HomeMy WebLinkAbout08-1680IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS CIVIL DIVISION
a division of FIRST TENNESSEE
BANK, NATIONAL ASSOCIATION,
NO.: OB- ilo8o ?IV, t Term
Plaintiff,
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
TYPE OF PLEADING
Defendants.
TO: DEFENDANT(S)
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOS COMPLAINT WITHIN TWENTY (20) DAYS
FROM SE VICr REOF s4 DE /CULT JUDGMENT
MAYBE NTE AGA sT nr rJ 1
ATTOIY F R P ?/
I THEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
6522 Chapma Highway
Knoxville, 37902
AND THE iKA (S
4502 W s
Mecha 1705 _
I HERE BTH TI LOON OF
THE REBY T LIEN IS
4502 W M chbur PA 17055
CIVIL ACTION - COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF:
First Horizon Home Loans, a division of
First Tennessee Bank, National Association,
Plaintiff
COUNSEL OF RECORD FOR THIS
PARTY:
Scott A. Dietterick, Esquire
Pa. I.D. #55650
Kimberly A. Bonner, Esquire
Pa. I.D. #89705
JAMES, SMITH, DIETTERICK &
CONNELLY LLP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
A
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.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN
ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL
ESTATE.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of : CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff,
NO.: D F- /G Fd C,?,d
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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 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 SHOULD
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of : CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff,
NO..
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
AVISO
USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los
proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comperencencia escrita-y redicanco en la Courte
por escrito sus defensas de, y objecciones a, los 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 contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos
importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO RVIMEDIATAMENTE. SI
USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A
LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR
ASISTENCIA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of : CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION, ;
Plaintiff, : NO : (9 g- /6,0 -]-u,W,,
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes First Horizon Home Loans, a division of First Tennessee Bank, National
Association, by its attorneys, James, Smith, Dietterick & Connelly LLP, and files this Complaint
in Mortgage Foreclosure as follows:
1. The Plaintiff is First Horizon Home Loans, a division of First Tennessee Bank,
National Association, which has its principal place of business at 6522 Chapman Highway,
Knoxville, Tennessee 37920.
2. The Defendants, Jeremy S. Christian and Sherry Christian, are adult individuals
whose last known address is 4502 Woods Way, Mechanicsburg, Pennsylvania 17055.
3. On or about November 30, 2005, Defendant, Jeremy S. Christian executed a Note
in favor of Plaintiff in the original principal amount of $64,876.00. A true and correct copy of
said Note is marked Exhibit "A", attached hereto and made a part hereof.
4. On or about November 30, 2005, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to Plaintiff a Mortgage in the original principal amount
of $64,876.00 on the premises hereinafter described, with said Mortgage being recorded in the
Office of the Recorder of Deeds of Cumberland County on December 22, 2005, in Mortgage
Book Volume 1935, Page 2163. A true and correct copy of said Mortgage containing a
description of the premises subject to said Mortgage is marked Exhibit "B", attached hereto and
made a part hereof.
5. Defendants are the record and real owners of the aforesaid mortgaged premises.
6. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due.
7. On or about February 4, 2008, Defendants were mailed combined Notices of
Homeowners' Emergency Mortgage Assistance Act of 1983 and Notices of Intention to
Foreclose Mortgage, in compliance with the Homeowner's Emergency Mortgage Assistance Act,
Act 91 of 1983 and Act 6 of 1974, 41 P.S. § 101, et seq. True and correct copies of said Notices
are marked Exhibit "C", attached hereto and made a part hereof.
8. The amount due and owing Plaintiff by Defendants is as follows:
Principal $ 64,124.13
Interest through 3/11/2008 $ 4,211.68
Late Charges $ 399.11
Property Inspections $ 95.00
Attorney's Fees $ 1,325.00
Court, Sheriff & Title Costs $ 2,500.00
TOTAL $ 72,654.92
plus interest on the principal sum ($64,124.13) from March 11, 2008, at the rate of $15.05 per
diem, plus additional late charges, and costs (including additional escrow advances), additional
attorneys' fees and costs and for foreclosure and sale of the mortgaged premises.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $72,654.92, with interest thereon at the rate of $15.05 per diem from March 11, 2008 plus
additional late charges, and costs (including additional escrow advances), additional attorneys'
fees and costs and for foreclosure and sale of the mortgaged premises.
& CONNELLY LLP
Kimberly A. Bonner, Esquire
PA I.D. # 89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
PA I.D. # 55650
EXHIBIT "A"
0056342272 10
BALLOON NOTE
Mixed Rate)
THIS LOAN IS PAYABLE IN FULL AT MATURITY. YOU MUST REPAY THE ENTIRE PRINCIPAL
BALANCE OF THE LOAN AND UNPAID INTEREST THEN Dim, NO
OBLIGATION TO REFINANCE THE LOAN AT THAT TIME, YOU W1LL,LENDERlSR?UNDER?, BE
REQUIRED TO MAKE PAYMENT OUT OF OTE= ASSETS THAT YOU MAY OWN, OR YOU WML
HAVE TO FIND A LENDER, WIHCB MAY BE THE LENDER YOU HAVE THIS LOAN WrM,
WILLING TO LEND YOU THE MONEY. IF YOU REFINANCE THIS LOAN AT MATURITY, YOU
MAY HAVE TO PAY SOME OR ALL OF THE CLOSING COSTS NORMALLY ASSOCIATED WITH A
NEW LOAN EVEN IF YOU OBTAIN REFINANCING FROM TILE SAME LENDER
November 30th, 2005 STSWARTSTOWN
PltNNSYLvANIA
Date City
State
4502 WOODS WAY, MSCRANICSBttRG, PA 17055
Property Address
I. BORROWER'S PROMISE TO PAY
In return for a loan that I have received, I promise to pay U.S. $ 64, 876.00
Will be called "principal"), plus interest, to the order of the tender. The Lender is (this amount
FIRST HORIZON Wn LOAN CORPORATION
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and
who is entitled to receive Payments under this Note will be called the "Note Holder."
2. INTEREST
I will pay interest at a yearly rate of 8.500
Interest will be charged on unpaid principal until tie full amount of principal has been paid.
3. PAYMENTS
(A) Tittle and Place of Payments
I will pay Principal and interest by making payer each month of U.S, $ 498.85
I will make my payments on the lot day of ead month beginning on Jas
I will make ibex payments every month until I have paid all of the g easy an der
charges, described below, that I may owe under this Note, if, on DDoamber and laat. 020 any other
1 still awe amounts under this Note, 1 will pay all those amounts, In foil, on that date.
I will make my monddy payments at PO BOX 31
minPHIS • TN 38101
(B) Amount of Monthly Payments or at a tlifferertt place if required by the Note Holder.
$ My monthly payment38 ll be in the amount of U.S. S 498.85
with a balloon payment of
4. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received tie full amount of any of my monthly payments by the end of 13
calendar days
0 ? Oft the date it is due, I will b of m overdue pay a lam ?e to the Note Holder. The amount of the charge will
U.S. $ 00A y payment, but note less that U.S.$ 20.00 and not more than
I will pay this late charge only once an any late Payment.
(B) Default
If I do not pay the full amount of each monthly payment by the date stated in Section 3 above, I will be in
default.
Even if, at a tiros when I am in default, the Note Holder does not rquiru me to pay immediately in full as
described below, the Note Holder will still have the right m do so if I am in default at a later time.
(C) Notice from the Note Holder
If I am in default, the Note Holder may send the a written notice telling me that if I do am
amount by a certain date the Note Holder may require we to
Pay Pri the overdue
has not been paid and all the Interest that I owe on that' imThe rueat most be a l 30 the full amount a prncipal which
ys after the date
on which the notice is mailed to are or, if it is not mailed, ?30 dda? ay s after the date on which is delivered to inc.
PA 2" Baloon Note
FH6D t 1F Page n of 3 tn+irt:
9/Cf
1A PAyrwxt of Note-Holder's Cost and Expenses
° If the Note Holder has required me to pay Immediately in full as described above, the Now Holder will
have the right to be paid back for all of its costs and expe Those expenses include, for example, reasonable
nses to the extern not prohibited by applicable law.
5. THIS NOTE SECURED BY AA MORTTGAGE attorneys, fees:
In addition to the protecdons given to the Note Holder under this Now, a Mortgage, dated
November 30th. 2005 protects the Note Holder from
result if I do not keep the promises which I make in this Note. That M passible lasses which might
conditions I may be required to make ' age describes how and under what
6. BORROWER'S PAYMENTS BEFORE e1' pgymm Y ARE DUE DUUfWI Eof all atnoums that I owe under this Note.
I have the right to make payments of principal at any time before
known as a "ProWymcm." When l make a d1CY are due. A Payment of principal only is
PTePaYMOnt, I will tell the Note Holder in a letter that I am doing so.
A Prepayment of all of the unpaid principal is known as a "full prepay tnem." A Propaymem of only a part of the
unpaid principal is known as a "partial prepayment."
s may make a full Prepayment or a partial prepayment without paying any penalty. The Note Holder will use
ail of my prrpsryltts to reduce the amount of Principal prepayment, there will be no delays in the due dates or chhart? 1 ° under this Note. If I make 8 partial
the Note Holder agree$ in wrid ? to g? in the amounts of my monthly payments unless
1 may make a full ? those decays or changes.
Prepayment at any date. If I choose to matte a partial prepayment, the Note Holder may
require me to matte the Prepayment on the swo dry that one of m month!
Wray also require that the amount of my partial y Y payments is due. The Note Holder
been pan of my next era or more monthly p to the amount of principa] that would have
7. BORROWER'S WAIVERS y taYments.
I waive my rights to require the Note Holder to do certain things. Those things are; (A) to demand
of amounts due (known as "presentment'); (B) to give notice that amounts due have not been paid no nas
"notice of dishonor"); (C) to obtain an official certification of nonpayment " " . (known as
who agrees to keep the promises mace in this Note, or who agrees to mgic (brawn as a protest ). Anyone ease
to keep my promises under this Now, or who signs this Note to transfer rpt ato someot ne else also waives these
rights. These persons are known as "guarantors, sureties and endorsers.-
8. GIVING OF NOTICES
Any notice that must be given to me under this Note will be given by delivering or mai
mail addressed to me at the it lirtr it by certified
Property Address above. A notice will be delivered or mailed to me at a difftem.
address if I give the Note Holder a notice of my different address.
Any notice that must be given to die Note Holder under this Note will be given by mailing it by certified mail
to the Note Holder at the address stated in Section' 3 above, A notice will be mailed to the Note Holder at a
different address if I am given a notice of that different address
9. RESPONSIBILITY OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each of us is fully and
owed and to keep all of the promises made in this Note. An personally obligated to pay the full amount
described in Section 7 above) 1s also obligated Y guarantor, surety, or endorser of this Note as
thi
des Note against each is bated to do these things. The Note Holder may enforce Its rights under of us urged to vor against all of us together. This meats that any one of us may be
1e9 pay all of the amounts owed under this Note. Any person who takes over my rights or obligations
under this Note will have all of my rights and must keep all of my promises made in this Note. A
cakes over the rights or obligations of a my person who
cantor' surety, or endorser of this Now {as described in Section 7
above) is also obligated to keep all of the promises node in this W.
THIS OBLIGATION MAY E THE BASIS FORoA PERSONAL ACTION AGAVW THE
PROMISOR OR PROMISORS IN ADDITION TO OTHER REMEDIES ALLOWED BY LAW.
Pw 4]2 Tors
FH6D 110 Peas 2 of 3 rni".
9/03
• 11 - (
(W
ISTIAN -Borrower -Borrower
(Seal)
-Borrower
(Scat)
-Borrower
(SW)
-Borrower
(Sul)
-Borrower
-Borrower
(Seal)
-Borrower
(Sign Original Only)
0056342271
PA 21rD BaUooq Noss
FFi6D1 Ili Pus 3 of 3 9103
EXHIBIT "B"
ItEMO AND RMIN TO , .
eENTmPROPERTttSEAM 5 C?C 22 FR 2 1
9 M" AVEKUE SURE 200
NORRISTOWN^ 19403
33114"'2
Prepared Br.
FIRST HORIZON HOME LOAN CORPORATION
9515 DSYRBCO ROAD, STY 301
TIMNnM, ND 21093
FkmnrrTe:
1rHHLC - POST CLOSING MAIL ROOM
•
e
1SSS W. WALNI}T HILL LN. #200 MC 6712
IRVING, TX 75038
-3 -L9 NP k
Parcel Number County_ Premises: 4502 HOODS WAY
City:131 O ?rJ O MECHANICSBURG, Peaasylvaaia 17055
1 c AAow TAb Lihe For RecordliK Data)
MORTGAGE 0056341172
THIS MORTGAGE is made this 30th day of November, 2005 , between the Mortgagor,
JRRMff S. CHRISTIAN and SHERRY CHRISTIAN husband and wife
(herein "Bormwexl. and the Mortgagee.
FIRST HORIZON HM LOAN CORPORATION
. a corporation organized and
existing under the laws of THE STAT$ OF 1tANSA3 , whose address is
4000 Morison Kay, IRVING, TX 73063
(hadn "Lander")
WFWREAS, Borrower is indebted to Lander in the principal sum of U.S. S 64, 876.00,
which indebtedness is evidenced by Sorrowces note dated November 90th, 2005 and
extensions and renewals thereof (t rin "Note"), providing for monthly installments of
principal and interest, with the balance of the indebtedness, if not sooner paid, due and payable on
December lot, 2020 ;
TO SECURE to Lender the repayment of the indebtodtM evidenced by the Note. with interest thereon;
the payment of all other sums, with interest tbervon, advanced in accordance herewith to protean the se?vdty
of this Mortgage; and the performance of the covenants and agreements of Borrower herein contained,
PENNSYLVANIA - SECOND MO DE - Iiso - FNMA/PHLMC UNIFORM U?t8TRUMENT
ft76(PA) tosott For
Page 1 of IMthh:
YRtV MOftp016 8oMn[ons, (nC Ie00n521• Y
BK1935PG2163
Bwowcr does hereby mortgage, giant. and convey to Leader the following described property
totaled in the County of Chlraberlaad
State of Pennsylvania: '
BRING ]UNO t'N AND DRSX=hTRD AS LOT NO. 18, AS SHOW ON A PLAN BNTITLRD
•THR KhXOR OF WUTPORT', WRICH PLAN 13 RECORDED XRONG THE OFFICE OF
THS RECORDER OF DREDB IN AND FOR CUMBERLAND COUNTY, P8NMMVANIA,
IN PLAN BOOK 89, PAGE 143.
THE IMROVRICWS THEREON BEING 1trKM AS 4501 WOODS WAY.
which has the address of 4502 WOODS WAY Istmal
MECHANICSBURG (Cityl, Pennsylvania 17055 IMMOdel
(herein "Property Address");
TOGETM with all the improvements now or hereafter erected on the property, ad all easements,
rights, appurtenances and rents, all of which shall be deemed to be and remain a part of the property coveted
by this Mortgage: and all of the foregoing, together with said property (or the leasehold estate if this
Mortgage is on a leasehold) are berebufter referred to as the "Propety."
Borrower covenants that Borrower is lawfully seised of the estate hereby conveyed and has the right to
mortgage. grant and convey the Property, and that the Proputy is unencumbered, except for encumbrances. of
record. Borrower covenants that Borrower warrants and will defend generally the title to the Property against
all claims and demands, subject to encumbrances of record.
UNIFORM COVENANTS. Borrowea and Lander covenant and agree as follows:
1. Payment of Principal and Interest. Borrower shalt promptly pay when due the principal and
interest indebtedness evidenced by the Note and lace charges as provided in the Note.
2. Funds for Taxes and lnsaranca, Subject to applicable law or a wrium waiver by Lender. Borrower
shall pay to Lender on the day monthly payments of principal and interest are payable under the Note, until
the Note is paid in full, a aunt (herein 'Funds`) equal to one-twelfth of the yearly was and asse ssmeats
(including condominium and planned unit development asmssmeas, if any) which may attain priority over
this Mortgage and ground teats on the Property, if any, plus one-twelfth of yearly premium instaliments for
hazard insurance, plus one:-twelfth of yearly promiwn install matts for mongage insurance, if any, all as
reasonably estimated initially and from time to time by Lander on tho basis of assesonots and bills and
reasonable estimates thereof. Borrower shall not be obligated to make such payments of Amb to Lender to
the extent that Borrower makes such payments t0 the holder of a prior mortgage or decd of treat if stO
holder is an institutional lender.
0056342271 IettWs:
WNPA) tosmi Pogo z or a Fernt 9a3s
B'['% i935PG2164
rJ
If Borrower pays Funds to Lender, the foods shall be held in an institution the deposits or accounts of
which are insured or guaranteed by a federal or state agency (incudin; Lender if Lender is such an
institution). Iaider shall apply the Funds to pay said taxes, assessments, rhstm im premiums and ground
rents. Lender may not charge for so holding and applying the Funds, analyzing said account or verifying and
comp"g said assessments and bills, unless Lender pays Borrower inmernst on the Funds and applicable law
permits Lender lo make such a chBorrower and Lender may agree is writing at the time of execution of
this Mortgage that interest on the Ainds shall be paid to Borrower, and cutlass such agreement is made or
applicable law requim such is mmt to be paid, Lender shall not be required to pay Borrower any intaest or
earnings on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds
showing credits and debits to the Funds and the purpose for which each debit to the Funds was made. Ilse
Funds are pledged as additional security for the sums secured by this Mortgage.
If die amount of the Funds held by Lander. together with the future monthly insiailmeus of Funds
payable prior to dnc due dates of taxes, assessments, insurance premiums and ground raps. shall exceed the
amount required to pay said taxes, assessments, insuance premiums and ground cam as they fall due. such
excess 00 be, at Borrower's option, either promptly repaid to Borrower or credited to Borrower on monthly
installments of Funds. If the aanount of the Funds MM by Lander shall not be sufficient m pay rarer,
assessments. insurance premiums and ground rents as they fall due, Borrower shall pay to Lender any amount
necessary to make up the deficiency in one or more payments as Lander may requires
Upon payment in full of all stns secured by this Mortgage. Lender shall promptly refund to Borrower
any Funds held by Lender. If under paragraph 17 hered the Property is sold or the Property is otherwise
acquired by Lander. Lender shall apply, no later than iaumediately prior to the We of the Property or its
acquisition by Lender, any Funds held by Lender at the time of application as a credit against the sutra
secured by this Mortgage,
3. Application of Paymoems. Unless applicable law provides otherwise, all payments received by
Lender under the Note and paragraphs 1 and 2 hereof shall be applied by Lender first in payment of amounts
payable to Lender by Borrower under paragraph 2 hereof. then to interest payaw on the Now, and then to
the principal of the Now.
4. Prior Mortgages and Deeds of Trust; Charges; Liens. Borrower shall perform all of Borrower's
obligations under any mortgage, deed of trust or other security agreement with a lien which has priority over
this Mortgage, including Borrower's covenants to mate payments when due. Borrower shall pay or cause to
be paid all taxm assessments and other charges, fees and imposidons attributable to the Property which may
attain a priority over this Mortgage, and leasehold payments or ground tents, if any.
5. Hazard Insurance. Borrower shall keep the improvements now existing or hereafter eructed on the
Property insured against loss by fire, hazards included within the term "extended coverag<w' and such other
hazards as Lender may require and in such amounts and for such periods as Lander may require.
T'ic insunu" carrier providing the insurance shall be chosen by Borrower subject to approval by
Lander. provided, dot such approval shall not be unreasonably withhold. AU insuamx policies and renewals
thereof shall be in a form acceptable to Lender and shall include a standard mortgage claim in favor of and in
a form acceptable to Lender. Lacer shall have the right to hold the policies and renewals thereof, subject to
the terms of any rnortgagk deed of trust or other security agroemeat with a lien which has priority over this
Mortgage.
In the event of loss, Borrower shall give prompt notice to the i nstuance carrier and Lender. Lender may
make proof of loss if not trade promptly by Borrower.
0056342272
OR-76(PA) wsa2)
P"O 9da
SK1935PG2165
InM
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i
If the Property is abandoned by Borrower, or if Borrower faits to respond to Lender within 30 days
from the date notice is mailed by Lender to Borrower that the insurances carrier offers to settle a claim for
insurance benefits. Lender is audxxized to collect soil apply the insurance proceeds at Lender's option either
to restoration or repair of the Property or to the sums secured by this Mortgage.
6. Preservation and Maintenance of Property; Leaseholds; Cwtdominiu ms; Planned Unit
Developments. Borrower shall keep the Property in good ter and shall not commit waste of pcmdt
impairment or deterioration of the Property and shell comply with the provisions of any lease if this Mortgage
is on a leasehold: If this Mortgage is on a unit in a condotttinim ors planned unit development, Borrower
shall perform all of Borrower's obligations unda the de lamdon or covenants creating or governing the
condominium or planned unit development, the by-haws and regulations of the condominium at planned unit
developmaiL and constituent documems.
7. Protection of Leader's Security. If Borrower fags to perform the covenants and agreements
contained in this Mortgage, or if any action or proceeding is commenced which materially affaas Lender's
interest in the Property, then Lender, at Lender's option. upon notice to Borrower, may make such
appearances, disburse such sums, including reasonable attorneys' fees. and take Such action as is necessary to
protect Lender's interest If gander requited mortgage insurance as a condition of making the loan secured by
this Mortgage, Borrower shalt puny the premiums required to maintain such insurance in effect until such time
as the requirement for such instance terminates in accordance with Borrower's and L ender's written
agreement or applicable law.
Any amounts disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the Note rate,
shall become additional indebtedness of Borrower seared by this Mortgage. Unless Borrower and Lender
agree to other terms of payment, such amounts shall be payable: upon notice from Lender to Borrower
requesting payment drereof. Nothing contained in this paragraph 7 shalt require Deluder to incur any expense
or take any action hereunder.
8. Inspection. Lender may make or cause to be trade reasonable entries upon and inspections of the
Property, provided that Leader shall give Borrower notice prior to any such inspection specifying reasonable
cause therefor related to Leader's interest in the Property.
9. Condemnation. The proceeds of any award or claim for damages, direct, or consequauial, in
connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in lieu
of condemnation, are hereby assigned and shall be paid to Lem, subject to the terms of any mortgage, deed
of trust or other security agreement with a lien which has priority over this Mortgage.
10. Borrower Not Released; Forbearance By Lewder Not a Waiver. Extension of the time for
payment or modification, of amortization of the stuns secured by this Mortgage granted by I.eadax to any
successor in i nterea of Borrower shall not operate to release, in any manner, the liability of the original
Borrower and Borrower's successors in interred, Lender shall not be requited to commence proceedings
against such successor or refuse to extend time for payment or otherwise modify amortization of the sums
secured by this Mortgage by reason of any demand made by the original Borrower and Borrower's
successors in interact. Any forbearance by Lender in exercising arty right or remedy hereunder, or otherwise
afforded by applicable law, still not be a waiver of or preclude fie exercise of any such right or remedy.
0056312272
t76(PA) tosozt
Pays 4 of 4
81?1935PGZ165
iakiali:
a?m $639
11. Successors and Asaips Bound; Joint and Several Liabitlty; Co-signers. The covenants and
agreements herein contained shall bind. and the rights haetuder shall inters to, dire respective successors and
assigns of Lender and Borrower, subject to the provisions of pwagraph 16 beteof. AB covenants and
agreements of Borrower shall be, joint and several. Any Borrower who co-signs this Moetpge, but does not
execute the Now, (a) is co-signing this Mortgage only to mortgage, grant and convey that Borrower's interest
in the Property to Lender under the tams of this Mortgage, (b) is not personally liable on the Note. or adder
this Mortgage, and (c) agrees that ]ender and any other Borrower ha w nder may agree to exterd, modify,
forbear, or make any other accommodations with regard to the teams of this Mortgage or the Note without
that Borrower's consent and without mkasing that Borrower or modifying this Mortgage as to that
Borrower's interest in the Property.
12. Notice. Saoepi for any notice requited under applicable law to be given in another manner, (a) any
notice to Bom war provided for in this Mortgage shall be given by delivering it or by mailing such notice by
certif'A mail addressed to Borrower at the Property Address of at such other address as Borrower may
designate by notice to Lender as provided herein, and (b) any notice to Lender shall be given by certified mail
to Lender's address stated herein or to such other address as Lender may designate by notice to Borrower as
provided herein. Any notice provided for in this Mortgage shall be deemed to have been given to Borrower
or Lender when given in the manner designated herein.
13. Governing Law, Severabilitr. The state and local laws applicable to this Mortgage shall be the
laws of the jurisdiction in which the Property is located. The foregoing sentence shall not limit the
applicability of federal law to this Mortgage. In the event that any provision or clause of this Mortgage or the
Note conflicts with applicable law, such conflict shall not affect other provisions of this Mortgage or the Note
which can be given effect without the conflicting provision, and to this and the provisions of this Mortgage
and the Note are declared to be severable. As used herein, "costs," "expenses" and "auorneys' fees" include
all scans to the extent not prohibited by applicable law of limited herein.
14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this Mortgage
at the time of execution or after recordation hereof.
15. Rehabilitation Loan Agreeatent. Borrower " fulfill all of Borrower's obligations under any
home rdwbilkation. impmvennent, repair, or odner loam agreement which Borrower enters into with Lender.
Lender, at Lender's option, may require Borrower to execute and deliver to Lender, in a form acceptable to
Lender, an assignment of any rights, claims or defenses which Bwower may have against parties who supply
labor, materials or services in connection with improvements made to the Property.
16. Transfer of the Property or n Beneficial Interest in Borrower. If all or any part of the Property
or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or vainsferred and
Borrower is not a natural person) without Lender's prior written consent. Lender may, at its option, require
immediate payment in full of all sums secured by this Mortgage. However, this option shall not be exercised
by Lender if exercise is prohibited by fedasi law as of the date of this Mortgage.
If Lender exercises this option, sender shall give Borrower notice of acceleration. The notice shall
provide a period of not less than 30 days from the date the notice is delivered or mailed within which
Borrower must pay all sums secured by this Mortgage. If Borrower fails to pay these sums prior to the
expiration of this period, Lender may invoke any remedies pertnitled by this Mortgage without further notice
or demand on Borrower.
0056341271
4%-76(PA) (ow2i Pape s of a
6K1935PG2167
InHla
4-F-O-rm 3899
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
17. Acceleration; Remedies. Upon Borrower's breach of any covenant or agreement of Borrower
in this Mortgage, including the covenants to pay when due any sums second by this Mortgage, leader
prior to acceleration shall give notice to Borrower as provided by applicable law specHAM, among
other thiogs: (1) the breach; (2) the action required to cure such breach; (3) a date,not less then 30
days from the date the notice Is mailed to Borrower, by which such breach mast be cured; and (4) that
failure to cure such breach on or before the date specified In the notice may result In acceleration of the
sums secured by this Mortgage, foreclosure by judicial proceeding, and sak of the Property. The notice
shall further inform Borrower of the right to reinstate after acceleration sod the right to assert in the
foreclosure proceeding the nonexistence of s default or any other defense of Borrower to acceleration
and foreclosure. If the breach is not cured on or before the date specified in the notice, Lender, at
Lender's option, may declare all of the sums secured by this Mortgage to be immediately due and
payable witbout farther demand and may foreclose this Mortgage by judicial proceeding. Lender shalt
be entitled to collect in such proceeding all expenses of foreclosure, Including, but not limited to,
reasonable attorneys' fees, and costs of documentary evidence, abstracts and title reports.
18. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums secured by this
Mortgage due to Borrower's breach. Borrower shall have the right to have any proooedings begun by Latch
to enforce this Mortgage discontinued at any time prim to at least one hour before the commencement of
bidding at a sheriff's sale or other sale pursuant to this Mortgage it, (a) Borrower pays !.ender all sums which
would be then due under this Mortgage and the Now had no acceleaation occurred; (b) Borrower cures all
breaches of nay other covenants or agrmnents of Borrower contained in this Mortgage; (c) Borrower pays all
rrasonabiF incurred by Lender in enforcing the coveatarits and agreements of Borrower voamincd in
this Mortn enforcing Lender's teatedies erg provided in paragraph 17 hereof, indudling, but not
limited toe action as Lender may reasonably require
to n oand Borrower's obligation to pay the
s h payment and cure by Borrower, this
Me bligations accrued hereby abet! remain in full force and effect as if no acceleration had
occurred.
19. Assignment of Rents; Appointment of Receiver; Lender in Possession. As additional security
hereunder, Borrower hereby assigns to Leader the rents of the Property, provided that Borrower shall, prior
to acceleration under paragraph 17 bereof or abandonment of the Property, have the right to collect and retain
such rents as they become dun and payable.
Upon acceleration under paragraph 17 hereof or abandonment of the Property, Leader, in person, by
agent or by judicially appoWW receiver shall be entitled to otter upon, take possession of and aaanage the
Property and to collect the teats of the Property including those past date. All rents collected by Lander or the
receiver shalt be am lied first to payment of the costs of manapemett of the Property and collection of rents,
including, but not litaited to, receiver's fees, praniuttts on receiver's bond arse! rdasotteble attorneys' fees, and
then to the sums secured by this Mortgage. Leader and the receiver shall be liable to account only for those
tents actually received,
20. Release. Upon payment of all sums secured by this Mortgage, Lender shall dkharge without charge to Botmwer. Borrower shalt pay all costs of this Mortgage
recordation, if any.
21. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be die rate stated in the Note.
00563!2272
Inri
et-TO(PA) tnsoza Papa t oft orm 8839
BKI935PG2168
REQUEST FOR NOTICE OF DEFAULT
AND FORECLOSURE UNDER SUPERIOR
MORTGAGES OR DEEDS OF TRUST
Borrower and Lender request the holder of any mortgage, deed of oust or other encumbm= with a lien
which has priority over this Mortgage to give Notice to Lender, at Leader's address set forth on page one of
Nis Mortgage, of any default under the superior encumbra m and of any sale or other foreclosure action.
IN WITNESS WHEREOF Borrower has r: mumd this. Mn"anve
(Seat)
In wer
&:?Seat)
HSRRY C ISTIAN -Borrower
- (Seat)
-Bonewer
(Seat)
-Besower
(Seat)
-Borrower
- (seal)
-Borrower
(Sign Original Only)
0056342172
76(PA)in)
(Sod)
-Borrower
(sag)
-Borrower
Pago 7 or a
Forts 38351
BKI935PG2169
COMMONWEALTH OF PENNSYLV , YORX County Sc
On ibis, the ? day c ( d81? 7VX9J, bcfbm me, the wndasigned officer,
personally appeared JSRZ= S. CHRISTIAN and SHERRY CHRISTIAN
known to me (or satisfactorily proven) to be the
person(s) whose name(s) L%hwe subscribed to the within instniment and acknowledged that he/shNlhey
executed the some for the purposes herein contained.
IN WITNESS WHEREOF. I hereunto set my band and official Seal.
My Commission Expires: /?l?sr Ddb
?. Fnat.a .' tyn ?'rMic
• +, 'urk Counr
r ?? A400'.1 ? 4Ac L.
Thle of Offi=r-
Certificate Resitimce
1, r..AW'A4? ?: 4V V44
the correct addressor the within-named Lenda is 4000 SORIZOIt WAY,
Witness my hand this 3tlw day of w?
Nolsf ut 8ml
Fnwk.l. Hack. Nourv Public
9krws"tmvn hero, le'hCaOMY
My Commk4w Fxpim Dm 2& 2006
i'eml vav ks-k4 ton
U56342272
W7$(PA) roso4 Pp• e of a
BK t 935PG2170
inpq
o?m 3939
. do herby certify that
IRVING, T8 75063
EXHIBIT A
BEING KNOWN AND DESIGNATED as Lot No. 18, as shown on a Plan entided "Thc Manor of Westport". which Plan
is recorded among the Office of the Recorderof Deeds in and for Cumberbmd County, Pennsylvania, in Plan Book 89, Page
143.
The improvements thereon to be known as 4502 Woods Way.
Parcel ID No. 13-10-0256.063
i 8K 1935PG2171
0
BALLOON PAYMENT RIDER
TO THE SECURITY INSTRUMENT
Borrower Name: JWU= S. CHRISTIAN
1
Property Address: 4502 WMS WAY
N2CRAN=CSMMG, PA 17055
Loam Number: 0055342272
THE TERMS OF THE. LOAN CONTAIN PROVISIONS WHICH WILL REQUIRE A BALLOON PAYMENT
AT MATURITY.
THE AMORTIZATION OF PRINCIPAL AND INTEREST IS BASED ON A 30 YEAR FACTOR AND
WOULD AMORTIZE THE PRINCIPAL LOAN ON A 30 YEAR SCHEDULE, BUT SINCE THE FULL
BALANCE IS PAYABLE IN 180 MONTHS, A BALLOON PAYMENT OF $ 51,152.38 WILL
BE REQUIREDON December 1st , 2020
The loan is payable in full at the end of 15 years. You must repay the entire principal balance of the
loan and the unpaid interest then due. The lender is under no obligation to refunm= the loan at that time. You
will, therefore, be required to make payment out of other assets you may own, or you will have to find a leader
willing io tend you the money at the prevailing market rate, which may be considerably higher or lower than the
rate on this loan.
If you refinance this loan at maturity, you may have to pay some or all closing costs normally associated with a
new loan, even if you obtain refinancing from the same lender.
I/We hereby acknowledge receipt of the above notice relating to the balloon payment provision of this loan, which
have also been a ined to mclus.
(ml) (Seal)
S IAN . -Borrowtr
-Borrower
AA Jz&a& (Seal) (Sad)
SHERR CHRISTIAN -Borruwr -Borrower
(Seal) (Sed)
-sorro`Mef -Borrower
(SUD ()
Bonwoff -9oero.er
Banton Payums Rider - No CRR 0605 PW 1 or I D03R
BKI935PG2172
0
PLANNED UNIT DEVELOPMENT RIDER
THIS PLANNED UNIT DEVELOPMENT RIDER Is made this 30th day of
November, 2003 , and is incorporated into and shall be
deemed to amend and supplement the Mortgage, Deed of Trust or Security Deed (the
"Security Instrument') of the same date, given by the undersigned (the "Borrower") to
secure Borrower's Note to
FIRST HORIZON sONZ LOAN CORPORATION
(the "Lender") of the same date and covering the Property described in the Security
instrument and located at:
4502 WOODS WAY, t1RCHANICS3=G, Pennsylvania 17035
[Property Address)
The Property includes, but is not limited to, a parcel of land Improved with a dwelling,
together with other such parcels and certain common areas and facilities, as described in
(the "Declaration"). The Property is a part of a planned unit development known as
THE MANOR Or WXSTPORT
[Name of Planned Unit Development)
(the "PUD"). The Property also includes Borrower's interest In the homeowners association
or equivalent entity owning or managing the common areas and facilities of the PUD (the
"Owners Association") and the uses, benefits and proceeds of Borrower's interest-
PUD COVENANTS. In addition to the covenants and agreements made in the Security
Instrument, Borrower and Lender further covenant and agree as follows:
A. PUD Obligations. Borrower shall perform all of Borrower's obligations under the
PUD's Constituent Documents. The 'Constituent Documents" are the: (i) Declaration; (ii)
articles of incorporation, trust Instrument or any equivalent document which creates the
Owners Association; and (III) any by-laws or other rules or regulations of the Owners
Association. Borrower shall promptly pay, when due, all dues and assessments imposed
pursuant to the Constituent Documents.
0056312372
MULTISTATE PUD RIDER - Single Family/Second Mortgage 3188
Page 1 of 3 initials:
et-207R (0411) VMP Mortgage Solutions, Inc. (800)521.7291 4. ?
BKI935PG2173
B. Hazard Insurance. So long as the Owners Association maintains, with a generally
accepted insurance carrier, a "master" or "blanket" policy insuring the Property which is
satisfactory to Lender and which provides insurance coverage In the amounts (including
deductible levels), for the periods, and against loss by fire, hazards included within the term
"extended coverage,' and any other hazards, including, but not limited to, earthquakes and
floods, for which Lender requires insurance, then: (i) Lender waives the provision in
Uniform Covenant 2 for the monthly payment to Lender of the yearly premium installments
for hazard insurance on the Property; and (ii) Borrower's obligation under Uniform
Covenant 5 to maintain hazard Insurance coverage on the Property Is deemed satisfied to
the extent that the required coverage is provided by the fawners Association policy.
What Lender requires as a condition of this waiver can change during the term of the
loan.
Borrower shall give Lender prompt notice of any lapse in required hazard insurance
coverage provided by the master or blanket policy.
In the event of a distribution of hazard insurance proceeds in lieu of restoration or
repair following a toss to the Property, or to common areas and facilities of the PUD, any
proceeds payable to Borrower are hereby assigned and shall be paid to Lender. Lender,
shall apply the proceeds to the sums secured by the Security Instrument, whether or not
then due, with the excess, if any, paid to Borrower.
C. Public Liability Insurance. Borrower shall take such actions as may be reasonable
to insure that the Owners Association maintains a public liability insurance policy
acceptable in form, amount, and extent of coverage to Lender.
D. Condemnation. The proceeds of any award or claim for damages, direct or
consequential, payable to Borrower in connection with any condemnation or other taking of
all or any part of the Property or the common areas and facilities of the PUD, or for any
conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender. Such
proceeds shall be applied by Lender to the sums secured by the Security Instrument as
provided in Uniform Covenant 9.
E. Lender's Prior Consent. Borrower shall not, except after notice to Lender and with
Lender's prior written consent, either partition or subdivide the Property or consent to., (f)
the abandonment or termination of the PUD, except for abandonment or termination
required by law in the case of substantial destruction by fire or other casualty or in the case
of a taking by condemnation or eminent domain; (fi) any amendment to any provision of the
'Constituent Documents" If the provision is for the express benefit of Lender; (iii)
termination of professional management and assumption of self-management of the
Owners Association; or (iv) any action which would have the effect of rende ' the public
liability insurance coverage maintained by the Owners Association unaccep le Lender.
et-207R (0411) Page 2 of 3 initials:
0911- . 3199
BKI935PG2174
I
•
F. Remedies. If Borrower does not pay PUD dues and assessments when due, then
Lender may pay them. Any amounts disbursed by Lender under this paragraph F shall
become additional debt of Borrower secured by the Security Instrument. Unless Borrower
and Lender agree to other terms of payment, these amounts shall bear interest trom the
date of disbursement at the Note rate and shall be payable, with Interest, upon notice from
Lender to Borrower requesting payment.
BY SIGNI BELOW, Borrower accepts and agrees to the terms and covenants contained
this PU er.
(Seaq (Seal)
JL?ff TTSTIAN -Borrower -Borrower
4 "LL Seal) (Seal)
SHERRY CH STIAN -Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
0056342272
Ck-207 R (4411)
- (Seal) (Seal)
-Borrower -Borrower
Page 3 of 3
3199
8KI935PG2175
RIDER TO DEED OF TRUST/MORTGAGE/SECURITY DEED
0056341272
Date: 11/30/2005
The escrow of taus and insuraum required in Paragraph 2 of your DEED OF
TRUST/MORTGAGE/SECURTTY DEED to
7IRST HDRIZON B01W LOAD cORpORATION
is hereby waived and you are notified that you are not requited to deposit with
rmy of the aemounts setoorrtb i n said ?d paragraph,
a vided:
(a) Escaows for future taxes and immucc pmaiums are being oollected and maintained by
the holder or servicer of the mortgage loan superior to our lien, or
(b) If you pay your own taxes and insurance premiums, you fulfill your obligation to peep
taxes and insurance premiums current with respect to the property secured hereby.
This waiver does not, in any way, release you from your obligation to make escrow payments of taxes
and insurance to the holder of any prior mortgage, nor does it relieve you of your obligation to keep
taxes and insure premiums current with respect to the secured property.
All payments will be applied first to the ac erred interest and next to the unpaid principal of your loan.
The exact amount of your final payment, fmance charge, and total of payments will be somewhat more
or less than the amounts shown if we do not receive each payment on the scheduled payment date.
AIJ I Certify this to be recorded
SHERRY C ISTIAN in um er an County PA
A 2nd Rider
CB6DO82 Revised 8/01
8K i 935PG2176
RECEIPT ACKNOWLEDGED:
EXHIBIT " U
Jeremy Christian February 4, 2008
4502 Woods Way
Mechanicsburg, PA 17055
Via Certified Mail -
Return Receipt Requested
Regular U.S. Mail
ACT 91 NOTICE
TAINCEE-7JACTION TO SAVE YOUR
HOME FROM FORECLOSURE
attached pages
help to save your home
This Notice explains how the roeram works
when you meet with the Counseling A? cv
hearin can call 717 780-1869 .
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it. You
may also want to contact an attorney in your area. The local bar association may be able to help
you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA
SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES
SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Jeremy Christian and Sherry Christian
4502 Woods Way, Mechanicsburg, PA 17055
10363326
First Horizon Home Loan Corporation
First Tennessee Bank National Association
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
-+.. ca?avi?71L'?1\l..?i W jYj(_,ji
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 YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND
YOUR CONTROL
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a
temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice.
During that time you must arrange and attend a "face-to-face" meeting with one of the consumer
credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR
WITHIN THE NEXT (30) DAYS. IF YOT 1 nn Mn•r A DDT v
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 --
t hone numbers of des' ated consumer credit counselin a encies for the count in which
the property is located are set forth at the end of this _Notice. It is only face-to-face meeting. Advise you lender imm?ly of your intentionsecessary to schedule one
APPLICATION FOR MORTGAGE ASSISTANCE.- Your mortgage is in default for
the reasons set forth later in this Notice (see following pages for specific information about the
nature of your default.) If you have tried and are unable to resolve this problem with the lender,
you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies
have applications for the program and they will assist you in submitting a complete application
to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO
SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN
THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL
BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the Agency under the eligibility criteria established by the
Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it
receives your application. During that time, no foreclosure proceedings will be pursued against
you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN
ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergent 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: 4502 Woods Wav Mechanicsburg PA 17055 IS
SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:monthly payments of $498.85 for the months of
July 2007 through February 2008 fora total monthly payment amount of $3_.990.80.
Other Charges: Late Charges in the total amount of $349-23 and BPO in the total amount
of $75.00.
TOTAL AMOUNT PAST DUE:_ $4,415.03
HOW TO CURE 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 $_ 4,415.03 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made
either by cash cashier's check certified check or money order made navable and sent to
Scott A. Dietterick, Esquire
James, Smith, Dietterick & Connelly LLP
P.O. Box 650
Hershey, PA 17033
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY
(30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the
mortgage debt. This means that the entire outstanding balance of this debt will be considered
due immediately and you may lose the chance to pay the mortgage in monthly installments. If
full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclosure upon your mortgaged
ro er .
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by
the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you
cure the delinquency before the lender begins legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees
will be added to the amount you owe the lender, which may also include other reasonable costs.
If you cure the default within the THIRTY (30) DAY Period, you will not be required to
pay attorney's fees
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid
principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured
the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, ou
still have the right to cure the default and prevent the sale at any time up to one hour before the
Shenff S. Sale. You ma do sob a n the total amount then ast 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 have never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that
such a Sheriff s Sale of the mortgaged property could be held would be approximately six (6)
months from the date of this Notice. A notice of the actual date of the 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:
T
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
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 _
your home to a buyer or transferee who will assume the may or mortgage debt, pmay not sell or
rovided that all theer
outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and
that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN
ANY CALENDAR YEAR).
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
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
800-342-2397
In accordance with the Fair Debt Collection Practices Act, Title 15 U.S.C. 31692(g), you may
dispute the validity of this debt, or any portion thereof, if you do so in writing within thirty (30)
days after receipt of this notice. If you dispute the validity of this debt or any portion thereof
within this thirty-day period, this firm will provide you with written verification thereof,
otherwise the debt will be assumed to be valid. Please be advised this is an effort to collect a
debt. Any and all information obtained will be used for that purpose.
Sincerel,
S A.
SAD/mse
Sherry Christian February 4, 2008
4502 Woods Way
Mechanicsburg, PA 17055 Via Certified Mail -
Return Receipt Requested
Regular U.S. Mail
ACT 91 NOTICE
TAT-7` ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mort a e on our home is in default and the lender
intends to foreclose. S ecific information about the nature of the default is provided in the
attached naees
help to save your home
This Notice exnlains how the program works
when you meet with the Counseling_A encv
hearine can call (717) 780 1869)
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it. You
may also want to contact an attorney in your area. The local bar association may be able to help
you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA
SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES
SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Jeremy Christian and Sherry Christian
4502 Woods Way, Mechanicsburg, PA 17055
10363326
First Horizon Home Loan Corporation
First Tennessee Bank National Association
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
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 YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND
YOUR CONTROL
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a
temporary stay of foreclosure on your mortgage for thi
During that time you must arrange and attend a "face-trt face" meeting with netof the consumer
credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR
WITHIN THE NEXT (30) DAYS. IF YOT T TV) Vn-r A n"T v _-_
rwX i OF THIS NOTICE CALLED "HOW TO CURE YOUR MOR
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
tel hone numbers of desi ated consumer credit counselin a encies for the count in which
the nropertv is located are set forth at the end of this Notice It is only necessary to schedule one
face to face meeting. Advise you lender imm_ely of your intentions.
L
APPLICATION FOR MORTGAGE ASSISTANCE. - Your mortgage is in default for
the reasons set forth later in this Notice (see following pages for specific information about the
nature of your default.) If you have tried and are unable to resolve this problem with the lender,
you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage
Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies
have applications for the program and they will assist you in submitting a complete application
to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO
SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN
THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL
BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the Agency under the eligibility criteria established by the
Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it
receives your application. During that time, no foreclosure proceedings will be pursued against
you if you have met the time requirements set forth above. You will be notified directly by the
Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN
ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance)
HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date)
NATURE OF THE DEFAULT - the MORTGAGE debt held by the above Lender on
your property located at: 4502 Woods Way Mechanicsburg PA 17055 IS
SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:monthly payments of $498.85 for the months of
July 2007 through February 2008 for a total monthly payment amount of $3,990.80.
Other Charges: Late Charges in the total amount of $349.23 and BPO in the total amount
of $75.00.
TOTAL AMOUNT PAST DUE: $4,415.03
HOW TO CURE 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 $ 4,415.03, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made
either by cash, cashier's check certified check or money order made payable and sent to
Scott A. Dietterick, Esquire
James, Smith, Dietterick & Connelly LLP
P.O. Box 650
Hershey, PA 17033
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY
(30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the
mortgage debt. This means that the entire outstanding balance of this debt will be considered
due immediately and you may lose the chance to pay the mortgage in monthly installments. If
full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclosure upon -your mortgaged
propertv.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by
the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you
cure the delinquency before the lender begins legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00.
However, if legal proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees
will be added to the amount you owe the lender, which may also include other reasonable costs.
If you cure the default within the THIRTY (30) DAY period. you will not be required to
pay attorney's fees.
OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid
principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured
the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, You
still have the right to cure the default and prevent the sale at an y time up to one hour before the
Sheriff s Sale. You may do so by paving the total amount then past due plus any late or other
charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and
any other costs connected with the Sheriff's Sale as specified in 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 have never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that
such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6)
months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be
sent to you before the sale. Of course, the amount needed to cure the default will increase the
longer you wait. You may find out at any time exactly what the required payment or action will
be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: First Tennessee Bank National Association
Address: 6522 Cha man Highway, Knoxville TN 37902
Phone Number: 1-800-971-3275
Fax Number: 865-633-2434
Contact Person: Collections De artment
EFFECT OF SHERIFF'S-SALE, - You should realize that a Sheriff's Sale will end your
ownership of the mortgaged property and your right to occupy it. If you continue to live in the
property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may or XXX may not sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that all the
outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and
that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN
ANY CALENDAR YEAR).
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
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
1Vlaranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
(717) 762-3285
PHFA
211 North Front Street
Harrisburg, PA 17110
800-342-2397
In accordance with the Fair Debt Collection Practices Act, Title 15 U.S.C. 31692(g), you may
dispute the validity of this debt, or any portion thereof, if you do so in writing within thirty (30)
days after receipt of this notice. If you dispute the validity of this debt or any portion thereof
within this thirty-day period, this firm will provide you with written verification thereof,
otherwise the debt will be assumed to be valid. Please be advised this is an effort to collect a
debt. Any and all information obtained will be used for that purpose.
quire
- 1L/ 111JG
VERIFICATION
I, Amy McKamey, Foreclosure Specialist, for First Tennessee Bank, N.A., depose and
say subject to the penalties of 18 Pa.C.S.A., sec. 4904 relating to unsworn falsification to
authorities that the facts set forth in the foregoing pleading are true and correct to the best of my
information, knowledge and belief.
Amy McKamey
Foreclosure Specialist
O
W
?.
00
v 1
d -°- r ^1
J. :;1 .e.. C._? ( 1
1
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01680 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST HORIZON HOME LOANS
VS
CHRISTIAN JEREMY S ET AL
STEPHEN BENDER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
CHRISTIAN JEREMY S
was served upon
the
DEFENDANT , at 1709:00 HOURS, on the 24th day of March , 2008
at 4502 WOODS WAY
MECHANICSBURG, PA 17055
+.--?r. r-in wt? rTTT1 Tl"?TTT TT
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: So Answers:
Docketing 18.00
Service 12.48
Affidavit 00 P
Surcharge 10.00 R. Thomas Kline
.00
40.48 03/26/2008
JAMES SMITH DIETTERICK CONNELL
3/28108
Sworn and Subscibed to B :
before me this day Deputy Sheriff
of A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01680 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST HORIZON HOME LOANS
VS
CHRISTIAN JEREMY S ET AL
STEPHEN BENDER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT- MORT FORE was served upon
CHRISTIAN SHERRY the
DEFENDANT , at 1709:00 HOURS, on the 24th day of March 2008
at 4502 WOODS WAY
MECHANICSBURG, PA 17055 by handing to
JEREMY S CHRISTIAN, ADULT IN CHARGE
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: So Answers:
Docketing 6.00
Service .00
45
Affidavit 00 r
Surcharge 10.00 R. Thomas Klinq
.00
16.0003/26/2008
JAMES SMITH DIETTERICK CONNELL
Sworn and Subscibed to By:
before me this day Deputy Sheriff
of A. D.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS CIVIL DIVISION
a division of FIRST TENNESSEE
BANK, NATIONAL ASSOCIATION,
Plaintiff,
VS.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
No.: 08-1680 CIVIL TERM
ISSUE NUMBER:
TYPE OF PLEADING:
PRAECIPE FOR DEFAULT JUDGMENT
(Mortgage Foreclosure)
Defendants.
I Hereby ertify that the last known address
of Defen s) is/,ars?
4502 Wo av lk
FILED ON BEHALF OF:
First Horizon Home Loans, a division of
First Tennessee Bank, National Association,
Plaintiff
COUNSEL OF RECORD FOR THIS
PARTY:
Scott A. Dietterick, Esquire
Pa. I.D. #55650
A. lbietteric?, b q ire Attorney for Plaintiff
JAMES, SMITH, DIETTERICK & CONNELLY LLP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff, NO.: 08-1680 CIVIL TERM
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
PRAECIPE FOR DEFAULT JUDGMENT
TO:PROTHONOTARY
SIR/MADAM:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendants, Jeremy S. Christian and Sherry Christian, in the amount of $71,507.43 which
is itemized as follows:
Principal $ 64,124.13
Interest through 5/5/2008 $ 5,039.43
Late Charges $ 498.87
Property Inspections $ 95.00
Attorney's Fees $ 1,325.00
Title Costs $ 425.00
TOTAL $ 71,507.43
plus interest on the principal sum ($64,124.13) from May 5, 2008, at the rate of $15.05 per diem,
plus additional late charges, and costs (including additio al escro ad es), additional
attorneys' fees and costs and for foreclosure and sale of Xe mo g premises.
JAMES
By: A// N4IV)
Scott AIDTetteri&,-Fsqui
Attorney for Plaintiff
PA I.D. #55650
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
& CONNELLY LLP
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS:
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendants are not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that the Notices of Intent to take Default
Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies.
Sworn to and subscribed before me
, 2008.
this--- day of &!??
Notary Public
My Commission Expires:
Scott A. Di
COMM;OMEALTH OF PENNSYLVANIA
NOTARIAL SEAL
MICHELLE ELLIOTT NOTARY PUBLIC
DERRY TOWNSHIP DAUPHIN COUNTY
My Z01
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01680 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST HORIZON HOME LOANS
VS
CHRISTIAN JEREMY S ET AL
STEPHEN BENDER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
CHRISTIAN JEREMY S the
DEFENDANT , at 1709:00 HOURS, on the 24th day of March 2008
at 4502 WOODS WAY
MECHANICSBURG, PA 17055 by handing to
JEREMY S CHRISTIAN
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: So Answers:
Docketing
Service 18.00
12 , 48
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
40.48 03/26/2008
JAMES SMITH DIETTERICK CONNELL
Sworn and Subscibed to By: A7
before me this day -Deputy Sheriff
of A.D.
CASE NO: 2008-01680 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST HORIZON HOME LOANS
VS
CHRISTIAN JEREMY S ET AL
STEPHEN BENDER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT- MORT FORE was served upon
CHRISTIAN SHERRY the
DEFENDANT at 1709:00 HOURS, on the 24th day of March 2008
at 4502 WOODS WAY
MECHANICSBURG, PA 17055
JEREMY S CHRISTIAN
by handing to
ADULT IN CHARGE
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 6.00
Service .00
Affidavit .00
Surcharge 10.00
Sworn and Subscibed to
before me this day
So Answers:
lip
R. Thomas Klinq.
03/26/2008
JAMES SMITH DIETTERICK CONNELL
By: 4? &/
Deputy Sheriff
of A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of : CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff, NO.: 08-1680 Civil Term
VS.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
11"ORTANT NOTICE
TO: Sherry Christian
4502 Woods Way
Mechanicsburg, PA 17055
DATE OF NOTICE: April 15, 2008
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO YOUR 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.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of : CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff, NO.: 08-1680 Civil Term
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
AVISO IMPORTANTE
A. Sherry Christian
FECHA DEL AVISO: April 15, 2008
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108 .
DATE: S D
JAMES
BY:
FIRST CLASS U.S. MAIL, POSTAGE PREPAID
CONNELLY LLP
PA I.D. #55650
Kimberly A. Bonner, Esquire
PA I.D. #89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of : CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff, NO.: 08-1680 Civil Term
VS.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
11"ORTANT NOTICE
TO: Jeremy S. Christian
4502 Woods Way
Mechanicsburg, PA 17055
DATE OF NOTICE: April 15, 2008
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO YOUR 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.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
61,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of : CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff, NO.: 08-1680 Civil Term
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
AVISO EW PORTANTE
A. Jeremy S. Christian
FECHA DEL AVISO: April 15, 2008
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO; SE PUEDE DICTAR
UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-910G? p JAMES S T TK & CONNELLY LLP
DATE: 1 l BY:
Sc A. ttenc , Esquire
PA I.D. #55650
Kimberly A. Bonner, Esquire
PA I.D. #89705
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
FIRST CLASS U.S. MAIL, POSTAGE PREPAID (717) 533-3280
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff,
NO.: 08-1680 CIVIL TERM
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: Jeremy S. Christian
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $71,507.43
plus interest on the principal sum ($64,124.13) from May 5, 2008, at the rate of $15.05 per diem,
plus additional late charges, and costs (including additional escrow advances), additional
attorneys' fees and costs and for foreclosure and sale of the mortgaged premises.
llelz?
P?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff,
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
CIVIL DIVISION
NO.: 08-1680 CIVIL TERM
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: Sherry Christian
( ) Plaintiff
(XXX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on
( ) A copy of the Order or Decree is enclosed,
or
(XXX) The judgment is as follows: $71,507.43
plus interest on the principal sum ($64,124.13) from May 5, 2008, at the rate of $15.05 per diem,
plus additional late charges, and costs (including additional escrow advances), additional
attorneys' fees and costs and for foreclosure and sale of the mortgaged premises.
1?0
IN THE COURT OF COMMON PLEAS OF CCIMERyw aavm, PENNSYLVANIA
First Horizon Home Loans, a
division of First Tennessee
Bank, National Association (Plaintiff)
V
Jeremy S. Christian and Sherry
Christian,
C-= DIVISION
File No.08-1680 CIVIL TERM
( Defendant (s )
TO THE PROTHONOTARY OF THE SAID COURT:
Amount Due $ 71,507.43
Interest from 5/5/08 to $ 4,530.05
date of ME
Atty's Comm
Costs
The undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgrent, but if it does,
it-is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR EXECLYMON
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described property of the
defendant(s)
See Exhibit "A" attached.
PRAECIPE FOR ATTACHM NP EXECUTION
Issue writ of attachment to the Sheriff of Cumberland . County, for debt,
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishee(si apa?dens against
real. estate of the defendant(s) described in the attached exhi
DATE; May 5, 2008 Signature:
Print Name:
Address: James Smith Dietterick s Connelly LLP
P O Sox 650, Hershey PA 17033
Attorney for: Plaintiff
Telephone: (717) 533-3280
Supreme Court ID No.: 55650
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff,
VS.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
CIVIL DIVISION
NO.: 08-1680 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
First Horizon Home Loans, a division of First Tennessee Bank, National
Association, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of
Execution was filed the following information concerning the real property located at
4502 Woods Way, Mechanicsburg, Pennsylvania 17055:
1. Name and Address of Owner(s) or Reputed Owner(s):
JEREMY S. CHRISTIAN 4502 Woods Way
Mechanicsburg, PA 17055
SHERRY CHRISTIAN
4502 Woods Way
Mechanicsburg, PA 17055
2. Name and Address of Defendant(s) in the Judgment:
JEREMY S. CHRISTIAN 4502 Woods Way
Mechanicsburg, PA 17055
SHERRY CHRISTIAN
4502 Woods Way
Mechanicsburg, PA 17055
3. Name and Address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
FIRST HORIZON HOME LOANS a division of Plaintiff
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION
4. Name and Address of the last record holder of every mortgage of record:
FIRST HORIZON HOME LOANS a division of Plaintiff
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION
5. Name and Address of every other person who has any record lien on the
property:
CUMBERLAND COUNTY TAX
CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
6. Name and Address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
DEPARTMENT OF REVENUE
COMMONWEALTH OF PA
PA Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
PA Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
7. Name and Address of every other person of whom the Plaintiff has
knowledge who has any interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse
RELATIONS OFFICE One Courthouse Square
Carlisle, PA 17013
I verify that the statements made in this Affidavit are true and correct to the best
of my personal knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn
falsification to authorities.
DATED: J Ll
JAMES, SMTI
BY:
Scott A. Die#drick, E9
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Y LLP
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff,
VS.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
NO.: 08-1680 CIVIL
Defendants.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Jeremy S. Christian
4502 Woods Way
Mechanicsburg, PA 17055
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 3, 2008, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
4502 Woods Way
Mechanicsburg, Pennsylvania 17055
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 08-1680 Civil Term
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Jeremy S. Christian and Sherry Christian
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to.
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Courtand a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, SMITH] DWTTF gCIk& CONNELLY LLP
DATED: Q BY:
Stott% Dietterick, Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN piece, parcel or tract of land situate, lying and being in
Cumberland County, Pennsylvania, and more fully bounded and limited as follows, to-
wit:
BEING KNOWN AND DESIGNATED as Lot No. 18, as shown on a Plan
entitled "The Manor of Westport", which Plan is recorded among the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 89, Page
143.
HAVING thereon erected a dwelling house being known and numbered as 4502
Woods Way, Mechanicsburg, Pennsylvania 17055.
BEING the same premises which RCP&.P, LLC a Pennsylvania Limited Liability
Company, by Deed dated November 29, 2005 and recorded on January 20, 2006 in and
for Cumberland County, in Deed Book Volume 272, Page 4236, granted and conveyed
unto Jeremy S. Christian and Sherry Christian, as Tenants by the Entirety.
Tax Map No.: 13-10-0256, Parcel No.: 062
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff,
VS.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
NO.: 08-1680 CIVIL
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Sherry Christian
4502 Woods Way
Mechanicsburg, PA 17055
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 3, 2008, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
4502 Woods Way
Mechanicsburg, Pennsylvania 17055
Cumberland County
A
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 08-1680 Civil Term
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Jeremy S. Christian and Sherry Christian
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
'J
THE. LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, SMITTA F?CK & CONNELLY LLP
DATED: BY:
Scott X.-Dietterick, Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
l
LEGAL DESCRIPTION
ALL THAT CERTAIN piece, parcel or tract of land situate, lying and being in
Cumberland County, Pennsylvania, and more fully bounded and limited as follows, to-
wit:
BEING KNOWN AND DESIGNATED as Lot No. 18, as shown on a Plan
entitled "The Manor of Westport", which Plan is recorded among the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 89, Page
143.
HAVING thereon erected a dwelling house being known and numbered as 4502
Woods Way, Mechanicsburg, Pennsylvania 17055.
BEING the same premises which RCP&P, LLC a Pennsylvania Limited Liability
Company, by Deed dated November 29, 2005 and recorded on January 20, 2006 in and
for Cumberland County, in Deed Book Volume 272, Page 4236, granted and conveyed
unto Jeremy S. Christian and Sherry Christian, as Tenants by the Entirety.
Tax Map No.: 13-10-0256, Parcel No.: 062
Exhibit "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1680 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FIRST HORIZON HOME LOANS, a division of FIRST
TENNESSEE BANK, NATIONAL ASSOCIATION, Plaintiff (s)
From JEREMY S. CHRISTIAN and SHERRY CHRISTIAN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $71,507.43 L.L.$ 0.50
Interest from 5/05/08 to Date of Sale - $4,530.05
Atty's Comm % Due Prothy $2.00
Atty Paid $175.48 Other Costs
Plaintiff Paid
Date: 5/06/08
Prothonotary
(Seal) By:
REQUESTING PARTY:
Name: SCOTT A. DIETTERICK, ESQUIRE
Address: JAMES SMITH DIETTERICK & CONNELLY LLP
PO BOX 650
HERSHEY, PA 17033
Attorney for: PLAINTIFF
Telephone: 717-533-3280
Supreme Court ID No. 55650
Deputy
First Horizon Home Loans
VS
Jeremy S. Christian and Sherry Christian
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-1680 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per letter of request from Attorney Scott Dietterick.
Sheriff s Costs:
Docketing
Poundage
Levy
Law Library
Prothonotary
Mileage
Surcharge
30.00
1.81
15.00
.50
2.00
13.00
30.00
$ 92.31 ? L/ a??o D,
So Answers:
R. Thomas Kline, Sheriff
BY
Cl
Real Estate S rgeant
It C? -
uLu Gy54 Y
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff,
VS.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
CIVIL DIVISION
NO.: 08-1680 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
First Horizon Home Loans, a division of First Tennessee Bank, National
Association, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of
Execution was filed the following information concerning the real property located at
4502 Woods Way, Mechanicsburg, Pennsylvania 17055:
1. Name and Address of Owner(s) or Reputed Owner(s):
JEREMY S. CHRISTIAN 4502 Woods Way
Mechanicsburg, PA 17055
SHERRY CHRISTIAN
4502 Woods Way
Mechanicsburg, PA 17055
2. Name and Address of Defendant(s) in the Judgment:
JEREMY S. CHRISTIAN 4502 Woods Way
Mechanicsburg, PA 17055
SHERRY CHRISTIAN
4502 Woods Way
Mechanicsburg, PA 17055
3. Name and Address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
FIRST HORIZON HOME LOANS a division of Plaintiff
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION
4. Name and Address of the last record holder of every mortgage of record:
FIRST HORIZON HOME LOANS a division of Plaintiff
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION
5. Name and Address of every other person who has any record lien on the
property:
CUMBERLAND COUNTY TAX
CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
6. Name and Address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
DEPARTMENT OF REVENUE
PA Inheritance Tax Division
Department 280601
Harrisburg, PA 17128-0601
COMMONWEALTH OF PA
PA Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
7. Name and Address of every other person of whom the Plaintiff has
knowledge who has any interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC Cumberland County Courthouse
RELATIONS OFFICE One Courthouse Square
Carlisle, PA 17013
I verify that the statements made in this Affidavit are true and correct to the best
of my personal knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
JAMES, SMIT
DATED: Q BY:
Scott A
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
Y LLP
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of CIVIL DIVISION
FIRST TENNESSEE BANK, :
NATIONAL ASSOCIATION, :
Plaintiff,
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
NO.: 08-1680 CIVIL
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Jeremy S. Christian
4502 Woods Way
Mechanicsburg, PA 17055
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 3, 2008, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The LOCATION of your property to be sold is:
4502 Woods Way
Mechanicsburg, Pennsylvania 17055
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 08-1680 Civil Term
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Jeremy S. Christian and Sherry Christian
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to.
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, SMITHI DWTTFACA& CONNELLY LLP
DATED: S ®? BY:
S1 ottk& Dietterick, Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN piece, parcel or tract of land situate, lying and being in
Cumberland County, Pennsylvania, and more fully bounded and limited as follows, to-
wit:
BEING KNOWN AND DESIGNATED as Lot No. 18, as shown on a Plan
entitled "The Manor of Westport", which Plan is recorded among the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 89, Page
143.
HAVING thereon erected a dwelling house being known and numbered as 4502
Woods Way, Mechanicsburg, Pennsylvania 17055.
BEING the same premises which RCP&P, LLC a Pennsylvania Limited Liability
Company, by Deed dated November 29, 2005 and recorded on January 20, 2006 in and
for Cumberland County, in Deed Book Volume 272, Page 4236, granted and conveyed
unto Jeremy S. Christian and Sherry Christian, as Tenants by the Entirety.
Tax Map No.: 13-10-0256, Parcel No.: 062
Exhibit "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a division of CIVIL DIVISION
FIRST TENNESSEE BANK,
NATIONAL ASSOCIATION,
Plaintiff, NO.: 08-1680 CIVIL
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Sherry Christian
4502 Woods Way
Mechanicsburg, PA 17055
TAKE NOTICE:
. That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013 on
Wednesday, September 3, 2008, at 10:00 a.m. prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a brief
mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
4502 Woods Way
Mechanicsburg, Pennsylvania 17055
Cumberland County
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 08-1680 Civil Term
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Jeremy S. Christian and Sherry Christian
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that
hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty
(30) days after the sale, and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it, within
ten (10) days of the date it is filed. Information about the Schedule of Distribution may
be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
South Hanover Street, Carlisle, Pennsylvania 17013.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights to
prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Cumberland County Court Administrator
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
THE. LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious
defense against the person or company that has entered judgment against
you. You may also file a petition with the same Court if you are aware of
a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly
inadequate price or for other proper cause. This petition must be filed
before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common
Pleas of Cumberland County. The petition must be served on the attorney
for the creditor or on the creditor before presentation to the Court and a
proposed order or rule must be attached to the petition. If a specific return
date is desired, such date must be obtained from the Court Administrator's
Office, Cumberland County Courthouse, One Courthouse Square, 4th
Floor, Carlisle, Pennsylvania 17013, before presentation of the petition to
the Court.
JAMES, SMITH -'F CK & CONNELLY LLP
r,
DATED: S l? BY:
Scoft A. Dietterick, Esquire
Pa. I.D. #55650
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
VIA CERTFIED MAIL, RETURN RECEIPT REQUESTED
AND
VIA PERSONAL SERVICE BY CUMBERLAND COUNTY SHERIFF
LEGAL DESCRIPTION
ALL THAT CERTAIN piece, parcel or tract of land situate, lying and being in
Cumberland County, Pennsylvania, and more fully bounded and limited as follows, to-
wit:
BEING KNOWN AND DESIGNATED as Lot No. 18, as shown on a Plan
entitled "The Manor of Westport", which Plan is recorded among the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 89, Page
143.
HAVING thereon erected a dwelling house being known and numbered as 4502
Woods Way, Mechanicsburg, Pennsylvania 17055.
BEING the same premises which RCP&P, LLC a Pennsylvania Limited Liability
Company, by Deed dated November 29, 2005 and recorded on January 20, 2006 in and
for Cumberland County, in Deed Book Volume 272, Page 4236, granted and conveyed
unto Jeremy S. Christian and Sherry Christian, as Tenants by the Entirety.
Tax Map No.: 13-10-0256, Parcel No.: 062
Exhibit "A"
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 08-1680 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FIRST HORIZON HOME LOANS, a division of FIRST
TENNESSEE BANK, NATIONAL ASSOCIATION, Plaintiff (s)
From JEREMY S. CHRISTIAN and SHERRY CHRISTIAN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $71,507.43 L.L.$ 0.50
Interest from 5/05/08 to Date of Sale - $4,530.05
Atty's Comm % Due Prothy $2.00
Atty Paid $175.48 Other Costs
Plaintiff Paid
Date: 5/06/08
Prothonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name: SCOTT A. DIETTERICK, ESQUIRE
Address: JAMES SMITH DIETTERICK & CONNELLY LLP
PO BOX 650
HERSHEY, PA 17033
Attorney for: PLAINTIFF
Telephone: 717-533-3280
Supreme Court ID No. 55650
Real Estate Sale # 27
On May 12, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA
Known and numbered as 4502 Woods Way, Mechanicsburg,
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
trt?
Date: May 12, 2008 By:.
Real Es to Sergeant
LE :b V L- A qj OOOZ
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST HORIZON HOME LOANS a CIVIL DIVISION
division of FIRST TENNESSEE
BANK, NATIONAL ASSOCIATION,
Plaintiff, NO.: 08-1680 CIVIL J
vs.
JEREMY S. CHRISTIAN and
SHERRY CHRISTIAN,
Defendants.
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Please mark the judgment filed at the above-captioned term and number satisfied without
prejudice.
Respectfully submi
JAMES,
Scott A. Die viL
PA I.D. #55650
Attorney for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
CONNELLY LLP
C.0
C.-.