O O --• O O 0! O 0 0 0 0: 0 O O O 0 0 0 0 O O O 0:0 O O
r
D
m (s
69 -O
69 69 69 69 69 EA 69 69 N 69 69 69 69 EA (A 63 6w 69 A -6W 69 (A 6i 6w w 67 69 fA 69 69 4A -fA 69 (A 6) 69 63 4A 69 w 0.
O 0'0 0 0 0 o O'cD 0 0 0 0 0.0 0 0 0 0 o O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 04
00 °o g °O o o° o' o° 000 O° 00 °O °o 00 °o °O 00 °o °0 00 00 00 00 00 °O °o °O °O O° ! 00 0° 0 ° 00 O° °O oo o U)
°
EA
v
69 4.9:40 69 69 (A 69 69 69 69 69 69 69 69 4A 69 69.69 EA 69 69 0 69 69 69 69 EA w W 69 69 . 69 69 69 0 69 69 rA 69 .Cy.. a
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0' 0 0 0 0 0 0 0 0 0 .0 0 0 0 0 0 0 0 0 0 0 0 0 0; 0
0 :o 0 0 0 0 0 0;0 0 0 0 0 0 00 *0 0 00 0 0 0 0 0 0 00 00 0 0 0 0 0 0 0 0 0 0
0! O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 p; 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0
0
O
O
69 69 Q N
69 69 69 69 69 69 69 69 69 ?i 69 69 EA 69.69 6969 69 69 69, 0 EA 69.69 69 4A 4A 69 EA 69 fA 69 69 O 69-b9 69 69
Co O O O 0 0 0 0 0( 0 O O O 0:0 0 O O' o 0 0 0 0 0 0 O' O O O O O 0: 5 O: 0 0. 0 p) N
0 0 0 0 0 0 0 0 0 W O 0 0 0. : 0 O O 0 0: 0 O -: 666:6;600000000 O! O OI O
O O O O 0.0 0.0 O V O O O O 0 O O O O O O_ 0,0:00000000000 O O O O
s?
N N
69 69 69 69 EA 69 69 EA 69 69 69 69 69 69 69 69 69 69 69 69 69 69: 69 EA 69 69 69 EA 69 69 69 69 69 69 69 69 69 69.69 f?D
O: O O O o 0 O O. 0 O O O O O O: O 0'0 O O: O O O O O O O O O O O O O O. 0 O! O O O .N« y
0 0 0 0 0! 0 0 0. 0 O O O O O O. 0 O 0.0 0! 0 O O 0 0 0 0 0. 0: 0 O 0 0 0 0 O! O
O O O 0.0 . 0 0 0 O O O O O O O O O 0:0,0:0 O. 0 0 0 0 0 0 0 0 0: 0 0 0 0 O O OO 0O
69 69 69 69 69 69 69 69 4A 69 69 69 69 4 4 EA 619 CA 69 69 69 Zq 4A 69 EA 6A ' - S C
N ! La K) W N N ' 69 W N N IV N - K) N ' K) ? --+ : N IV fJ IV ' IV N N K) N - -? (D ?"
V 69 : W E9 O rn W: co O ((pp 69 0) ((?jf1 o i Lrl (O 008 ! 69 0 A A O A A A to C7i EA EA rl) 110
69 N d
0. M.
OD : O V - CO O ()1 W w V (97 A O O A A - N ? ? U) N OD Ln O O OD W Q) (r ? O O : OD OD O M
OD:O A W O -? W W!OD V W O V (T W'N 0_N j A-N O:O A'.N N-(AI O-CD CA 0.0 V V !O 0 -+ -+:O
CT O M N O O OD N_ N O VI O O OD Ul OD -? O O OD ! OD Ww' V: OD V O' O CO (O : O O I O O i 0
r
m
69 69 - EA - D (D
i i a
69 . W 69 4A N 69 ' 69 69 : 69 69 69 N 69 69 69 4A 40 69 EA 4A 69 69 ' 69 69 : 69 4A 69 ' 4A b9 69 69 69 69 69 EA 69 69 69 17 a(p
O! O O 0 0) O: O O O 0 0 (O 0 0 0: 0 O O 0 0. O 0 0 0: 0 0 0 O O 0 0 0 0 0 0 0 0. 0! 0 G. m
O (T O O W 0 0 0 Cl 0 O A 0 0 0! 0 O O O O O O: O O O O O O! O 0 0 0 0 0 0 O O O O O
O: O O A O O O O O o A 0 0 0 O O O O O o 0 O 0:0 O. O O O o 0 0 0 0 1 0 0: 0. 0: 0 (D
r
W
O, O O (T 0 00 (T - O O w 0 Co 0 0 (A 0 -+ O 0 . 0 O 'o 0 4 0 0 0 0 0 0 0 0 0 0 O ?+ 0 O O M
1
L
r
rr
i
1
1
1
1
i
c
J
t
x ?
0
N 0
N 0 : 0
' i O i
N .
' N i -:
i
N
OD .O
N N
CO '.O
A O
N N
CO O
W N'
CO
N N N N N N N N ':.
O
O O
O O
O : O
O O
O O
O ! O
! O O:
O
CA O O :Lb O V V V
O ' O O ': O O i i l
N ON -+ !OD .-+ I N N I\i
N
CA ; O
I N N
Co N
: N O
N N
co O
W N
CO '
N
O
N
O
N
O N
O N
O N
O . N
0 N
O
0
O 0
O 0
O 0
'V 0
W O
V O
V O
V;
W
CO
- W
7 ? 3 'd j' -N j ;
O `y
N CD
O N N
O CL
V
N g ?
N N
O
O
1
CD
CD
0
N
u
7
CD ?
0
co fA E9 H? W 69 69 69 69 69 z
0 0 0 O W :: O O 0 .0 O CD
0 0 o w :o 0 ;0 0 o a c
rn O o O OD 0 0 :0 .0 0
fA fA
i
W 69 69 69 CA . 69 fA : 69 69 69 CD
W .0 0 0 C O 0 :0 0 0 10 M
0 0 0 W 0 O -:0 O -.O O
V O O O W 'O 0 -. 0 0 . 0
? D
5-'
a
W 69 69 fA 69 W9 69 69 fA -: 6' % C1
W 0 0 0 0 0 0 : 0 O O (V .q
jv O O O O : O 0 :0 O O O
i O O O O : O O ; O O '.O
r
w D
(D a
m
t j 69 fA fA 69 40 69 to fA W Ol d
O O O O O . 0 ,
0 1 0 0 0
A O '.
O O S O S -i O o
0
O 0 O
, . : 0)
D
v
NO fA 69 fA 69 -69 fA ! 69, fA 69 C_
Cy
0 0 0 0 0 0 0; 0 0 ;0 .
..
0 0 0 0 0 0 0 0 0 ,0 0
0 0 0 o o :o 0 01 0 O
s
fA
fA
fA
fA
fA
fA
fA
69
! fA
'a O
0 0 0 0 0 0 0 0 0 o m y
L' 0 0 0 0 0 0 0 0 0
o 0 0 0 ;0 0 0 0 0
s?
49 fA fA fA fA 69 69 69 69 69 N
O 0 0 0 0! 0 O :
O 0: 0
y
O O: 0 0 0 1 0 O! 0 O O
0 0 0 0 0 0 O. 0. 01
O
0
EA
co - zq G69 '.,. 3
S' W '
W 69
O W
la ' 0)
W ?p
O ? G9 W '
' ?A CD Ol
?
O . : OH O Ch
: O + a.
.
W: O O; W O A': C c"
_A OD O N ' CA O to O V- 0
r
m
f±
0 N fi fA 9
0
a
o
A
O
O
O
O
O .
r
i,
.c 90 L d
m O- A O oi 0 0 SI OWD CD
r
d
CA)
_
ID N
O O O (" O O O O: O
Exhibit "C"
a .10/31/2007 14:34 8184441912 LOAN SERVICING PAGE 06/ 13
Recerding Requested By &When Recorded
1Vta47'f'o
Value Borne Loan, Inc.
5959 Topanga Canyon Blvd. #201
Woodland Hills, CA 91367
F?
AND T:F-jft.?7
Lon No. 51 a" Space above this fine for rmnrdar's use
Trc1c Order No.
LONG FORM DEED OF TRUS'T' AND ASSIGNMENT OF RENTS FOR
ROME EQUI'P' REVOLVING LINE OF CREDIT
THIS DEED OF TRUST, made this 13th day of June, 2006, betwtea Steven M. Zeigler & Marsha J. Zeigler, ber in called
TRUSTOR, whom
address is 5959 Topangs Cil yon Blvd., Suite $201, Woodland Hills, CA 91367
COUNTY RECORDS RESEARCH, a California corporation, b=in called TRUSTEE and VALUE HOME LOAN, INC, a
California corporation, CFL # 6038218 whose address is 5959 Topanga Canyon Blvd #201 Woodland Hills, CA 91367, herein
called BENEFICIARY.
. Witneneth, That TRUSTOR IRREVOCABLY GRANTS, TRANSFERS AND ASSIG118 to TRUSTEE IN TRUST, WITH
POWER OF SALE that property in Caotberland Caurty, Peimsylvanis deann'bed as (the "Property).
TOGETHER WITH the t+en , issues and profits thereof; SUBJECT HOWEVER., to the right, power and authority given to and
conferred upon Beneficiary in Paragraph 10 below to collect and apply such rents, issues and profits.
FOR TM PURPOSE OF SECURING:
(A) Performance of each agretanetrt of Ttustor commuted in this Deed of Trust.
(3) Paymentof the indebtedtsess evidenced by a Monte Equity Ctedit Line Revolving Loan Agr wnt (hereinafter
referred to as "AGREEMENTT") of Mn date hacmth in the initial principal amount of $150,000.00, but subject to increase to a
maximrmt of 5150,000.00, executed by Trustor in favor of Beneficiary or order, and any extension or renewal thereof The
AGREEMENT is a revolving: lime of credit enabling the Ttustor to redrew sums previously repaid, to be secured lrareby, pursuant to
the tcrtus of the AGREEMENT and this Deed of Tuvst.
STATEMENT OF OBLIGATION: Beneficiary tray coiled the than ma &=n fee provided by Section 2943 of the California Civil Code
for finnishing a stat+cammt of obligation.
TRANSFER- I(Trustor vohutttsrily sells or conveys the above-deserIed Property, fully or partially, or any interest in it or, by sore ad or
means divest themselves of title to the Property waout obtaining the written consent of Beneficiary, Trustor shall be in dclhult avid
Beneficiary may, at its option, declare the entire unpaid balance of the loan and aaxued but napaid interest kmwdiately due and payable.
TO PROTECT THE SECi1RITX OF THIS REED OF TRUST, TRUSTOR MAO AGUES:
(1) To kep the Property in good condition and repair; not to raoovu: or daootidt any building themort; to complete or testote promptly in good
and worlananlt7re manner any building which may be constructed, damaged or destroyed thereon and to pay when due all rkims for labor perfortned and
umeriak furnished therefor, to comply with Al laws affecting said Property or requiring any alteration or inrprovernent to be made Ow"n; not to oomt *
or permit waste thmma; not to commit, A f r cr permit any ad upon said Property in vialadoo of law; to cultivate, irrigate, fertilize, fumigate, prune and
do all other acts which from the charneter or use of said Propety troy be reasonably necessary, the specific enrotxxation herein not excluding the general.
(2) To provide, maintain and deliver w Beneficiary fire ineurartoc sa ffsfaetory to it and with loss payable to Beneficiary. The amount wileded
under any first or other insrrwoc policy may be applied by Beneficiary upon iodcbtedoess secured hereby and in such order as Beneficiary may
determine, or at option of HOMBciaty, the attire amount so colkotal or any part thereof rmy be nicased to Trustor. Such application or release shall not
cute or waive any default or notice of defauk hereunder or invalidate arty act done pumt of to such notice.
(3) To appear in sad defend any action or proceeding purporting b alter the Security hereof or 9:c rights or powers of Beneficiary or Twstee;
and to pay all costs and expenses, imbiling costs of evidence of title and attorneys fns in a reasonable sum in any such action or proceeding in which
Ben4ciary or Trustee tray appear, and in any ant brought by Beneficiary to enforce this Deed of Tmst
ta1a7rr1U71Zelnhgrl -
20•MmDWofttMSiPx9t Pape Ia
Z
_1-0131/2007 14:34 B184441912 LOAN SERVICING PAGE 07/ 13
• (4) To pay at least ten days befog de inquenry alt taxes and suessruen is affecting said Property, including assessments on eppurxnant watch
..stock, -*= due, A cneaarubranexs, charges and liens, with interest, on said Property or arty part thereof, which appm to be
vjd all ? teesandexpenses of this Trust Should Trustor fail to make or to do Fvv prior a to w superior haters;
_bat wihhoud obll any ?? any ? as hatcher provrdcd, then Beneficiary fi $ciary or Trrutee,
gallon so to do tend without mediae to or dernand upon Ttustor and without rdeni ft Tbistor from any obligation hmvK may make or do
du-- same in such manner and to such extent as either may dada necessary to protect the sewrity hereof; Benet`'iciary or Thaw being authorized to enter
upon said Property for such purpose, appear in and dtfmd any action or proceeding purport to affect the security heroof or the rights of powers of
Bemeficay or Truster. pay, purchase, eondest or comwornise any eaambramce, chargje or lien which in the judgment of either to be pro
supenorhereto, and in exemsi such appears or
ng any power, pay necessary exparsrs, etutploy coeanset and pay his reasonable fees.
(5) To pay invae s0ely and without demand all suite so egreodod by Beneficiary or Trustee, with fitrarce charges fivrt date of expenditure at
the applicable Annual Peroeaatage Rate in the AGREMWENT, and to pay for any statcrncrrt provided by laws in efket st the date hereof regarding the
obligation secured hereby arty atnoi t demanded by Sermficiary not to exceed the nmxiritturu allowed by law at the time wben said statwnent is demanded _
(t7 71%9 soy award of datmages in connection with any condesrnaaiom fot public use of or injwy to said property or any part thereof is hereby
aseaigned and shall be paid to Seznefictary who my apply or rd=w such moneys received by him in the same manner and with the same effect a5 above
provided far disposition ofproceeds of fire or other insurance,
(7) That by accepting payrtuant of any sum seemed hereby after its due date, Beneficiary does not waive his right either to require prompt
paymmt who due of all other swag so secuued or to declare default for fulum so to pay.
(8) That any t:m and from time to tune, without liability there for and without notice, Won written request of Ecneficiary and presentation of
Ibis Deed of 1tust and said AOMEMENT for Widorsernent, and wldtout affecting the personal liability of my person for paymmt of the indebtednem
scoured bereby, Trustee any recomvey any per of said Property; consent to the makog of my map or plat thetwt join in granting any casernent tbercon
or join in any Wansion agm ernoht or any agree ndtt subordinating the lien or chatgo hereof
(9) That upon written request of Elmcficiatry staging that all suns wcirned hereby have been paid, aced upon surrender of this Deed of Trust and
said AOREEMENT to Trustee for cancellation and retention and report payment of its fees, Thustce shall reeonvey, without warranty, the Properly then
held haunder. The recitals in such rooonvemnee of any matters of fact shall be oondwive proof of the ttuthfuhess tltcreo£ The grantee in such
reeonvoymor tray be described as, "the pcrsotr or persons legally entitled tlucrt:to.` Five years after tuna ahac of such full toomveyance, Trustee may
destroy said AGR T and the Deed of Trust unless directed in larch request to retain theta.
(10) That as additional sccwity, Trawor be eby gives to and confers upon Beneficiary the right, power and suthemty, doting the continuance of
these Trusts, to collect the tents, issues ad profits of said Property, reserving unto Trustor the right, prior to any default by Tntctor in payment of any
in4cbtaincss secured hereby or in ice of any agteernent hereunder, to collect and retain such rents, issues and profits as they become due and
payable. Upon any such default, Beneficiary may at any tune without native, either in presort or by agcaht, or by a receiver to be appointed by a sour, and
without regard to the adequacy of any security for the indebtedness hereby secmcd, enter upon and take possession of said Property or any part hetc4 ire
his own mmne sue for or otherwise collect such trots, issues and proft fneluding those past due and unpaid, and apply the am, less costs and cxpams
of operation and coliccdon, including attaraWs: foes upon any fadeb6tdam secured hereby, and in such order as Betcticiary may dextri sne. The
entering upon and tatldng possession of said Property, the collection of such rents, issues and ptoftts and the application thereof as sibressid shall not cure
or waive anydcfauit or notice of defmdt hatundcr or invalidate arty acxdone pw's amt to such moticc.
(11) That upon default by Ttustor under the AGREWWT, Beneficiary may declare all suttns secured hereby immediately due and payable by
delivering to Trustee a writhm declaration of default and dernsad for sale acrd a writte t notice of default and election to ewe to be sold said Property,
which notice Theme shall cause to be filed for record. Beneficiary also shall deposit with Trustee this Deed of Trust, the AGREE1vi fr and all
doarrments evidencing expenditures second herein. After the law of such time as may their be requited by law following recordation of said notice of
default, and aotiae of site having been given as then required by law, TWswe, without demturd upon Trustor, shall self. the Property at the tints and place
fired by or in said notice of sak, either as a whole or in separate pxtei% and in such order as it may deterritine, at public auction to the highest bidder for
cash in lawful money of the United States, payable at tune of Sala T'tustce may postpone sale of all or any portion of said Propctty by public
announoaltcut at the citric fixed by the prrxteding poetpanemxnt. Trustor shall ddiva to such purchaser its decd conveying the Property, but without
covenwit or warranty, express or implied- The recitals in such deed of any ntattera of Abet shat! be conclusive proof of the truthfulness thereof. Any
person, including Uustor, Truster, or Beneficiary, as hereinaftcr defined, tnay purchase at such sek After deducting ail costs, fees and expenmua of
Tfustor and of this Trust, including costs of evidence of title in connection with sale, Trusnx shall apply the proceeds of sate to payment of all sums
expanded ender the terms hereof; not then repaid, with accrued finance charges at the applicable Annual Percentage Rate in the AGRBEwxr. all ctber
sums then sexaacd thereby. and the reminder, if arty, to the patron or persons legally entitled thereto.
(12) Beneficiary cx any successor in ownership of any indebtedness seared hereby, may from fire to time, in an instnuttent m writing,
substitute a successor or arceeseprs to any Thusft awned herein or acting hexeemder, which instrumernrs executed by Beneficiary and duly acknowledged
and recorded in the office of the recorder of the county or counties where said Propetty is situated, shall be conclusive proof of proper substitution of such
successor Trustee or Trustees, who shall, without conveyance from the Truett prederessot, succeed to all its title, estate, rights, powers and duties. Such
ins unwit mist contain the narne of the original Trustor, Trustee aid Bareficiary hereunder, the book and page when this Deed of Tout is recorded end
the narne and address of the new This=.
(13) That this Deed of. Trust applies to, inures to the benefit of and binds all parties hereto, their halts, legatees, devisees, administrators,
CUU1110rg auaxxsorz and assigns. The term Beneficiary means the owner and holder, including pledgees, of the AGREEMENT secured hereby, whether
or not named as Beneficiary herein. In this Decd of Toast, whenever the context so requires, the masculine gender includes the feminine and or neuter,
and the singular number includes the phial.
(14) That Trustee accepts this Trust when this Decd of Trust, duly executed and acknowledged, is made a public record as providW by law.
Trustee (s trot obligated to notify any party hereof of a pending sale under any etcher dead of trust or of arey action or proceeding in which Trustor,
Beneficiary or Tmatec shall be a patty unless brought by Trustee.
(15) If this Decd of Trost is smtred by oondotttiniutn, conminity apart nen4 stock cooperative Icasebotd or planned unit development, Trustor
agrees to comply with all recorded declaration of coveaarrta, conditions and mstfitbons, association bylaws, and association rules and regulations, and,
upon w4ttcn request fiom 13mefic iaty , to enforce the same as against other owners in such developmcats.
(lfi If the Deed of Trust is secured by a lease, Trustor agrees not to &I d, chants modify or waive his or her interest therein, or agree to do
so or to breach the lease without the written vm=t of Beneficiary. If this tovetant is breached and the security for this Deed of Trust is materially and
tslarntarr n zep?&-
to.twoeDrWdtrustalnxIi Page 2of3 ?V
.10/3142007 14:34 8184441912 LOAN SERVICING PAGE 08/13
adver.* , BeneGeisry d mil have the option to dcchm all wns owed under the AGRMWEN and this Decd of Trust, invnediekly due and
pay ble in full.
-TRUMM RWU]ES'['S THAT A COPY OF ANY ROME OF DEFAULT AND OF ANY NOTICE OR SALE BE MAIL19D TD TRUSTOR
AT TRUSTOR'SADDRM SET FORTH ON THE FRONT OF TM DEED OF TRUST.
IN ACCORDANCE WrM S13CCION 2924b OF THE CALWORMA CM CODE, REQUEST IS HEREBY MADE BY THE TRIISTO THAT A
COPY OF ANY N011CB OF DEFAULT AND A COPY OF ANY. NOTICE OF SALE UNDER DEED OF TRUST RBCORDED ON
is Book . Page Official Records of County (or RW for rocord with
Recordees Serial Number ofsatot: County), Califomia affe=g the Property deserved on the front of this instrument
exca and by as Trooor in which is named as Beneficiary,
and as Trustee, be nmikd to County Records Research at 4952 Wamer Ave, i105. Huntington Beach,
CA 92649_
SIGNATURES OF TRUMR(S):
61( -r(v 6
80"Wer Stow ,w ZOV Dale
Stateof..C uia_nnec{(0A0;Cc_ )
) ss.
County Of h l; k,,bcP 1o-,,A )
On
(? D J
. Be-et-,6
a notary public, personally
personally known to rna (or proved Va me on the basis of satisf toty evi&we) to be the person(s) whose name(s) is/are subscribed to
the within inskment and acimawledged to me that Wshe/they execabed the same in his/herMx*, authorized capacity(ies), and that by
IxWhert&= signabure;(s) on the instrument the person(s), or the entity upon behalf of the person(s) aettxl, executed the inst ntopttt
WITNESS my hand and official seal. MY Cb,urt; ss i t k, (f )(P ? tear ' /'0/11/0 p
.j,
s
Motr WITH t F PENN$YLVANiA
Pl&AM Seel
Linda ?6t &mz^ Ndw Putt
nd
Ffa Cwtols cam
Mytbrraris wf*MOtt.21,2009
Umber, Pomw,+mnta Assomflon at Natetms
\S'/
151 MA18771 MOmri
20-HdocDead &UPIataxtl Pa"2912
Exhibit "D"
.10/31/2007 14:34 8164441912 LOAN SERVICING PACE 10/13
ROME EQUrff CREI)?Fr LINE REVOLVING LOAN AGREEMENT
Jun 13, 2006. This is an agreement containing the berms and disclosures which apply to your home equity line of credit
account ("Account") with Value Home Loan lnr? whose address is 5959 Topanga Canyon Blvd., suite #201 Woodland Hills CA
91367., a California corporation, CFL # 603$218. The words "we" or "ties" refer to the lender narned in the previous sentence. The
wcstds "you" or "your" mean the person or persons who use or authorize the use of the Account jointly and severally.
1. Now You May Use Your Account. Turing the fmt 36 months of the Account ('Draw Period"), you can borrow money ("Cash
I-020e ) from your Account by malting a written request to us up to your nmim m credit limit. After the Draw Period you will not be
permitted to borrow money but must repay your Account m full over a 180 month period (`Repayment period, 1. Your Account is a
rcvdving line of credit. YOU cannot request money in excess of the available credit (the difference between your Outstanding balance
and your maximum credit limit) on your Account. You may not request less than $1,000.00 at any one time- Requests for money must
be in writing sent to us at art address we will give you. We will respond to it widen 5 business days after receipt of your request. For
the first 30 days after your Account is open, you will not be pcnniteed to draw more than 90% of your initial credit l
` mail, nor draw
moze than $5,000.00 in any 30 day period. You cannot make more than one draw request per 30 day period
2. Maximum Credit Limit. Your initial credit limit is $150,000.00, of which your first Cash Loan shall be 5120,000.00. You agree
that we can change your credit limit at any time at our sole discretion but it shall never exceed $150,000.00. You also agree that we
are not obligated to extend further credit to you for any amount that would make your outstanding balance exceed your initial credit
lin dt, or for any amount if your outstanding balance is already over the initial credit limit. We may disburse funds from your ava ilable
credit and assess the cash advance fee to cure any default related to your property. Any increases in your initial credit limit you request
will require that you makr a written app-.cation for our approval. You will pay arty amounts that exceed your maximum credit limit
upon demand. We may re-evaluate your financial condition if you request a higher credit limit, or at any other tine, and this may
include obtaining a current credit bureau report, and/or asking you for current financial information. We may suspend your tight to
obtain additional Cash Loans when: (i) the value of your property has declined more than 2096 fivni the appraised value at the time the
Account was opened, (ii) we reasonably believe that you will be unable to fulfill your repayment obligations under this Agreement
because of a material adverse change in your financial circumttancea, (iii) you file a bankruptcy petition, (iv) one of the Account
holders requests such suspension or (v) governmental or court action. If you believe that one of the conditions is no longer present, we
will reinstate your ability to obtain Cash Loans if you so request in writing and we confirm that the condition is no longer presem
3. Monthly Statement. If you have an o msauding debit or credit New Balance of $1.00 or more, or if there is any finance charge
imposed during s billing cycle, we will send you a statcmem 20 days prior to the payment due date. You agree to pay us for all Casks
Loam, fees and charges, if any, and Finance Charges on your Account, all payable in United States Dollars according to the terms and
conditions of this Agreement no later that. the payment due date. The payment due date will be the same date each month which is
thirty days after the original funding date of your loan.
4. Finance Cirarge on Your Account Balance. We will detetmine and impose a FINANCE CHARGE by applying a daily periodic
rate of 0.63192% to the daily unpaid principal balance for the number of days that balance remains unpaid in the billing cycle. The
daily periodic rate is the ANNUAL. PERCENTAGE EATS of 11,49% divided by 360. The Annual Percentage Rate is subject to
change as explained in section 5 below. To get the daily unpaid principal balance, we will take the beginning balance each day, add
any new debits or Cash Loans and subtract any payments or credits- The Annual Percentage Rate does not include costs described in
this Agreement other than interest A portion of the Finance Charge will be figured by applying a cash advance fee (a transaction fee)
of 12,0% of each Cash Loan to each cash loan after the first Cash Loan, on the date the new Cash Loan is posted to your Account.
Finance charges accrue on a new Cash Advance and the related cash advance fee as soon as the Cash Advance is made. Amounts we
must pay to protect the security of our Decd of Trust will earn finance charges at the Annual Percentage Rate applicable during default
as soon as we make the advance.
5. Changes in the Annual Percentage Rate. The Annual Percentage Rate on your Account may change based upon cbwges in the
value of an Index. During the Draw and Repayment Periods, the Index is the Wall Strut Jourual Prime Rate. If the Index is no longer
available, we will choose a new Index diet is based upon comparable information and will give you notice of this choice- Your Annual
Percentage Ante may only change once per year, on June 1". The first adjustment will not occur until the third year of the loan. To the
Index value as of the first business day in the preceding May, we will add a margin of 4.3%- The sum of the Index value and the
margin will be your new Annual Percemge Rare, subject to the limits described in the remainder of this section. You will pay
periodic Finance Charge at the new rate starting with the following July I`r payment. 'Me maximum Annual Percentage Rate that can
apply during the Draw and Repayment Periods will be 10.0% percentage poiuitg over the initial Annual Percentage Rate. The
nuninum Areal Percentage Rate that can apply during the Draw and Repayment Periods is the initial Annual Percentage Rate. There
are no other limits on how much the Annual Percentage Rate can change at any one annual adjustrnent-
AWcA 8-oms Soflwsre. w- WM 833.330 1518M M771 UVrerj
t9-H.90Ckale PW t d4r0
..10/31/2007 14:34 8164441912 LOAN SERVICING PAGE 11/13
- 6. Agnimuln Payment. You agree to pay either the entire outstanding balance ('Tlew Balance") indicated on your mot# tly statcn)mxt
or in monthly payments. During the Draw Period, the nu Gnu m monthly payment (Minimum Payment Due") you must pay will be
equal to just the interest at the then applicable Annual Percentage Irate that accrued during the billing cycle, without any provision for
reduction of the unpaid principal balance. You can always pay more if you wish. During the Repayment Period and continuing until
you have paid the unpaid principal balance in full, your Minimum Payment Due will be fined at each adjustment of the Annual
Facentage Rate at am amount sufficient to fully May what yon owe in equal monthly installments by the end of the ISO month
Repayment Period. Each July 1°` during the Draw and Repayment Periods, changes in the Annual Percentage hate will result in
changes to the amount of your Minimum Payment Due. If you default and we must advance other sums to protect the security of our
Deed of Trust, you agree to pay these amounts in hill together with the next regularly scheduled Mirtimmum Payment Due.
7_ Fees.
(a) gate Payment Fee: Your Min nmm Payment Due will be past due if it is not received by us on or before the Payment Due
Date shown on each monthly statement. A late charge of 10.0% of the payrnent with a miinrmurn of $25.00 will be charged to your
Account, if at ).east the Minimum Payment Due, including unpaid payments, is not received by us within lA days after the Payment Due
Date.
(b) Fee for Documents: If you request a copy of a statement, Cash Loan request or other doetunent not in connection with a
billing error, we will charge your Account the smn of $15.00 for each copy.
(c) Annual or Initial Fees. You agree to pay, by a debit to your Account, the following initial, non-refundable fees to set up
this Account
RMqdLd-=- AMU-at
Title Insurance $395.00 (estimated)
Recording Fee $45.00 (mdrrmted)
Appraisal Fee $200.00 POC
Amoatut
DaiMtw-n
Escrow Fees $395.00 (estimated)
Loan The 12.00/a of initial advance
Other: Loan Setup 5795.00
You agree to pay the exact amount of any initial fee that is estimated. Thew are no annual fees on this Account, but you will pay a
cash advance fee for new Cash Loans.
(d) Refurncd Payment Check Fee: If you make payment by check and a check is returned unpaid for any reason, your A= =
will be charged S2S.00 for each retained check
3. Draw and Repayment Periods. During the Draw Period, you may add Cash Loans to your Account for up to 36 months so long
as you own your property and you am not in default. ThereatieT, during the Repayment Period, you must pay at least the Mitrirnuum
Payment until the Unpaid Balance is paid in full. On written notice to you we can extend your Draw Period or your Repayment Period,
but we are not obligated to do so.
9. Application of Payment. We will determine the method of applying your payrncnts and credits to your Account.
10. Security. All of yoor obligations under this Agreement are secured by it deed of tug (geed ofTTusn on your property located at
1059 A York Road Diilsburg PA 17019.
You may buy property insurance from anyone that is acceptable to us You will provide proof you are insured under the policy.
The Deed of Taut allows us to declare a default if you sell or transfer your property without our prior written consent (you are the
"Trustor," we are the "Beneficiary," and the "Property" is your property in the fbiIowing quotation):
7 4N$FE If Tr rstor r+obortardy meh's or conw-ys rile above described pmfan?tfwly, w'Pnjapi err any interest in it or, by some
actOraw=di?= thensWvrs of title to the Property without ebtaintng the written consent q ,Be7teffed qty Duwor shat! be in default
and Arneftdary mo, ai its opt&),, dej- my the ew rt: unpaid &danm of the loan and awrwed but unpaid fntc est fmme U&y due
and payable.
11. Events of Defiult. You will be in default under this Agreetnmt if any of the following events occurs: (a) if you fall to comply
with the Minimum Payrnwt or any other terms or conditions of this Agrecinent; (b) if you die and you are the only Account holder or if
an Account holder survives you, we deem die security for the Account adversely affected; (c) your sell or transfer your property; (d) if
you fail to maintain the insutwxe rcquxed by the Deed of Trust; (c) if a lien senior to our Deed of Trust on your property forecloses;
(t) if yaw property is taken by eminent domain; (g) if you convnit waste or otherwise destructively use or haul to maintain your
property such that the action adversely affects the security of our Deed of 'Lost; (h) if you use your property illegally and such use
subjects your property to seizure by governtne ttal authorities; (i) if you move out of your property and your non-occupancy adversely
affects the security for the Account; and (l you fail to pay propcrty taxes and other assessment liens on your property that are senior to
the Deed of Trust.
12. Entire Uance Due. If you are in default, we may do one or more of the following: (i) require that you immediately pay the
outstmding balance with interest due on 16 balance, at the Anneal PercwtWe Rate provided above, until paid, or (ii) we can
terminate your right to obtain additional Cash Loans. We may exercise one of these options without giving up our right to exercise
APOW ttu hXm aetbw* br- MO) 833-98 3 ?sttsn/51art i zetgrar? r Z-
19 - Nabs Note P&9r2 or 4 -" .--,
.1-0131/2007 14:34 8184441912 LOAN SERVICING PAGE 12113
w lhar option if your default cantirntes. If we demand full payment of the outstanding balance and you fail to itarnediarely make
payyment, you agree to pay all collection costs, including our attorney's fees.
13. Trsrnsfer of Account You carmot transfer or assign your Account to any other person.
14. Notice to Joint Applicants. Each applicant has the right to use this Account to the extent of the Maximum Credit Lizrdt and may
be liable for all. amounts extended under this Account to airy Joint applicant
15. Change of Address or Telephone Number. You agree to advise us promptly if you change your mailing address or telephone
nuxd=- All written notices and statements from us to you will be considered given when placed in the United States mail, postage
pzeptid, and addressed to you at your current address as it appears in our records.
16. Irregular Payments. We tray acc;V late payments or partial payments or checks, drafts or money orders marked `Payment in
Full" without losing any of our rights under this Agreement
17. Anwndmemts. We may make insignificant changes to this Agreement at any time or changes that unquestionably benefit you, as
long as we give you advance written notice as required by law.
18. Cancellation. You can cancel yarn Account at any time by giving us notice and paying in full all stuns due on your Account.
Your obligation under this Agreement, including our security interest in your property, and any changes made under this Agreement
prior to cancellation will continue to apply until you have paid you all the money you owe on the Account
19. Other Provisions. Each of you who sighed this Agreerent or use the Account is individually and jointly obligated for all
payments due under this Agreement The Account has been appbed for, considered, approved and issued in the State of California and
all extensions of credit are being made from the State of Califomia. You agree that this Agreement shall be governed by and
interpreted under California and Federal law. If any pert of this agreement is not valid, all other parts will remain enforceable.
20. Tax Consequences. You should consult a tax advisor about die deductibility of interest and other charges under this Agreement
YOUR FILLING RIGHTS - MEP THIS NOTICE FOR FUTURE USE
This notice contains important information about your rights and our responsibilities under the Fair Credit Billing
Act
Notify Us In Case Of Errors or Questitms about Your Bill.
If I think your bill is wrong, or if you need ruore information about a transaction on yourbill, write to us on a
separate sheet at the address listed the bill- We must hear from you no later than 60 days after we sent you the first
bill on which the error or problem appeared. You can telephone us, but doing to will not preserve your rights.
In your letter, give us the following information.
Your full natne and Account number.
The dollar amount of the suspected error.
Describe the error and entain, if you con, why you believe there is an enror_ if you need more information,
dcscnbc the item you are not sure about
If you have autltori7ed us to pay your brill automatically from your savings or checking account, you can stop the
payment on any amount you tbink is wrong. To stop the payment your letter must reach us by three business days
before the automatic payment is scheduled to occur.
Your Rights and Your ReWonsibflities after We Receive Your Written Notice.
We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we
must either correct the error or explain why we believe the bill was correct.
After we receive your letter, we cannot try to collect arty amount you question, or report you as delinquent. We can
Continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount
against your credit limit You do riot have to pay any questioned amount while we are investigating, but you are still
obligated to pay the parts ofyour bell that are not in question.
ApUkd Bul - 3*4we. km (MM U3-ss43 j5ta771,ta77 ? ZetprerJ Sr-
ta.HeftrAoe Page 3d4 2
LOAN SERVICING PAGE 13/3-3
,3-8/31i2007 14:34 8184441912
If we find that we made a mistake on your bill, you will not have to pay any finance charges related to any
,gdestiow4 amount. If we dWn"t make a mistake. you racy have to pay finance charges, and you will have to make
up any missed paynws on the questioned amount In either case, we will send you a statement of the amount you
owe and the date that it is due.
If you fail to pay the amount that we think you owe, we may report you as delinTma However, if our explanation
does not satisfy you and you write to us within ten days telling us that you shill refuse to pay, we must tell anyone we
report you to that you have a question about your bill. We roust tell anyone we report to that the matter Iuas been
settled between us when it finally is_
If we don't follow these rules, rune can't collect the first $50 of the questioned amount, even if your bill was comet
21. California Notice. California law requires that we notify you that if you fail to fulfill the terms of your credit
obligation. a negative credit report retleeting your credit record may be submitted to a credit reporting Agency.
22. Early Closure Fee. This agrocment is subject to an "Early Closure )Fee." If you close your Line of Credit and requested a
release of the security instrument securing your property within 36 months of the loan agmement you.will be required to pay in
"Early Closure Fee" in the amount of. 5445.00. This Early Closure Fee is due whether said closure is voluntary or involuntary as
in acceleration whether due to transfer or non-payment
By signing below, you agree to all of the above terms and conditions and certify that you have received a eou?pleted copy of this
Agr eemcat and two copies of a Notiu of Right tU Cancel this Agreement on the date shown below.
C i ??? b ? L t? ab
BOMMOr SAAWW A6Z oar 4t4rarN 4 z,?p?ar Oar
CPC Modem ched below:
E) FOR INFORMATION CONTACT THE DEPARMENT OF CORPORATIONS, STATE OF
CALIFORNIA
APOW 9WnM So"" MG (MM Q3-9343 1519rr1513n r Zelda l
19-Heftm to ftp4014
Exhibit "E"
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669 C O
1310 INDUSTRIAL BOULEVARD
I FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690 ATTORNEY FOR PLAINTIFF
r
'
VALUE HOME LOAN INC. COURT OF COMMON PLEAS i L= r
5959 TOPANGA CANYON BOULEVARD,
#201 WOODLAND HILLS, CA 91367 CIVIL DIVISION
:mo
<
PLAINTIFF
VS.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
1059 A YORK ROAD
DILLSBURG, PA 17019
DEFENDANTS
NOTICE
CUMBERLAND COUNTY
NO. 0&- 71 bvi I Term
COMPLAINT IN
MORTGAGE FORECLOSURE
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the court your defense or objections to
the claims set forth against you. You are warned that if you fail to do so the case may proceed without you
and a judgment may be entered against you by the Court without further notice for any money claimed in the
complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
800-990-9108
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF.
IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE
VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN
EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT
FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE
NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD
THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO
CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT
UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
1310 INDUSTRIAL BOULEVARD
I s' FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690 ATTORNEY FOR PLAINTIFF
VALUE HOME LOAN, INC. COURT OF COMMON PLEAS
5959 TOPANGA CANYON BOULEVARD,
#201 WOODLAND HILLS, CA 91367 CIVIL DIVISION
PLAINTIFF
VS.
CUMBERLAND COUNTY
STEVEN M. ZEIGLER NO.
MARSHA J. ZEIGLER
1059 A YORK ROAD COMPLAINT IN
DILLSBURG, PA 17019 MORTGAGE FORECLOSURE
DEFENDANTS
CIVIL ACTION MORTGAGE FORECLOSURE
1. Value Home Loan, Inc. (hereinafter referred to as "Plaintiff") is an Institution conducting
business under the Laws of the Commonwealth of Pennsylvania with a principal place of
business at the address indicated in the caption hereof.
2. Steven M. Zeigler and Marsha J. Zeigler (hereinafter referred to as "Defendants") are
adult individuals residing at the address indicated in the caption hereof.
3. Plaintiff brings this action to foreclose on the mortgage between the Defendants and itself
as Mortgagee. The Mortgage, dated June 13, 2006, was recorded on June 28, 2006 in the
Office of the Recorder of Deeds in Cumberland County in Mortgage Book 1956,
Page 2234. A copy of the Mortgage is attached and made a part hereof as Exhibit `A'.
4. The Mortgage secures the indebtedness of a Note executed by the Defendants on
June 13, 2006 in the original principal amount of $150,000.00 payable to Plaintiff in
monthly installments with an interest rate of 11.49%. A copy of the Note is attached and
made a part hereof as Exhibit `B'.
5. The land subject to the mortgage is 1059 A York Road, Dillsburg, PA 17019. A copy of
the Legal Description is attached and made a part hereof as Exhibit `C'.
6. The Defendants are the Record Owners of the mortgaged property located at
1059 A York Road, Dillsburg, PA 17019.
7. The Mortgage is now in default due to the failure of the Defendants to make payments as
they become due and owing. As a result of the default, the following amounts are due:
Principal Balance $129,433.21
Interest to 12/18/2007 $7,285.54
Accumulated Late Charges $901.67
Cost of Suit and Title Search $550.00
Attorney's Fees $1,000.00
TOTAL $139,170.42
plus interest from 12/19/2007 at $41.31 per day, costs of suit and attorney's fees.
8. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchase at Sheriff's
sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be
charged.
9. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a
defaulting mortgagor with a Notice of Homeowners' Emergency Mortgage Assistance
("Act 91 Notice") 35 P.S. Section 1680.403c.
10. The Notice of Homeowners' Emergency Mortgage Assistance was required and Plaintiff
sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to
the Defendant by regular and certified mail on November 16, 2007. A copy of the Notice
is attached and made a part hereof as Exhibit `D'.
11. The Mortgage is not a residential mortgage under 41 P.S. Section 401 because the
principal amount of the Mortgage is in excess of $50,000.00 and, therefore, Plaintiff was
not required to send the Act 6 Notice of Intention to Foreclose.
WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the
mortgaged property in Plaintiff's favor and against the Defendants, in the sum of $139,170.42 together
with the interest from 12/19/2007 at $41.31 per day, costs of suit and attorney's fees.
Law offices of Gregory Javardian
BY:
Gr ory Ja 4 rdia
ttorney ID N 5669
Attorney for PI ntiff
EXHIBIT `A'
;10/31/2007 14:34 8184441912 LOAN SERVICING PAGE 06/13
Recerding Requested By &When Recorded
mlim
Value Home Loan, Inc.
5959 Topanga Canyon Blvd. #201
Woodland Hills, CA 91367
C_ fir-
loan M. 511877 Space above this tine for recordees use
Title Order No.
LONG FORM DEED OF TRUST AND ASSIGNMENT OF RENTS FOR
ROME EQUUY REVOLVING LINE OF CREDIT
THIS DEED OF TRUST, made this 13th day of June, 2006, between. Steven M. Zeigler & Marsha J. Zeigler, henin called
TRUSTOR, whose
address is 5959 Topaugn Canyon Blvd_ Suite 9201, Woodland Bills, CA 91367
COUNTY RECORDS RMARCH., a California corporation, 11 " i called TRUSTEE and VALUE HOME LOAN, INC., a
California corpotatioon, CFL # 6038218_ whose addrm is 5959 Topanga Canyon Blvd #20I Woodland Hills, CA 91367, herein
called BENEFI(CLARY.
Witnemeth, That TRUSTOR IRREVOCABLY GRANTS, TRANSFERS AND ASSIGNS to TRUSTEE IN TRUST, WrM
POWER OF SALE that property in Cumberland County, Pennsylvania describod as (the "Property).
TOGETHER WITH the tents, issues and profits thereof, SUWECr HOWEVER, to the rigK power and authority given. to and
confetrcd upon Beneficiary in Paragraph 10 below to collect and apply such rem, issues and profits.
FOR THE PURPOSE OF SECURING.
(A) Perfouraince of each agreement of Truster comained in tb?is Deed of Trust.
(I3) Paymicut of the Wdebtedj= evidenced by a Horne Equity Credit Line Revolving Loan Agrreernent (hereinafter
referred to as "AGREEMENT'? of even date herewith in the initial principal amount of $150,000.00, but subject to increase to a
rtnxinnnm of 5150,000.00, executed by Trustor in favor of Beneficiary or order, and any extension or renewal thereof_ The
AGREEMENT is a revolving line of credit cnrablk g the Tnrstor to redraw sums previously repaid, to be seared hereby, pursuant to
the tenets of the AGREEMENT and this Decd of Trust.
STATEN fWr OF 0BUGA110N: Beneficiary may collect the then ntaxunrun fee provided by Section 2943 of the California Civil Code
for famishing a statement of obligation.
TRANSFER. If Truster volimbrily sells W conveys the above-described Property, hilly or Wlally, or any interest in it or, by some act or
Means divest themselves of title to ibe Property without obtamnig the written cogent of Beneficiary, Truster shah be m &cfsalt and
Beneficiary may, at its option, declare the emir unpaid balance of the loan and accmed but unpaid interest irurnediately due and payable.
TO PROTW17 THE SEC117t W OF THIS DEED OF TRUST, TRUSTOR ALSO AGREES:
(1) To l=p the Property in good condition and repair; not to mnuw or dcmolish any building the con; to complete or restore promptly in good
and w orkmanl'ke manner any building which nay be canstr tetod, damaged or destroyed thereon and to pay when due all claims for labor performed and
matexiats furnished therefor, to comply with an laws affecting said Property or requiring any alteration or improvernmt to be made thereon: not to cottmit
or pextnit waste thereon; not to commit, 3ufier cr permit any ad upon said Property in violatioo of law; to cultivate, irrigate, fertilize, fumigate, [mate and
do all other acts which from the diameter or use of said Pmopctty may be reamobly necessary, the specific enumcratirm herein not excluding the general.
(2) To provide, maintain Arid deliver ro Beneficiary fm irtsutanc;c satisfactory to it acrd with low payable to Beneficiary. The amount collected
under any hest or other insuranx policy may be applied by Beneficiary upon iod6teduess waited hereby and in such order as Bawficiary may
detemninq or at option of Beneficiary, the expire amount so collected or any part tletoof may be released to Truster. Such application or release shall tent
cute or waive any default or notice of default hownder or invalidate any act done pursuant to such notice.
(3) To appear in and defend any ruction or promoding purporting to ahm the security hereof w the rights or powers of Beneficiary or Trustee;
and to pay 211 costs and expenses, including costs of evidence of title and attor ncy$ fees in a treasonable sum in any such action or proceeding in which
Beneficiary or Trustee may appear, and in any suit brought by Beoefec iary to enforce this peed of Trust
P`10"15511177 l Zelpldry?
20 - Heim Deed of Tfm sin x 51 PDP-1 of 3r-
" S
•-0/31/7007 14:34 8184441512 LOAN SERVICING PAGE 07/ 13
• (4) To pay at leer ten days before: ddkngnency all taxes and a rests of acung said Property, including assessrocrits on apputtcoant water
stock, -ebw dire, A encumbrances, durgea and liars, with intereest, on said Property or any part thereof, which appear to be prior to or superior haeto;
n, d all coats, fens and expanses of this That 3hmntd Trustor fail to make any payt ad or to do any act as herein provided, that Be tieficiary or T}tatre,
_btye without obligation so to do and witherttt notice to or dernatnd upon Ttuetar and without teleasittg Truster frown any obligation harco& tray retake or de
the same in such mower and to such extent as either may deem necessary to p[otect the sec onty hnereK Beneficiary or Trafta being authorized to eater
upon said Property for such purpose„ appear in and ddend any action of proceeding purport to atlect the security hemof or the rights or powers of
Eianeficiuy or Trustee, pay, ptmlase, oordest or cooapromim any taco nbrance, cdmrp or lien which in the judgment of either to be
supamr bat+, aM it exercising airyseuh power , pay nwesmry c epenses, employ counsel aid pay his reasonable foes appears proper or
(5) To pay imrueduddy and without demand AU vmu so expended by Batebclary or Trustee, with f dance charges firm date of expenditure at
the atpp nbk Annual Percentage Bate in the AGREEMM. and to pay for arty statemc t provided by laws In effect at the slate hereof rrgardinng the
obit illation sescaaed hereby my mrrount derivinded by Screciary not to exceed the nm mourn allowed by law at the time when said statanent is detumnded _
(d) That say award of datriages in connection with any condemnation for public use of or h oury to said property or any pact thereof is hcwby
assigned and shad be paid to scrhefiaiary who may apply or rdesec such moneys roceived by him in the same manner and with the same effect as above
provided for disposition of proceeds of fire or other insurance.
(7) That by acoa pting payer of any sour scoured hereby attar its due date, Beneficiary does not waive his right either to require prompt
payment when due of all other antis so secured or to declare default for hit re so to pay.
(8) Thaat any time and ftam theta to time, without liability ibeefor and without noticc, upon writ m request of Beneficiary and poesontation of
this Deed of Trost sad said AQRMWENT for endorsements and without affecting rite pcrsotal debility of any pemn for pmyme nt of the indelitedneas
seared hereby, Trustee may. recouvey any pat-- of odd Property; ant to the mold ng of any map or plat thereog join in granting any casement thetoom?
or join in any extension agmetttettt or any aglrctt d subordinating the rout or charge hrreo£
(9) Tbat upon written request of Beneficiary stating that all sum seemed hereby have beat paid, and upon surrender of this Deed of Trust and
said AGREMAENF to TWstee for canai wou and retention and upon paynicm of its fees. Trustee doU reeonvey, withow wwauty, the Property then
held hereunder. Tale recitals in such rmomrrrtce of any matters of fact shall be conclusive proof of the tauthf ihess ihcxco£ The grantee in such
rewsrvcyartce may be dc3cribed as. "Nee ptason or pereoos legally crtitled th+:rsto." Five yeas aft Wa;arsaw of such fuel rzconveyance, Trustee may
destroy said AGREEMENT and the Doed of Trust unless directed in anh request to retoitt them.
(14) That as additional security, Trutltor hereby Om to and confers upon Beneficiary the right, power and authority, during the continuance o f
these Trusts, to collect the rents, issues ad profits of said Property, reserving unto Trustor tho urgent, prior to any default by Tttustor in payment of any
indebtedness awnred hereby or in performance of any agrnemmt hereunto, to collect and retain such rents, issues and profits as they become due and
payable Upon any such delimit, Beneficiary may at any time wittiout noticr, either in pa corn or by 4gCnt, or by a r+eeeiver to be appointed by a court, and
without regard to the adegwcy of any security for the indebtedness bereby secured, enter upon and (aloe possession of said Property or any part heneK in
his own name lam for or otherwise collect such rents, issues and pmoftts, tttehmdutg thaw post due said unpaid, and apply the serene, less costs and cagmrses
of operation and collection, intdtldinng art ftws foes spat any indd*doess secured hereby, and in such order as BoacAciary may determine. The
entering upon and taking possession of said Property, the collection of such rents, issues and profits and the application thereof as aforesaid shall not cure
or waive any dctauh or notice of default heroxxicr or invalidate any act done pursuant to such notice.
(11) 11W upon default by Thatch under the AG'ItEEMMVT, Beneficiary may declare all serums secured hereby imuricdistdy due and payable by
delivetitsg to Trustee a written declaration of default and demand for sale and a written notice of default and election to cause to be sold said Property,
which notice Trustee shall cause to be filed for record. Beneficiary siso sball deposit Yin& 'hustle this Deed of Trust, the AGREEMBNT and all
documrtennts evidencing a xpenditurm secured herein. After the lapse of such thane as may then be required by law following recordation of said notice of
default, and notice of sate having been given as then required by law, Ttmstoo, without demand upon Tn,stor, shall sett the Ptperty at the time and place
fixed by or in said notice of sate, enter as a whole or in sere pwcels, and in such order as it may determine, at public auction to the highest bidder for
cash in lavfut money of the United States, payable at tiara of Sale` Trustee may postpone sak of all or any portion of said Property by public
announcctt>cut at the time fixed by the prexxedi;ig ppetponunnat Trustor shall deliver to such purchaser its decd conveying the Property, but without
coveoUtt or wo7srdy, express or implied- The recitals in arch decd of any matters of feet shall be conclusive proof of the truthfulness thereof. Any
person, including Truster, Tnlstcc, or Berteficuuy, as heminidkr defined, may purchase at such sale ARer deducting all costs, foes and ocpenses of
Trustor and of this Trust; including costs of evidence of tide in connection with sale, Ttustor shall apply the proceeds of sale to payment of all surns
extended under the terms ho mt not that repaid, with accrued finance charges at the applicable Annual Percattagc Rate in the AGREEWXr: all other
sums thine secured thereby. scud the reanaiexler, if any, to tine person or persons legally entitled thereto,
(12) Beneficiary or any macassor in ownership of any indcbtedness scarred hereby, may from titre to time, in an instrument in writing,
substitute a successor or successom to any Tiusift atoned hest:in or acting ho rcunder, which instruments exccuuted by Beneficiary and duly adenowledged
earl rccCrded in the office of the tt:cader of the cAunry er crnmQes where said property is situated, slap be com1wive proof of proper substitution of such
successor Trustee or Trustees, who shall, without conveys ec from the TWWC ptedemWot, succeed to all its title, estate, rights, powers and duties. Such
instrutrtatt must contain the name of the original Tnusew, Trustee and Beneficiary bercunder, the book and page when this Deed of Trust is recorded and
the naate mud address of the new Tlustcc.
(13) That this Dead of Trust apphet to, inures to the benefit of and binds all parties hereto, their heirs, legatees, devisers, administrators,
executors, successdx and assigns. The term Beneficiary -IMM the owner and holder, inchuding pledgees, of the AGRP2}MENT secured hereby, whetter
or not matt as Beneficiary herein. In this Deed of TruA whenever the context so requires, the masculine gender includes the feminine and or neuter,
and the singular number includes the plnal.
(14) That Trustrxt accepts this T mst when this Decd of Trust, duly executed and a0movAcdged, is made a public record as provided by law.
Trustee is not obligated to notify any party hereof of a pending sate under any other deed of trust or of any action or proceeding in which Tlrastor,
Beneficiary or Trustee shall be a patty unless brought by T uatee.
(15) If this Dccd of'ftust is secured by oondominiurn. cOaMmily apartment, stock cooperative behold or planned unit development, Trustor
agrees to comply with all recorded deetaration of covenants, conditions atnd 1016tritions, a&s=Mon bykaws, and association rules and regulations, and,
upon written request from Beneficiary, to esifott a the sane as against other owners in such devetopnxmft
(W) If the Deed of Trust is scarred by a lease, Trustor agues riot to amend, change, modify or waive his or her interest therein, or agree to do
so or to breach the least without the written consent of BOMOcittry. If this Covenant is breached and the security for this Doed of Trust is materially and
istannrt'rr azeto"
20 • Mee00 DWd of yard at/2 x r t Pape 2 of 3 ,,.7 _
.10/31/2007 14:34 8184441912 LOAM SERVICING PAGE 08/3-3
advert ely std, Beneficiary shall have the option to dcdm atl ww owed under the AGREEMENT sand this Dead of Trust, immediately due and
parole in fulL
k'TRUSTOR REQUES M TUAT A COPY OF ANY NO-PICE OF DEFAULT AND OF A" NOTICE OF SALE BE MAILED TO TRUSTOR
AT TRUSTOR'S ADDRM SET FORTH ON THE FRONT OF TENS DEED OF TRUST
IN ACCORDANCE W]TH SECnON 29Ub OF THE CALIFORNIA CIVIL CODE, REQUEST IS HEREBY MADE BY THE TRUSTORTHAT A
COPY OF ANY NOTICE OF DEFAULT AND A COPY OF ANY NOTICE OF SALE UNDER DEED OF TRM RBCORDED ON
in Book . Page Ollieral Records of County (or filed for raord with
Recotdes's Serial Number ofsame Com qt Cal*ak affecting the Property desalted on the ftnmt of this mstr ustient
auzuted by a: Tru for in which is named as Beneficiary,
and as Trustee, be mWIW to Comity Records Reseazch at 4952 Warner Ave. # 105. Huntiagtoo Beach,
CA 92649.
SIGNA7URIZS OF TAUSTOR(S):
6 It 40 6
9oirawer -ewes AL Z Date
.rus+,..,. Dore
StatE D10?18.RE:-{`tTQt? Q )
S5.
Covttty of Ct-Let be vlo---A
of v5 15"`Jc tf ? 'b fare me, {? •? ?ty_??ez a notary public, personally
personalty known to rw (or proved Vmc Dn htebasis of sadActory evAnce) to be the person(s) wbose tm lc(s) is/are subscribed to
the will-in instrurnent and acknewlodsed to me that be/alre/they 8xmted the samee in hss/hedtlxir authorized capacity(ies), and tbat by
hathet/thcir Pgaature(s) wk the instiumu the person(s), or the entity neon behalf of the /p}erson(s) acted, executed the mstru=nt.
WITNESS my hand and official sea]. my t, bmm;ss i on if Xv mr
?-
s EAL_Tm OF PENNMVANIA
coM]?cnrw
Notmldsod
trds M. Dow^ Notary Putxc
w0wv*dM ;*w0 tQ ,2008
u mbar, penaeovanis Aseoctadw of NouLdea
(Seal)
j5urnj6167712dphr)
20 - How Dead ofUntMax11 Pa9a30-3
EXHIBIT `B'
.10/31/2007 14:34 8184441912 LOAN SERVICING PAGE 10/ 13
HOME EQUITY CREDIT LINE REVOLVING LOAN AGREEMENT
Jun 13, 2006. This is an agreement containing the terms and disclosures which apply to your home equity line of credit
account ("Account") with Value Home Loan lac. whose address is 5959 Topanga Canyon Bind., suite #201 Woodland Hills CA
91367., a California corporation, CFL # 3038218. T%e words "we" or 'its" refer to the lender named in the previous sentence. The
words "you" or "your" mean the person or persons who use or authorize the use of the Account, jointly and severally.
1. NOW You May Use Your Aeeoant. Dining the first 36 months of the Amt ("Draw Period', you can borrow money ("Cash
Loess') from your Account by nuking a written request to us up to your maxmxtm credit limit After the Draw Period you will not be
permitted to borrow money but must repay your Account in full over a 180 month period ("Repayment Period'/. Your Account is a
revolving line of credit. You cannot request money in excess of the available credit (the difference between your outstanding balance
and your maximum credit l(mit) on your Account. You may not request less than $1,000.00 at any one time- Requests for money must
be in writing sent to us at an address we will give you. We will respond to it within 5 business days after receipt of your request. For
the first 30 days after your Account is open, you will not be permitted to draw more than 80% of your initial credit limit, nor draw
more than $5,000.00 in any 30 day period. You cannot make more than one draw request per 30 day period
2. Maximum Credit Limit, Your initial credit limit is $150,000.00, of which yow first Cash loan shall be 5120,000.00. You agree
that we cap change your credit lint at any time at our sole discretion but it shall never exceed $150,000.00. You also agree that we
are not obligated to extend further credit to you for any amount that would make your outstanding balance exceed your initial credit
limit, or for any amount if your outstanding balance is already over the initial credit limit. We may disburse funds firom your available
credit and assess the cash advance fee to care any default related to your property. Any increases in your initial credit limit you request
will require that you ma&e a written appl-cation for our approval. You will pay any amounts that exceed your maximum credit limit
upon demand. We may rc-evaluate your financial condition if you request a higher credit limit, or at any other time, and this may
include obtaining a current credit bureau report; and/or asking you for current financial information. We may suspend your right to
obtain additional Cash Loans when: (i) the value of yaur property has declined more than 201/0 Erato the appraised value at the time the
Account was opened, (ii) we reasonably believe that you will be unable to fulfill your repayment obligations under this Agreement
because of a material adverse change in yaw financial circumstances, (iii) you file a bankruptcy petition, (iv) one of the Account
holders requests such suspension or (v) govcrmnental or court actierri. If you believe that one of the conditions is no longer present, we
will reinstate your ability to obtain Cash Loans if you so request in writing and we confirm that the condition is no longer present.
3. Monthly Statement. If you have an o umlanding debit or credit New Balance of $1.00 or more, or if there is any finance charge
imposed dmirg a billing cycle, we will send you a statemen 20 days prior to the payment due date. You agree to pay us for all Cash
Loans, fees and charges, if any, and Finance Charges on your Account, all payable in United States Dollars according to the terms and
conditions of this Agreement no later that. the payn aat due date. The payment due date will be the same date each month which is
thirty days after the original funding date of your loan.
4. Finance Charge on Your Account Balance- We will determine and impose a FINANCEE QUARGE by applying a daily periodic
rate of 0.03192% to the daily unpaid principal balance for the umber of days that balance remains unpaid in the billing cyck. The
daily periodic rate is the AMUM 11ACENTAGE RATE of 11.49% divided by 360. The Annual Percentage Rate is subject to
change as explained in section 5 below. To get the daily unpaid principal balance, we will take the beginning balance each day, add
any new debits or Cash Loans and subtract any payments or credits. The Annual Percentage Rafe does not include costs described in
this Agreement other than interest A portion of the Finance Charge will be figured by applying a cash advance fee (a transaction fee)
of 11.0% of each Cash loan to each cash loan after the first Cash Loam, on the date the new Cash Loan is posted to your Account.
Finance charges accrue on a new Cash Advance and the related cash advance fee as soon as the Cash Advance is made. Amounts we
must pay to protect the security of our Decd of Trust will earn finance charges at the Arunttal Percentage Rate applicable during default
as soon as we make the advance.
5. Changes in the Annual Percentage Rate- The Annual Percentage Rate on your Account may change based upon changes in the
value of an Index. biting the Draw and Rcpsyroient Periods, the Index is the Wall Street Journal Prime Rate. If the Index is no longer
available, we will choose a new Index that is based upon comparable information and will give you notice of this choice. Your Annual
Percetage Rate may only change once per year, on June V. The first adjustment will not occur until the third year of the loan. To the
Index value as of the first business day in the preceding May, we will add a margin of 4.5%- The sum of the Index value and the
margin will be your new Animal Percertttge Raft, subject to the limits described in the remainder of this section. You will pay
periodic Fiume Charge at the new rate starting with the following July I" payment. The a>9xiniurn Annnwl Percentage Rate that can
apply during the Draw and Repayment Periods will be 10.0% percerdW points over the initial Annual Percentage Rate. The
minimum Annual Percentage Rate that can apply during the Draw and Repayment Periods is the initial Annual Percentage Rate. There
are no other limits on how much the Annual Percentage Rate can change at any one annual adjustment.
Applled 9ueh- SpWare. 1w- (eat 935.3343 1514771519» / Zelpreq -
19-Nabclvale Fags 1 d4n-q
..10/31/2007 14:34 8184441912 LOAM SERVICING PAGE 11/13
6. -Minimum Paynaet L You agree to pay either the entire outstanding balance ("New Balance") indicated on your toot Wy statcromM
or in monthly payments. During the Draw Period, the atirtitra m monthly payment r Minimnin Payment Due") you tttar9t pay will be
equal to just the interest at the then applicable Annual Percentage Rate that accrued during the billing cycle, without any provision for
reduction of the unpaid principal balance. You can always pay thorn if you wish. During the Repayment Period and continuing until
you have paid the unpaid principal balance in full, your Minimum Payment Due will be fixed at each adjustment of the Anmaaal
Percentage Rate at an amoemt sufr=ent to fully repay what you owe in equal monthly installments by the end of the 180 month
Repayment Period. Each July l' during the Draw and Repayment Periods, changes in the Annual Percentage Irate will result in
changes to the amount of your Minimura Paytrtaat Due- If you default and we mot advance other sutra to protect the security of our
Deed of Trust, you agree to pay these anvxwts in full together with the next regularly scheduled Minimum Payment Due.
7. Fees.
(a) ,gate paymvu Fee: Your Miranum Payment Due will be past due if it is not received by us on or before the Payment Due
Date shown on each monthly statement, A late charge of 10.0% of the payment with a m ininnsm of $25.00 will be charged to your
Account, if at least the Minimum Payment Due, including unpaid payments, is not received by us within 1.0 days after the Payment Due
Date.
(b) Fee for Documeaus: If you request a copy of a statement. Cash Loan request or other document not in connection with a
billing error, we will charge your Account the sum of $15.00 for each copy.
(c) Annual or Initial Fees. You agree to pay, by a debit to your Account, the following initial, non refundable fees to set up
this Account
D
Title Insurance $395-00 (estimated)
Recording Fee $45.00 (estitttated)
Appraisal Fee $200.00 POC
D 'on
Escrow Fees $395.00 (estimated)
Loan fee 12-0% of initial advance
Other: Loan Setup 5795.00
You agree to pay the exact amotmt of airy initial fee that is estimated. Than are no MUM fees on this Account, but you will pay a
cash advance fee for new Cash Loans_
(d) Returned Payment Check Fee: If you make payment by check and a cheek is returned unpaid for any reason, your Account
will be charged $25.00 for each returned check.
8. Draw and Repayment Periods. During the Draw Period, you may add Cash Loans to your Account for up to 36 months so long
as you own your property and you are not in default. Thar, dmutg the Repayment period, you must pay at least the Mimmattn
Payment until the Unpaid Balance is paid in full. On written notice to you we can extend your Draw Period or your Repayment Period,
but we are not obligated to do so.
9. Application of Payment. We will determine the method of applying your payments and credits to your Account.
10. Security. All of your obligations under this Agreement are secured by a deed of Mat (geed ofTrusn on your property located at
1059 A York Road Dilliburg PA 17019.
You tray buy property insurance from anyone that is acceptable to us- You will provide proof you are insured under the policy.
The Decd of Trost allows us to declare a default if you sell or transfer your property without our prior written consent (you are the
"Trnstor," we are the "Beneficiary," and the 'Twpc rWl is your property in the following quotation):
TJMN$FER• If Thaw cnlumadly sWs or c onMs the abote-dercrfiW Properly fatly or paHwHy, or any interest in it or, by some
act or maw dims themoelves of title to the Property without obta€ning the written consew of l3e wfldc )% 7frastvr shaft be in defeutt
and Aeagidwy may, at its gwien, de .*re eke embw unpaid balance of the loan and aawtod but unpaid Ink mo tmmedtatelp due
and paivVe.
11. Events of Default. You will be in default under this Agreement if any of the following events occurs: (a) if you fail to comply
with the Minimum Payment or any other tears or conditions of this Agreement; (b) if you die and you are the only Account holder or if
an Account holder survives you, we deem -he security for the Account adversely affected; (c) you sell or transfer your property; (d) if
you fail to maintain the insurance required by the Deed of Trust; (c) if a lien senior to our Deed of Trust on your property forecloses;
(f) if your property is taken by eminent domain; (g) if you commit waste or otherwise destructively use or fat? to maintain your
property such that the action adversely affects the security of our Deed of Trost; (h) if you use your property illegally and such use
subjects your property to seizure by governmental authorities; (i) if you move out of your property and your non-occupancy adversely
affects the security for the Account; and (1) you fail to pay property taxes and other assesunent liens on your property that are senior to
the Deed of Torsi.
12. Egtire Valance Due. If you are in default, we luny do one or amore of the following: (i) require that you immediately pay the
outstanding balance with interest due on 16 balance, at the Annual Percentage Rate provided above, until paid, or (ii) we can
terminate your right to obtain additional Cash Loans. We may exercise one of these options without giving up our right to exercise
APOW Ma' en &M u . 4i- MM) a33-3M 1stBT7,5,an, zelglo? S L
t8-Hole-Note Pegc204 ')rq?
a1-0131/2007 14;34 0184441912 LOAN SERVICING PAGE 12113
arl0her option if your default continues. If we davand &H payment of the outstanding balance and you fail to immediately make
patyment, you ague to pay all collection costs, including our attorney's fees.
13. Transfer of Account. You cannot ft Mfer ar assign your Aceouaut to any other person
14. Notice to Joint Applicants. l=ath applicant has the right to use this Account to the extent of the Maximum Credit Limit and may
be liable for all amounts ext+euded under this Account to any joint applicant
IS. Change of Address or Telephone Number. You agree to advise us promptly if you chattge your maiming address or telephone
num bcr. All written notices and statements from us to you will be considered given when placed im the United States snail, postage
pzelxid, and addressed to you at your current address as it appears in our records.
16. Irreplar Payments. We may accrpt late payments or partial payments or checks, drafts or money orders marked `Payment in
Full" without losing any of our rights under this Agreement.
17. Amendments. We may make insigr-ificant changes to this Agreement at any time or changes that unquestionably benefit you, as
long as we give you advance written notice as required by law.
18. Cancellation. You can cancel your Account at any time by giving us notice and paying in full all sums due on your Account.
Your obligation under this Agreement, including our security interest in your property, and any changes trade under this Agreement
prior to cancellation will continue to apply until you have paid you all the money you owe on the Account
19. Other ProvWoss. Each of you who signed this Agreement or use the Account is individually and jointly obligated for all
paysments due under this Agreement The Account has been applied for, considered, approved and issued in the State of California and
all extensions of credit are being made from the State of California. You agree that this Agreement shall be governed by and
interpreted under California and Federal law. If any part of this agreement is not valid, all other parts will remain enfu=able.
20. Tax Consequences. You should consult a tax advisor about the deductibility of interest and other charges under this Agreement.
YOUR BILLING RIGHTS - KEEP THIS NOTICE FOR FUTURE USE
This notice contains important information about your rights and our responsibilities under the Fair Credit Billing
Act.
Notify Us In Case Ot; Errors or Questions about Your Bell.
If I think your bill is wrong, or if you need ruore information about a transaction on your bill, write to us on a
separate sheet at the address listed the bill- We must hear ftom you no later than 60 days after we sent you the first
bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights.
In your letter, give us the following irformatiom
Your full name and Account number.
The 40ilat arnowrt of the suspected error.
Describe the error and expiaiu, if you can, why you believe there is an error. K you need more information,
dcsonbc the itcm you are not sure about
If you Crave authorized us to pay your br71 automatically fain your savings or checking account, you can stop the
payment on any amount you think is wrong. To stop the payment your letter roust reach us by three business days
before the automatic payment is sc.!kduled to occur.
Your Fights and Your Responsibilities After We Receive your Written Notice.
We must acknowledge your letter within 30 days, unless we have corrected the error by then. Within 90 days, we
nLnst either comot the error. or explain why we believe the bill was correct
After we receive your letter, we carrot try to collect any amiotrnt you question, or report you as delinquent. We can
continue to bill you for the amount you question, including finar>ce charges, and we can apply any unpaid amount
against your audit limit. You do not have to pay any questioned amount while we are investigating, but you are stilt
obligated to pay the parts of your bill that are not in question.
Apo" Duo Sok4WV. kr (WD) CU.SM3 1519 ]4lernr7.dert St`.
19 - Rabe NOW P8"39[4 V?
,1-8/31/2007 14:34 9104441912 LOAN SERVICING PAGE 13/13
If we find that we made a mistake on your bM, you will not have to pay any Nasser charges related to any
,questioned amount If we didn"t make a nastake, you may have to pay finance charges, and you will have to make
up any missed payments on the questioned tmount In either case, we will send you a statement of the amount you
owe and the date that it is due"
2f YOU fall to pay the amount that we think you owe, we may report you as delinquent However, if our explanation
does not satisfy you and you write to us within ten days telling us tlrat you sttv reflrse to pay, we must tell anyone we
report you to that you have a question about your bill. We roust tell anyone we report to that the matter has been
settled between us when it fealty is"
If we don't follow, these rules, we can't collect the first $50 of the questioned nxnxK even if your bill was correct
21. California Notice. California law requires that we notify you that if you f4 to fiiM the terux of your credit
obligation, a negative credit report reflecting your credit record may be submitted to a credit reporting agency.
22. Early Closure Fee. 'T'his agrectnent is subject to an "Earle Closure Fee." If you close your Line of Credit and requested a
release of the security instrument securing year property witWn 36 months of the loan agreement you will be required to pay an
Early Closure Fee" m the amount of. S495M. This Party Closure Fee is due whether said closure is voluntary or involuntary as
in acceleration whether due to transfer or non-payment.
By signing below, you agree to all of the above terns and conditions and certify that you have received a covTletcd copy of this
Agrfinent and two copies of a Notice of Right to Cancel this Agreement on the date shown below.
sonvwer srs.-rJKzM# +WersNJ. Z?.W? l? ab
mete
CFL Genders chew below:
[ l FOR INFORMATION CONTACT THE DEPARMENT OF CORPORATIONS, STATE OF
CALIFORNIA
AppW au fie. Ww_ ON) 833aW42
?S,ernsurr ? ta?or?
18-H21?C MOM p9AQ+l Oro
EXHIBIT ` C'
ALL THATCEKrAQdtmclafbeadsiasao isV*TavmdipafMoaor,,0=aya(Cumbetland,
and Conumoaw e" of Peansylvask being amm pmdc"y bounded mod detcm%cd is faUavm,
to wir
SEG1NWtlfi?apakofaloa4tco?aaratlwrlcmowr«fos?.vba('pwpirN.l?lwmr ml
Game & Ske& heir dmoe Sao16 S3 4Wm 07 Amoco Wca. &a voc of i M9J5 teal
dons leach am or i mmicily afGmW L Somek 6ei m oa ar7e of OO&M d wce Nails 2 depsccs
46 -Wca a 4hhmM of999 47 im daab louse rower fagW ft OM. jjWWW WS pilc of
„mot beat?kA $3 dWm R>.immW PtltRlialapos of 6k6A0 foci airas Panda mw or
R-317OM Wclr Savck *9 plc efstaom dux S=&21 dcrm es miavees fim a
distwaoc?99lLtq fc? doe6 (asdsa aoM q fotalaly al'Htwy A. Sdadtz amd Mara N. hfunar
w a p'k aJaaaaea and place ofBE(iQdWQriG.
CONTAINING IL63 awes is aeooedm = Wick navay P4'wcd for Rubest E. Sfil&,. Regimtc
Savc7oti Wad dead Scptmbcr31.1964.
Mm- M tc 262
EXHIBIT `D'
I-
4-
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
November 16, 2007
STEVEN M. ZEIGLER, A/K/A STEVEN M. ZEIGLER, A/K/A
STEVEN ZEIGLER STEVEN ZEIGLER
1059 A YORK ROAD 4909 LOUISE DRIVE, SUITE 104
DILLSBURG, PA 17019 MECHANICSBURG, PA 17055
MARSHA J. ZEIGLER MARSHA J. ZEIGLER
1059 A YORK ROAD 4909 LOUISE DRIVE, SUITE 104
DILLSBURG, PA 17019 MECHANICSBURG, PA 17055
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
This is an official notice that the mortgage on your home is in default and the lender intends to foreclose
Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save
your home. This Notice explains how the program works
To see if HEMAP can hel% you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet the
Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving your County are
listed at the end of this Notice. If you have any questions you may call the Pennsylvania Housing Finance
Agency toll free at 1-800- 342-2397 (Persons with impaired hearing can call (717) 780-1869).
This notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. IS NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADA ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDA SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): STEVEN M. ZEIGLER, A/K/A STEVEN ZEIGLER
AND MARSHA J. ZEIGLER
PROPERTY ADDRESS: 1059 A YORK ROAD, DILLSBURG, PA 17019
LOAN ACCT. NO.: 51877
ORIGINAL LENDER COUNTY RECORDS RESEARCH, AS TRUSTEE
FOR VALUE HOME LOAN, INC.
CURRENT LENDER/SERVICER: VALUE HOME LOAN, INC.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE
YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE
PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE.
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of
foreclosure on you mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR
MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -If you meet with one of the consumer credit
counseling agencies listed at the end of this notice the lender may NOT take action against you for thirty
(30) days after the date of this meeting. The names, addresses and telephone numbers of designated
consumer credit counseline agencies for the county in which the nrooerty is located are set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately
of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default). If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out
sign and file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO
NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Agency of its decision on you
application.
NOTE; IF YOU ARE CURRENTLY PROTECTED BY THE FILING
OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT
TO COLLECT THE DEBT
If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date)
NATURE OF THE DEFAULT- The MORTGAGE debt held by the above lender on your property located
at 1059 A YORK ROAD, DILLSBURG, PA 170191S SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due 8/22/2007 through 10/22/2007, one payment of which is due at a rate
of $1,263.38 per month, one payment of which is due at a rate of $ 1,305.40 per month, and one payment of
which is due at a rate of $ 1,317.46 per month.
Monthly payments plus late charges accrued: $ 4,143.12
(Suspense) ($0.00)
TOTAL AMOUNT TO CURE DEFAULT $ 4,143.12
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable):
N/A
HOW TO CURE THE DEFAULT- You may cure the default within THIRTY (30) DAYS of the date of
this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 4,143.12
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE THIRTY (30) DAY PERIOD. Payment must be made either by cashier's check, certified check or
money order made payable and sent to: 5959 Topanga Canyon Boulevard Suite 201, Woodland Hills CA
91367: TELEPHONE NO. IS 1-818-444-1930• CONTACT: GUSTAVO CARAVANTES
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter. (Do not use if not applicable) N/A.
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortg_ eag debt. This means
that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclosure upon your mortgage property.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay
off the mortgage debt. If the lender refers your case to its attorney, but you cure the delinquency before the
lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees
that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will
have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount to the lender, which may also include other reasonable costs. If
you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to
cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by
paving the total amount then past due plus any late or other charges then due reasonable attomp 's fees
and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as
specified in writing by the lender and by performing any other requirements under the mortgage. Curing
your default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such a Sheriff's
Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of
this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER-
5959 Topanga Canyon Boulevard
Suite 201
Woodland Hills, CA 91367
CONTACT: GUSTAVO CARAVANTES
TEL NO. 1-818-444-1930 ext. 262
EFFECT OF SHERIFF'S SALE- You should realize that a Sheriff s Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE- You T may or XX may not (check one) sell or transfer your
home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale that the other requirements of
the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT
TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED.
Very truly yours,
ATTORNEY FOR LENDER
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS
OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C §
1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE
DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING
WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN
VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE
VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT
OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)
THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY
(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING
YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT
YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT
TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU
HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF
THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR
WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT
OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS
(THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE
MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS
IN THIS SUIT.
CUMBERLAND COUNTY
Acorn Housing
14 S. 13th Street
Harrisburg, PA 17104
717.213.0150
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
'4 ?
VERIFICATION
The undersigned hereby states that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge, information and belief. The
undersigned understands that the statements therein are made subject to the penalties of 18
Pa.C.S. Section 4904, relating to unworn falsification to authorities.
Exhibit "F"
COPY
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
e-mail: Iawof iceCOepix.net
VALUE HOME LOAN, INC.,
Plaintiff
V.
STEVEN M. ZEIGLER and
MARSHA J. ZEIGLER,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-77 Civil Term
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this Complaint
and Notice are served, by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment may be entered
against you by the court without further notice for any money claimed in the Complaint or for
any other claim or relief requested by the Defendant. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford St.
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas quese presentan mas adelante en las siguientes paginas, debe toma accion dentro de
los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte
por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier
otra reclamacion o remedio solicitado por el demandante puede ser dictado en constra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos
importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A
PERSONAS QUE CUALIFICAN.
Cumberland County Bar Association
32 S. Bedford St.
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
u?
Date:
Gregory R. Reed, Esq ire
Attorney for Defendant Steven M. Zeigler
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
Attorney I.D. No. 23705
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
e-mail: lawoffice(cuepknet
VALUE HOME LOAN, INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
STEVEN M. ZEIGLER and
MARSHA J. ZEIGLER,
Defendants
NO. 08-77 Civil Term
J/ ANSWER AND NEW MATTER
AND NOW, this 7f?'day of February, 2008 comes Defendant, Steven M. Zeigler,
by and through his attorney, Gregory R. Reed, Esquire, and files an answer and new
matter, as follows:
1. Admitted.
2. Denied in part. Marsha J. Zeigler does not reside at the above referred to
address and has not resided there for a substantial period of time.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. It is specifically denied that the mortgage is now in default. Plaintiff was
illegally and erroneously charging defendants compound interest. Plaintiff acknowledged
the error and Jeffrey Keyser, an employee of plaintiff, granted defendants a six (6)
moratorium for the payment of the mortgage obligation. As such, said mortgage is not in
default, the interest claimed is not due and in the alleged late charges are unwarranted and
inaccurate. Also, the claim for the costs of suit, title search and attorney's fees are not
due because there is no default.
8. Defendant's answer to paragraph 7 hereof is incorporated herein by reference
as though fully set forth herein.
9. Admitted.
10. Admitted.
11. Neither admitted nor denied.
WHEREFORE, defendant, Steven M. Zeigler, respectfully requests this court
to enter judgment for both defendants and against plaintiff.
NEW MATTER
12. Defendant's answer to Paragraph 7 hereof is incorporated herein by reference
as though fully set forth herein.
WHEREFORE, defendant, Steven M. Zeigler, respectfully requests this court
to enter judgment for both defendants and against plaintiff.
Date: ? ; &o-,
&6' gory R`Ae , squi
Attorney for defendant Steven M. Zeigler
3120 Parkview Lane
Harrisburg, PA 17111
(717) 238-0434
Attorney I.D. #23705
1, Steven M. Zeigler, hereby verify that the statements made in the attached
Answer and New Matter are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements are made herein I am subject
the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
Date:
Steven M. Zeigler /
CERTIFICATE OF SERVICE
AND NOW, this --qL' day of February, 2008, I, Gregory R. Reed, Esquire, Attorney for
Defendant, Steven M. Zeigler, does hereby certify that I have this day served by first class mail a
copy of the attached Answer and New Matter, to the following address:
Gregory Javardian, Esquire
1310 Industrial Boulevard
1St Floor, Suite 101
Southhampton, PA 18966
fs_
Gregory R. A6 , Esq ire
Attorney for Defendant, Steven M. Zeigler
3120 Parkview Drive
Harrisburg, Pennsylvania 17111
(717) 238-0434
Attorney I.D. 23705
Exhibit "G"
ow Mau* som fK i A To*smk . rh 12FIV rzdbar?
tgmsoommom'
,?. itsto?$oaaa?a!a4??sdatsrwo?m?°b?as+?9le?se?aa3dxdot?mxl
??? ?t ?? Baesor??a
?:. 't}jt' l atogp ed eo defs.1 btu man mow oad s samqx*
C lbcEo bmtl,?a iY e?c?, and fi sat pa t.tait d?cpsym
?. Y?tos liaosw LamR Roaa+ m mddgeo a Es drda tie pe aado
I. i.cat pomw ,Eoenra?aa#roaotl..
Jt£minrm. odk V . IW-@be?e
'C'Mm?s?p?arRr+ar?'?E?roee# #gdsar+?eflprlsE?I
twat -I - 4 ft-MI!,
+s?s?l xYr?oe?s dj?dld svd??y,?? ?pc ?Y ($+f. # at 1?e?e+? ?
to bft =heft mm"dwm= .y ftufw gyp, V
IIAft"estYt.0 Its'1R*Mf MW%%Opp"*&tM. Wprbw$ofMW *04&
.116, F
Pygo mfti*t#ds ,Vs-kcH=Lmui htizm. Bmo*mmifAwwmisk-shftow
don cwwIbemOEapQd of7 i -91-01 diet.wA eaEtoImsssdoffuL>#ioe*
6??ea?ei?u:ssabgsse+o s I?eo ?t 8a? sA ?s++m?6efdsd pt
mwwftmpqo?rR?t ?sSe aedatx e+?ro e L r e t eJ?tg ndmt is k
ma?lbta?ae?ti;prid at:?dM,Yt?tlftl? Laaoriae ?? Ai<od?pw? paper ?'.?iE?zjr,
f tiiettaesoagafffie i a snt r?ee sxe B x?tsi bciia tltUo t
ti m Yt?el3aetlsLeico?, mep? rr?lraat
ra" oo*r-
x
Steven NL U91a & rsha L Zeigler
x
Voloo Home LOAR XWFAVQaALULUVia . Wht Name And Sip?
12 Ammamwalm w4k.wo6illi-Im -III
+?!! awa?psid!(?Y?Iia?netea?? s?itba?+?s ?.?,oo?icQ+!e?a?ga3d11?3?Z
=dDmdalTr*lb ftVmpcmaic Mcats ftasamorfta ft* Orp armke
:
1t a aad aad gad 1 rad t 'WIDIX =any
W dolt ?a uicmoolp p ay dsb:
s?e?oese?rfl?ecpd?ea,t?e?arni??Soa a?r:e+d?:e?sa?mrl.
ptft rgy?e?Jraodaad asn"G* d+ tsaasaaeoor it+aedb deabae cent Woo d%
b??adY?acNaax ?a.?
ui? ? a?rawaQ tb?s if?ee_ie sed st?bG er?,e ? ? e?
!u brasile bj? ? Haft PbO ? sue[.
i ? ?? ?md?ti6?L5e?saom?p?Sed;pf ?F mt Fx+a?,'6?Daga'd;?3ear?,
wMbtVucb"fim
8ocrorae?s oda?cad? ?e drt f ? aab? ? P ?edaeanr ?poaao? ?[aqp ?F a?ot
*+ ? , bae a;ry pea?erd a a? ?.?Y s?m?spd? iD ieradesar ?oo:ae?i ? lm3er Yeea?r
?4?ti?rim?efbt8a?•?Qc??Cr?r.ramsof4K? and imsn?a? imdee
Irl eria a a ora *109awpm Awpr rme4taaedndby
3odtr ?e?orsvrrers d? 1ae?odb?]a?t ?,' ?,?, ?
aa?;=odiaghkow. m O&a edA nlM4*s*AbhoOakc?bas#?4q:dry.
p: I'l
?`rn'?1be.?Eik bJr» tira:in tiara
?er+?sMdsp?+.
x
gi n R Zeigler & M .I. z,,.ig,,,
Valuer Horse t RRwe =tative Mmw Print Na=,,
818-749-0010 east 4 : ?t?4-1
THE LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN Attorney for Plaintiff
ATTORNEY I.D. # 55669
1310 Industrial Boulevard,
1St Floor, Suite 101
SOUTHAMPTON, PA 18966
(215) 942-9690
VALUE HOME LOAN, INC.
Plaintiff
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
vs.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
Defendants
No.: 08-77 Civil Term
CERTIFICATE OF SERVICE
TO THE PROTHONOTARY:
I hereby certify that true and correct copies of Plaintiff's Motion for Summary
Judgment has been served upon the following persons via first-class mail on the date
indicated below.
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
Attorney for Defendant, Steven M. Zeigler
Date: March 13, 2008
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 3 J`-
DAY OF m?1c y , 2008.
Marsha J. Zeigler
405 Front Street
Boiling Springs, PA 17007
Defendant Pro Se
?? - zA___1
Gr ory J ard' , Esquire
torney for P ' tiff
ARY PUBLIC
JAWs ?q,
ComT? ?MR?fCip?
11
?' C7
- •1
ties
A YAIAATC*
Y40041TI +4 tit
,*Wuq !
Y
PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next
Argument Court.)
CAPTION OF CASE
(entire caption must be stated in full)
Value Home Loan, Inc.
vs.
Steven M. Zeigler
Marsha J. Zeigler
No. 08-77 , Civil Term
1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to
complaint, etc.):
Plaintiff's Motion for Summary J»rjT nt
2. Identify all counsel who will argue cases:
(a) for plaintiffs:
Dale F. Shughart, Jr., Esquire
(Name and Address)
35 East High Street, Suite 203 Carlisle, PA 17013
(b) for defendants:
Gregory R. Reed, Esquire
(Name and Address)
3120 Parkview Lane Harrisburg, PA 17111
3. 1 will notify all parties in writing within two days that this case has been listed for
argument.
4. Argument Court Date:
May 28, 2008
S" ature
James P. Kennedy
Print your name
Date:
Attorney for Plaintiff
INSTRUCTIONS:
1. Two copies of all briefs must be filed with the COURT ADMINISTRATOR
(not the Prothonotary) before argument.
2. The moving party shall file and serve their brief 12 days prior to argument.
3. The responding party shall file their brief 5 days prior to argument.
4. If argument is continued new briefs must be filed with the COURT
ADMINISTRATOR (not the Prothonotary) after the case is relisted.
THE LAW OFFICES OF GREGORY JAVARDIAN
BY: JAMES P. KENNEDY Attorney for Plaintiff
ATTORNEY I.D. # 86614
1310 Industrial Boulevard,
1St Floor, Suite 101
SOUTHAMPTON, PA 18966
(215) 942-9690
VALUE HOME LOAN, INC.
Plaintiff
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
vs.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
Defendants
No.: 08-77 Civil Term
CERTIFICATE OF SERVICE
TO THE PROTHONOTARY:
I hereby certify that true and correct copies of the Argument Praecipe has been
served upon the following persons via first-class mail on the date indicated below.
Gregory R. Reed, Esquire
3120 Parkview Lane
Harrisburg, PA 17111
Attorney for Defendant, Steven M. Zeigler
Marsha J. Zeigler
405 Front Street
Boiling Springs, PA 17007
Defendant Pro Se
Date: April 16, 2008
SWORN TO AND SUBSCRIBED
BEFORE ME THIS RD Y"'?
DAY OF U-1` _?, Q , 2008.
NOTARIAL SEAL
TW E. POPER, Notary Pudic
Upper Scutloroton TWP.. 9udm Cox"
CdRrrniseiorr Nara W 29.20
12 -
J es P. Kennedy, Esquire
ttomey for Plaintiff
i 1
I
:+, Cn ` ?
VALUE HOME LOAN, INC.,
Plaintiff
VS.
STEVEN M. ZEIGLER and
MARSHA J. ZEIGLER,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 08-77 Civil Term
ENTRY OF APPEARANCE AS LOCAL COUNSEL
Dear Sir:
I hereby enter my appearance as local counsel, in conjunction
with the Law Offices of Gregory Javardian, for the limited purpose
of representing the Plaintiff at Argument Court to be held on
Wednesday, May 28, 2008.
Date: May 7, 2008
o?? Y
Dale F. SAg ar -,Vr .
Supreme Cour .D. 19373
10 West High treet
Carlisle, PA 17013
(717) 241-4311
cc Gregory Javardian, Esquire, for plaintiff
Gregory R. Reed, Esquire, for Steven M. Zeigler, defendant
Marsha J. Zeigler, defendant
ca
?- ? a
??
Office of the Prothonotary
Cumberland County
Curtis R. Long
Prothonotary
Dale F. Shughart, Jr., Esquire
35 East High Street
Suite 203
Carlisle, PA 17013
DATE: May 8, 2008
TO Attorney Shughart:
THIS IS TO NOTIFY YOU THAT CASE NUMBER 08-77,
Value Home Loan, Inc.
VS.
Steven M. Zeigler
Marsha J. Zeigler
U ? O DT. Ti N i 1r0rjr In 109"M] ? T%,r17TXXW1LTT AI,T f,s___ HII ^fAAA
CURTIS R. LONG
Prothonotary
Cumberland County RLEG--?YTF--
One Courthouse Sq E PAOIII ? OTARY
Carlisle, PA 1701
2018 MAY 14 AM 10: 45
CUi a (J vi G?f',
JIV:iYLVA IA.
Dale F. Shughart, Jr., Esquire_
35 East High Street
Suite 203
Carlisle, PA
i 7012IKCIS 2 0020
SAP PQ8r `!
41 ?' lq WIND
02 1A $ 0
0004631598 MAY
MAILED FROM ZIP COI
oF- -7 -7
SIXIC 171 CE
RETURN TO
NOT DELIVERABLE
UNABLE TO
BC: 117012 jj
?llli??llt'?Il)ili1??13??f?11?11
L 2$ 05/'1
SENDER
AS ADDRESSED
FORWARD
*0119-09816-C
THE LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN Attorney for Plaintiff
ATTORNEY I.D. # 55669
1310 Industrial Boulevard,
1 S' Floor, Suite 101
SOUTHAMPTON, PA 18966
(215) 942-9690
VALUE HOME LOAN, INC.
Plaintiff
VS.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
Defendants
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
No.: 08-77 Civil Term
PRAECIPE TO WITHDRAW PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
TO THE PROTHONOTARY:
Kindly withdraw Plaintiff's Motion for Summary Judgment with respect to the
above-captioned matter.
Date: May 21, 2008
egos av r ian, Esquire
ttorney f laintiff
C? n
c-n fv?
c;- T7
tJ' h?
C?
THE LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN Attorney for Plaintiff
ATTORNEY I.D. # 55669
1310 Industrial Boulevard,
1 st Floor, Suite 101
SOUTHAMPTON, PA 18966
(215) 942-9690
VALUE HOME LOAN, INC.
Plaintiff
vs.
STEVEN M. ZEIGLER
MARSHA J. ZEIGLER
Defendants
COURT OF COMMON PLEAS
TRIAL DIVISION
CUMBERLAND COUNTY
No.: 08-77 Civil Term
PRAECIPE TO DISMISS COMPLAINT WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly DISMISS the Complaint without prejudice with respect to the above-
captioned matter.
Date: May 21, 2008 7Esquii
Gr o Jav ian
e
orney f lain
C> rv
r-a C
- IT
?' aJ
C.,.
>
. zo