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HomeMy WebLinkAbout08-2156ORRSTOWN BANK 77 EAST KING STREET SHIPPENSBURG, PA 17257 Plaintiff V. LUTHER R. PALMER 1805 FURMAN STREET RUSTON, LA 71270 Defendant IN THE COURT,OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-/S"(o CIVIL TERM MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an 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 DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 ORRSTOWN BANK 77 EAST KING STREET SHIPPENSBURG, PA 17257 Plaintiff V. LUTHER R. PALMER 1805 FURMAN STREET RUSTON, LA 71270 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008- 9 I .,?rG CIVIL TERM MORTGAGE FORECLOSURE COMPLAINT NOW, comes Plaintiff, Orrstown Bank, by and through its attorneys, O'BRIEN, BARIC & SCHERER, and files the within Complaint and, in support thereof, sets forth the following: 1. The Plaintiff and Mortgagee is Orrstown Bank, a Pennsylvania corporation with a place of business located at 77 East King Street, Shippensburg, Cumberland County, Pennsylvania. 2. The Defendant is Luther R. Palmer, an adult individuals who resides at 1805 Furman Street, Ruston, LA 71270. 3. By Deed acknowledged on September 14, 2002, Artrell Palmer, Carole Palmer Evans, Sherry Palmer Campbell and Kim Palmer Lee, conveyed their interests in the premises described in Exhibit "A", attached hereto and made a part hereof, to Luther R. Palmer. This Deed was recorded in Cumberland County Deed Book 257, Page 86, et seq., all of which pages are incorporated herein by reference and made a part hereof. The premises are further described as being 408 North West Street, Carlisle, Cumberland County, Pennsylvania. Luther R. Palmer further acquired an interest in the premises through the will of Sarah Catherine Palmer as referenced at estate proceeding no. 21-00-387. 4. On or about July 18, 2003, Luther R. Palmer, as Mortgagor, made, executed and delivered a written Note secured by a Mortgage made, executed and delivered the same day to Plaintiff as Mortgagee on the premises described in Exhibit "A". This Mortgage was recorded in the Cumberland County Office of the Recorder of Deeds on July 24, 2003, at Cumberland County Record Book 1825, Page 332, et seq., all of which pages are incorporated herein by reference and made a part hereof. A true and correct copy of the aforesaid Note is attached hereto and made a part hereof as Exhibit "B". A true and correct copy of the aforesaid recorded Mortgage is attached hereto and made a part hereof as Exhibit "C". 6. Defendant has defaulted under the terms and conditions of the Mortgage and Note by failing to make payments due October, 2007, November, 2007, December, 2007, January, 2008, February, 2008 and March, 2008. 7. Defendant is the present record partial owner of the premises described in Exhibit "A' and is the real partial owner of the premises. Plaintiff served Notice of Plaintiff s Intention to Foreclose and Act 91 notice to the Defendant via certificate of mailing on or about January 10, 2008. 9. Attached hereto and marked Exhibit "D" are true and correct copies of the combined Notice of Intention to Foreclose and Act 91 Notice mailed to the Defendant. 10. Attached hereto and marked Exhibit "B" is a true and correct copy of the certificate of mailing for the combined notice. 11. The original principal amount of the Mortgage was $21,000.00. 12. Under the terms of the Mortgage and Note, if any monthly payment of principal and interest is not made when due or any other obligations of the Note or Mortgage is not met, then the entire indebtedness owing on the Mortgage and Note obligation shall become due and payable immediately at the declaration of the Mortgagee. 13. Plaintiff, as Mortgagee, has exercised its option and declared the entire unpaid balance of principal and interest as immediately due and owing. 14. The following amounts are presently due on the said Mortgage and Note calculated to March 4, 2008: Principal $18,795.21 Interest to 03/04/08 $ 440.83 (per diem $3.46) Late Charge $ 73.22 Other Charges $ 51.52 Reasonable attorneys fees $ 1,879.52 fixed by Plaintiff for purposes of this Complaint (10% of principal debt) TOTAL: $21,240.30 WHEREFORE, Plaintiff demands judgment in Mortgage Foreclosure in the sum of $21,240.30, plus interest thereafter at the contract per diem rate from March 4, 2008, and costs and expenses against the Defendant, Mortgagor and real partial owner and seeks foreclosure and Sheriff's Sale of the mortgaged property in Exhibit "A". Respectfully submitted, O' EN, BARIC & SCHE t a David A. Baric, Esquire I.D. 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff, Orrstown Bank dab. dir/orrstownbank/palmer/foreclosurecomplaint. pld VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. This verification is signed by David A. Baric, Esquire, Attorney for Plaintiff and is based upon the statements provided by Plaintiff, as well as documents reviewed by the undersigned as attorney for Plaintiff. This verification will be substituted and ratified by a verification signed by the Plaintiff who is presently unavailable to sign said verification. I undersigned that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unsworn falsifications to authorities. z David A. Baric, Esquire Dated: April 3, 2008 ...iE .....?LAND COUNTY' 03 MY 13 Pal 2 28 Tax Parcel No: 0600.1789406 DEED . MADE THE day of in the year of Our Lord two thousand two (2002) BETWEEN ARTRELL PALMER, CAROLE PALMER EVANS, SHERRY PALM CR CAMPBELL and KIM P +' LEE, of Baltimore, Maryland, GRANTORS, and LUTHER R. PALMED of Carlisle, Cumberland County, Pennsylvania, GRANTEE, WITNESSETH, that in consideration of One and no/100 ($1.00) Dollar in hand paid, the receipt whereof is hereby acknowledged, the said Grantors do hereby grant and convey unto the said Grantee, his heirs and assigns, ALL THAT CERTAIN property and lot of ground located in the Borough of Carlisle, County of Cumberland, and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the West side ofNorth West Street; thence along the property of No. 406 North West Street, North 77 degrees 45 minutes West, a distance of 93 feet to the East side of a 12 foot Public'Alley; thence along the East side of the above Public Alley, North 12 degrees 15 minutes East, a distance of 14.41 % feet to a point; thence along property of No. 410 North West Street, South 77 degrees 45 minutes East, a distance of 93 feet to a point on the West side of North West Street; thence along the West side of North West Street, South 12 degrees 15 minutes West, a distance of 14.41 % feet to a point, the place of BEGINNING. KNOWN as and numbered 408 North West Street. TOGETHER with the right of ingress and egress and the common use of all that certain alley way located between properties nos. 408 and 410 North West Street. BEING the same property which Pierson K. Miller and Margaret S. Miller, husband and wife, by their Deed dated January 14, 1954, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book "N", Volume 15, Page 192, granted and conveyed unto William H. Palmer and Sarah Catherine Palmer, husband and wife. The said William H. Palmer died on March 24, 1995, thereby vesting fee simple title, by operation of law, in his surviving spouse, Sarah Catherine Palmer. plc 07 lff 86 Exhibit "A" The said Sarah Catherine Palmer died testate on March 19, 2000, and by her Last Will and Tit duly proven and registered in the Office of the Register of Wills in and for Cumberland County, Pennsylvania, at Estate Proceeding No. 21400-387, she devised the hereinbefore described property to her tight (8) children' namely Julia Ann Stadkfieid, WUHarn R Palmer, Jr., Shbiey Mae Palmer, Joan Marie Washington, Louis M. Palmer, LucWo Jean Simpson, Jacqueline Louise Palmer, and Luther R Palmer. The said Louis M. Palmer predeceased the said Sarah Catherine-Palmer, dying intestate on July 14, 1998, leaving to survive him as his sole issue, two (2) natural daughters, namely Artrell Palmer and Carole Palmer Evans and two (2) daughters, namely Sherry Palmer Campbell and Kim 19el? 67, and Lee, adopted by ereterod to docket 9/AD, Folio 78 Can NCo 1139No. 2 of 81 AD filed J? X16 January 1 Tani, January , The said Artrell Palmer, Carole Palmer Evans, Sherry Palmer Campbell and Kim Palmer Lee hereby convey any right, title and interest they may have in the above described property and do release and quit-claim said property to the said Grantees herein. AND the said Grantors hereby covenant and agree that they and each of them will warrant SPECIALLY the property hereby conveyed. IN WITNESS WHMEOF, said Grantors have hereunto set their hands and seals the day and year first above written. Signed, sealed and delivered in the presence of Carole Palmer Evans AUAWCOM NOTARY Kew STALE OF MARYLAM box W7 P&Coe jW EvkwMare 1 20RS STATE OF BALTIMORE ) COUNTY OF -91A 1Y SS. "Zl ? On this, the day of . -40- t'e#4b,LP, 2002, before me, the undampW officer, personally appeared Artreil Palmer, known to me (or satisfactorily proven) to be the person whose name is gibed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WrINESS WHEREOF, I hereunto set my hand and official seal. Notary Public STATE OF BALTIMORE ) s5. a 15- (? -`i8if ?? MJBUC STiVE (? ?YWCY?AI?i ?C i a3 MWA COUNTY OF On this, the J * day of St,gte m IN -t- f, -, 2002, before mee, the undersigned off ca•, personalty appeared Carole Palmer Evans, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained, IN WITNESS WBEREOF, I hereunto set my hand and official seal. Notary Public STATE OF BALTIMORE L?1•'uT' ti 66. - r'Q'W FLOW MR OF AOJMM COUNTY OF i ) * CWWSOM Exom. J&.h I On this, the 14 day of u { eML ¢ +(? 2002, before me, the undersigned officer, personally appeared Shiny Palmer Campbell, known to me (or saddhetorily proven) to be the person whose name is subscribed to the within instrument, and 6ooK W PAGE 86 acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public STATE OF BALTIMORE cR COUNTY OF ss. o!? -?q.3 On this, the ! day of s-e2002, before me, the undersigned officer, personally appeared Kim Palmer Lee, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My CAmmidon Elm M th t .200 5 CERTMCATE OF RESIDENCE I do hereby certify that the precise residence and complete post office address of the within named Grantee LuT%Eiq R. FALMEg horei.n is. RA follows: 228 wasr gao&tj srpscr, Su1rE a., R?chMeK , VA 23220 / 2003 , Attorney 1 !mac 257 McE 89 COMMONWEALTH OF P4V COUNTY OF CUMBERLAND : SS. Recorded on this day of A.D. 2002, in the Recorder's Office of the said County, in Deed Book Page Given under my hand and seal of the said office, the date above written, Recorder OWN) V r Ccr:'-j this to be recorded fn Cumberland County PA a • fit Recorder of Deeds i M ,..n ?"• M b arnaar+mm g$$gae?iS?e??$o?? H fi A u+ ? a q A ? p 2' IF c.+ 90 ,4EV-183 EX (6-96) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE BUREAU OF INDIVIDUAL TAXES DEPT. 280603 HARRISBURG, PA 17128-0603 REALTY TRANSFER TAX STATEMENT OF VALUE PA Complete each section and file In duplicate with Recorder of Deeds when (1) the full value/consideration is not set forth in the deed, (2) when the deed Is without consideration, or by gift, or (3) a tax exemption is claimed. A Statement of Value is not required if the transfer is wholly exempt from in based on: (1) family relationship or (2) public utility easement. If more space is needed, attach additional sheet(s). A CORRESPONDENT - All inquiries may be directed to the following person: Name: HAROLD S. IRWIN, III umpnone numoer. Q+-+ AA -..... 717243-6090 w-Y. 35 EAST HIGH STREET CARLISLE B TRANSFER DATA ARTRELL PALMER, at al 2121 WINSOR GARDEN LANE APT 544D BALTIMORE MD C PROPERTY LOCATION Street Address: 408 NORTH WEST STREET County: CUMBERLAND D VALUATION DATA 1. Actual Cash Consideration: $ 3,600.00 4. County Assessed Value: E EXEMPTION DATA la. Amount of Exemption Claimed: $27,083.33 I 21207 LUTHER R. PALMER RECORDERS USE ONLY Stets Tax Paid Book Number Page Number Date Recorded 17013 April 5, 224 WwsT 8?pwp S'1'IRatt'?T, SutTE 2 ?y? Shate? ?:.. r•.... RICHMOND VA CARLISLE AREA X 2. Check Appropriate Box Below for Exemption Claimed: _ Will or Intestate succession: 2!92-7-o 06-20-1789-206 s. cedent) (Estate Flle Number) Transfer to Industrial Development Agency. (Name of be- . Transfer to a trust. (Attach complete copy of trust agreement Identifying all beneficiaries.) Transfer between principal and agent (Attach complete copy of agency / straw party agreement.) Transfers to the Commonwealth, the United States and Instrumentalities by gift, dedication, condemnation or in lieu of condemnation. (If condemnation or in lieu of condemnation, attach copy of resolution.) Transfer from a mortgagor to a holder of a mortgage in default. Mortgage Book Number Page Number Corrective or confirmatory deed (Attach complete copy of the prior deed being corrected or confirmed.) Statutory corporate consolidation, merger or division. (Attach copy of articles.) X Other (Please explain exemption claimed, if other than listed above.) GRANTEE PURCHASED ONLY A 1/6 (OR 16.67%) INTEREST IN PREMISES (TOTAL VALUE OF $32,300 ON MOTHER'S INHERITANCE TAX RETURN) FROM GRANTORS FOR A TOTAL PURCHASE PRICE OF $3,600.00. Under penalties of law, I declare that 1 have examined this Statement, including accompanying Information, and to the beat of-my- f my knowledge and belief it I s, correct and complete. Slgnatu)* yaf'Vrespondent or Responsible Partv n . r4..a,. APRIL 18. 2003 BOROUGH REFUSAL TO RECORD THE DEED. . PROMISSORY NOTE I References in the shaded area are for Lender's use only and do not limit the applicability of this document to an Any Item above containing "• • •" has been omitted due to text length limitations y particular loan or item Borrower: LUTHER R PALMER (SSN: 208_38_5080) Lender: ORRSTOWN BANK 408 N WEST STREET HANOVER STREET OFFICE CARLISLE, PA 17013 PO BOX 250 SHIPPENSBURG, PA 17257 Principal Amount: $21,000.00 Interest Rate: 6.750% Date of Note: July 18, 2003 Maturity Date: July 18, 2018 PROMISE TO PAY. I ("Borrower") promise to pay to ORRSTOWN BANK ("Lender"), or order, in lawful money of the United States of America, the principal amount of Twenty-one Thousand & 001100 Dollars ($21,000.00), together with interest at the rate of 6.750% per annum on the unpaid principal balance from July 23, 2003, until paid in full. PAYMENT. 1 will pay this loan In 180 payments of $195.72 each payment. My first payment Is due August 18, 2003, and all sub payments are due on the same day of each month after that. M final Sequent My payment will be due on July 18, 2018, and will be for 811 principal and all accrued Interest and all credit insurance premiums, not yet paid. Payments Include principal and interest and credit Insurance premiums. Unless otherwise agreed or required by applicable law, payments will be applied first to any unpaid credit Insurance premiums, accrued to the date of receipt of payment; then to any accrued unpaid Interest; then to principal; then to any unpaid collection costs; and then to any late charges. Interest on this Note is computed on a 3651365 simple Interest basis; that Is, by applying the ratio of the annual Interest rate over the number of days in a year, multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance Is outstanding. I will pay Lender at Lender's address shown above or at such other place as Lender may designate in writing. PREPAYMENT. I may pay without penalty all or a portion of the amount owed earlier than it is due. Early payments will not, unless agreed to by Lender in writing, relieve me of my obligation to continue to make payments under the payment schedule. Rather, early payments will reduce the principal balance due and may result in my making fewer payments. If I prepay this loan in full, I will receive a rebate of any unearned insurance premiums. I agree not to send Lender payments marked "paid in full", "without recourse", or similar language. If I send such a payment, Lender may accept it without losing any of Lender's rights under this Note, and I will remain obligated to pay any further amount owed to Lender. All written communications concerning disputed amounts, including any check or other payment instrument that indicates that the payment constitutes "payment in full" of the amount owed or that is tendered with other conditions or limitations or as full satisfaction of a disputed amount must be mailed or delivered to: ORRSTOWN BANK, HANOVER STREET OFFICE, PO BOX 250, SHIPPENSBURG, PA 17257. LATE CHARGE. If a payment is 16 days or more late, I will be charged $2.50. INTEREST AFTER DEFAULT. Upon default, including failure to pay upon final maturity, the total sum due under this Note will bear interest from the date of acceleration or maturity at the interest rate on this Note. The interest rate will not exceed the maximum rate permitted by applicable law. DEFAULT. I will be in default under this Note if any of the following happen: Payment Default. I fail to make any payment when due under this Note. Break Other Promises. I break any promise made to Lender or fail to perform promptly at the time and strictly in the manner provided in this Note or in any agreement related to this Note, or in any other agreement or loan I have with Lender. False Statements. Any representation or statement made or furnished to Lender by me or on my behalf under this Note or the related documents is false or misleading in any material respect, either now or at the time made or furnished. Death or Insolvency. Any Borrower dies or becomes insolvent; a receiver is appointed for any part of my property; I make an assignment for the benefit of creditors; or any proceeding is commenced either by me or against me under any bankruptcy or insolvency laws. However, my death will not be an event of default if as a result of the death the Indebtedness is fully covered by credit life insurance. Taking of the Property. Any creditor or governmental agency tries to take any of the property or any other of my property in which Lender has a lien. This includes taking of, garnishing of or levying on my accounts with Lender. However, if I dispute in good faith whether the claim on which the taking of the property is based is valid or reasonable, and if I give Lender written notice of the claim and furnish Lender with monies or a surety bond satisfactory to Lender to satisfy the claim, then this default provision will not apply. Defective Coliateralization. This Note or any of the related documents ceases to be in full force and effect (including failure of any collateral document to create a valid and perfected security interest or lien) at any time and for any reason. Collateral Damage or Loss. Any collateral securing this Note is lost, stolen, substantially damaged or destroyed and the toss, theft, substantial damage or destruction is not covered by insurance. Events Affecting Guarantor. Any of the preceding events occurs with respect to any guarantor, endorser, surety, or accommodation party of any of the indebtedness or any guarantor, endorser, surety, or accommodation party dies or becomes incompetent, or revokes or disputes the validity of, or liability under, any guaranty of the indebtedness evidenced by this Note. In the event of a death, Lender, at its option, may, but shall not be required to, permit the guarantor's estate to assume unconditionally the obligations arising under the guaranty in a manner satisfactory to Lender, and, in doing so, cure any Event of Default. Cure Provisions. If any default, other than a default in payment is curable and if I have not been given a notice of a breach of the same provision of this Note within the preceding twelve (12) months, it may be cured (and no event of default will have occurred) if 1, after receiving written notice from Lender demanding cure of such default: (1) cure the default within fifteen (15) days; or (2) if the cure requires more than fifteen (15) days, immediately initiate steps which Lender deems in Lender's sole discretion to be sufficient to cure the default and thereafter continue and complete all reasonable and necessary steps sufficient to produce compliance as soon as reasonably practical. LENDER'S RIGHTS. Upon default, Lender may, after giving such notices as required by applicable law, declare the entire unpaid principal balance on this Note and all accrued unpaid interest immediately due, and then I will pay that amount. ATTORNEYS' FEES; EXPENSES. Lender may hire or pay someone else to help collect this Note if I do not pay. I will pay Lender that amount. This includes, subject to any limits under applicable law, Lender's attorneys' fees and Lender's legal expenses, whether or not there is a lawsuit, including attorneys' fees, expenses for bankruptcy proceedings (including efforts to modify or vacate any automatic stay or injunction), and appeals. If not prohibited by applicable law, I also will pay any court costs, in addition to all other sums provided by law. JURY WAIVER. Lender and I hereby waive the right to any jury trial in any action, proceeding, or counterclaim brought by either Lender or me Ll-'k 4 L.: 1 11, .. PROMISSORY NOTE Loan No: 180031111 (COrnflwed) Page 2 against the other. RIGHT OF SETOFF. To the extent permitted by applicable law, Lender reserves a right of setoff in all my accounts with Lender (whether checking, savings, or some other account). This includes all accounts I hold jointly with someone else and all accounts I may open in the future. However, this does not include any IRA or Keogh accounts, or any trust accounts for which setoff would be prohibited by law. I authorize Lender, to the extent permitted by applicable law, to charge or setoff all sums owing on the indebtedness against any and all such accounts, and, at Lender's option, to administratively freeze all such accounts to allow Lender to protect Lender's charge and setoff rights provided in this paragraph. COLLATERAL. I acknowledge this Note is secured by the following collateral described in the security instrument listed herein, all the terms and conditions of which are hereby incorporated and made a part of this Note: a Mortgage dated July 18, 2003, to Lender on real property located in CUMBERLAND County, Commonwealth of Pennsylvania. CREDIT INSURANCE.1 have chosen to purchase Single Life Insurance for this loan. Information concerning the premiums and the term of this insurance are set forth in the Disbursement Request and Authorization, all the terms and conditions of which are hereby incorporated and made apart of this Note. PROPERTY INSURANCE. I understand that I am required to obtain insurance for the collateral securing this Note. Further information concerning this requirement is set forth in the Mortgage and in the Agreement to Provide Insurance, all the terms and conditions of which are hereby incorporated and made a part of this Note. SUCCESSOR INTERESTS. The terms of this Note shall be binding upon me, and upon my heirs, personal representatives, successors and assigns, and shall inure to the benefit of Lender and its successors and assigns. NOTIFY US OF INACCURATE INFORMATION WE REPORT TO CONSUMER REPORTING AGENCIES. Please notify us if we report any inaccurate information about your account(s) to a consumer reporting agency. Your written notice describing the specific inaccuracy(ies) should be sent to us at the following address: ORRSTOWN BANK P.O. BOX 250 SHIPPENSBURG, PA 17257 GENERAL PROVISIONS. Lender may delay or forgo enforcing any of its rights or remedies under this Note without losing them. I and any other person who signs, guarantees or endorses this Note, to the extent allowed by law, waive presentment, demand for payment, and notice of dishonor. Upon any change in the terms of this Note, and unless otherwise expressly stated in writing, no party who signs this Note, whether as maker, guarantor, accommodation maker or endorser, shall be released from liability. All such parties agree that Lender may renew or extend (repeatedly and for any length of time) this loan or release any party or guarantor or collateral; or impair, fail to realize upon or perfect Lender's security interest in the collateral. All such parties also agree that Lender may modify this loan without the consent of or notice to anyone other than the party with whom the modification is made. The obligations under this Note are joint and several. This means that the words "1", "me", and "my" mean each and all of the persons signing below. PRIOR TO SIGNING THIS NOTE, I READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE. I AGREE TO THE TERMS OF THE NOTE. I ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS PROMISSORY NOTE. THIS NOTE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS NOTE IS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW. BORROWER: <.. LUT E , Individ ily USER PRO Lending, Var. 3.22.00.002 Copr. Harland Financial Solutions, Inc. 7007, 2002. All Rignu Rasa-ad. - PA O %CFnLPL1D2QFC TR-5010 PR-2 I 4?? R4 ?.? RECORDATION REQUESTED BY: ORRSTOWN BLANK ` : , ?... MANOVIR STREET OFFICE `D lr `uri 250 NVP MMMG, PA 17257 03 J(/(2 N CUNT WHEN RECORDED MAIL TO: HIS 1113 . PORRSTOyyI BLANK .0. BOX 250 BH PPBMMG, PA 17257 MORTGAGE THIS MORTGAGE dated July 18, 2003, Is ltlede and executed balween LUTHER R PALAIER 108 N WEST STREET, CARLISLE, PA 17013 (Warred to below as "GralflDr") and ORRSTOWN BANK " address Is PO BOX 250, SHIPPENSBURG, PA 17257 (ref wed to below as -Lender-? Londw NT O;NMotOR<tTranE pht v5? ? ?? b the Its grants, barpekef, ?, to A MW build Idlowkvg deecrbed real • transient, rWeeea Conltrns and mortgagee letameta, t tamenbt,merrh an no a Y. , respect ittarNo; all water, vvaler Appurtenant her stow, and the rewrelans and royalties. Pp?rOft ? rtp_ dghle. walercciraes and ditch rights (Including stock In utlNas with dlich or hApaSon rtgfrtsk and Y oMarn wtih P+'cP?ya") b«Md retail CUMj8 P D WWWrt?without IrtYletion Y minamill, ati. BeoUhermal and tkflar tnatlera, ?fa Unty, 9/14/02 DEED DATED91140OAECORDED IN BOOK 257, ? Of N CARLISLE BORO °Re? The Red PrcPertY or ft address is commonly known as 105 N WEST STREET, CARLISLE, PA 17013. Grantor PnWmy asslgns to Under Of of Gratora right. Oft. and bearers In and to all prawns and tUttae MM of the Property and all Rants from the Property. M addition. Grantor grants to Landr a UnIlorm CommsrcW Coda sscurly Name! In the PwsonW Properly and Rents. THIS MORTGAGE, INCLUDING THE ASSIGNMENT OF ARM AND THE SECURITY INiEREBT IN THE ROWS AND PERSONAL PROPERTY, IS GIVEN TO SECURE (A) PAYMENT OF THE INDWTMINEMIS AND IS) PERPORMANCof OF ANY AND ALL OBLIGATIONS 1J1D6i THE NOTE 1N THE ORIGINAL PRINCIPAL AMOUNT OF $21,500.00, THE RELATED DOCK, AND THIS MORTGAGE. THIS MORTGAGE 18 GIYEIH AND ACCEPTED ON THE FOLLOWING TERMS: PAYMENT AND PERFORMANCE. Except as otherwise provided In this Mortgaga, Grantor WWI pay to Lender all amounts secured this M as tray become due and shell OW* pvtorm all of Grantors obligations under this Mortgage. DY ortgape POSSESSION fol" r AND MAINTENANCE OF THE PROPERTY. Grantor somas that Grams possession and use of the Property shell be govsmad by the Posesso n and, Use. Usti the oocunarvoe of an Event of Default. Grantor may (1) remain in Possession and control of the operate or manage the Properly; and (ol) collect the Refs from the Property. ProPecfy (2) use. OW to Moftn. Grantor necessary to preeerva value ti maintain this Property in good condition and promptly Perform all repairs, caplacenrants, and nainlenaroe Its . Compliance with Emrhownse al Laws. Grantor represents and warrants to Londi r that (1) During the period of GmnW* owns" of the Prop", there has bean no use, generation, manufacture, storage, Ireatrtwf, disposal, miease or throderpd rafaeas of any Hazardous Substance by any Person on, under, about or from the Property; (2) Grantor has no knowledge of, or reason to beleve that there has been, except p m previously t o. and Acknowledged by Lander In writing. (U any breach or Wolttlon of any Environmental Laws, (b) any use, generation. by any prior overuse or occupants treatment, t, disposal, release or threatened release of any Hazardous Subslenoo on, under. about or from the Prop" such rr by any and (n Except or as the Property, or (c) any actual or threatened Mfigation or deft of any kind by any person reloing to such m ; agent or a0ar authorized previously disclosed to and acknowledged by Lender In writing, (a) neNhr Grantor nor any want, SuDslanor. on, under. about t or Property, from the usar of Do Property stall use, generate, manufacture. Wore. treat, dlepose of or release any Hazardous and local lows, regulations and ordirances. Innagnwitho) ut Iany such activity mitation el mAron mrdW conducted Laws. ant r ? wlleUa PlceNbygents tb =* mithortme this on uupProperty on the wNhpae t abomak of tucch nspectge? ind tsstssac? or t3 Mo duo, Lender may doom appropriate to closer. In@ comp?b,rveof the construed to create any responsibility or Mablfly on the part of Lender by Grantor r r or to any shah be other for Lender's The re purposes and warranties only and shell not bs cotelnsd heraln are based on Orentors due diligence In Imwtigetlng ifN a an hemby, ( And waives arty future claims against finder for Indemnify or ootrbugon In the event Gfor rantor Htr buo ecoms treb es liablenoes for . Grantor cleanup renuptor or ohsnbYMa o releases s and such laws; and (2) agrees to Indemnify and hold harmless Leader against costs under which Lender may directly or Ind4ec0y sustain or suffer resulting m a b arty and all t1Wma. loses, Mortgage kbM#sk damages, npenalties, seq a end aspen any gerldratiprior on, rranufr,e, storeQe, dNPDW release or fhreaHenaddrrWraaeoccurrlmg this swoon to of OraIators Ora o cotmepun t of any use, whelhar or not the same was or should have been known to Grantor. The of this b or Interest In obligation to indemnify, shot survive the a Pn and r o vo race of ot then f this Mortgage, Mortgage the shotn e Bowled by Lenders io YmsnU of the l In the the er by forecedenceudro or o o0iotherwianwlap Ice lien of this Mrtgapa and etas not be acquisition of any Interest in Ice Property. whether by a. Nuisance, Wade. Grantor shall not cause. conduct or Parmit any nuisance nor commit, permit, or suffer any stripping of or waste on or to the Property or any portion of sew Property. Wlhord Wiling the gumerality of the foregoing, Grantor will not remove, or prat to any other Party the right to remove. any timber. minerals (including at and ges), coal. clay, scone. Boo, gravel or rock products without Lenders Prior wrtftsn consent. Removal of Improvement& Grantor shall not demolish or remove any Improvements from the Rol P consent. As a condition to the remove) of any Improvements. Lender may require Grantor to make arrangements, Property without Lendan prior wrNlen such improvements with improvements of at Mast equal value. satisfactory to Lender to replace Lende rr' t Right is M and to . inspect Lander a Real s agents and representatives may enter upon the Real Property of WI reasonable times to attend to with Property for purposes of Granters compliance with the terms and conditions of this Mortgage. Compliance Governmental ~. of at g°tn?ha a f equicu ceble t0 the use shall ,?r?ff y? art laws, ordinances, and regulations, now or hereafter in ordina prior r dolati and withhold compliance, ry?? Y Proceeding. Including & Property. mGAPPa?alssmay o long contest C aIn Wth ntorg?as notified Lenhder In Grantor prior poet doing s e and so o or e s opinion, Lenders Interests In the Property we not t array bond, reasonably satlafacbry to Lender, to protect Lenders Interest. Lender may reglfre Duty 16 P?roltneo . Grantor agrees frneither om the Ab"on or and avve o unattended ceha? the Property. Grantor shall do all Dow ads. in addition to those ects ass TAX forth AND abL1e In this The on, the Properly are reasonably necessary to WOW and preserve the Property. following ; ENS. provisions relating to tho taxes and Doris on the Property are part of this Mortgage: Payment. Grantor shall whion dip (and In all events prior to d?? r? taxes. payroll tow, special taxes. assessments. water charges and saw service tha against or on account of the Pr sholl renftvd or material furnished to the Pro. Landw under this Mortgage, except for those hens aped maintain the, Property hse any Hers ehaving ptfor l priority over or equal done on or for services the keereef of due as further specified in the Right to Contest paragraph. agreed raetf to in writing by Lander. and except the Ito Ion of faxes and assessments not R19M I* Paley so b? Len Gr tsrsayf the Property rpayment of any tax, Assessment. or claim In connection with a good faith dispute over the obligation to Is not )eopardWd. If a Men arises or Is Mad as a result of nonpayment. Grantor shell within Mben 8K 1825PGO332 Exhibit rkC MORTGAGE Pap 2 (16) days ale the Oen srtees or, M a Ilan is fled, within Olken (15) days alter Grantor has notice at the MM feclre the dill-hargis by he llien der, dapcatt with Lander cash or • mu"IdInt corporafa surely bond or other security, se discharge of the Pon, or N any conlaat Granter s any coals and a0wneys' teas, or other Charges that could accrue as a result I8 to Lender in an amount Sufficient shag defend 111011 and Lender and shall Battey any adverse judgment baton mfult of a ant ro??e or sofa under the ban. In name Lender es an addndnal abtigee under any Surety bond furnished In the contest proceedings. gnat PrOParty Grantor shelf 8idetae of int. Granter shot upon dsmWW furnish to Lender satisfactory evidence of payment of the taxes or aeseesnhente and shall authorrna the appropriate gohernnrherhtet ofikW to deliver to Lender at any time it written statement Of the fazes and areeesnente again to PrGPant1'• 1a01ke of Construction. Grantor shall notify Lender at teat fifteen (15) days before any work Is earn need, any services are lurnishxd or any arterimis arm or me*"' h? wAl? Property, N any mechanlc's lion, matertelmen's ion, or other Ilan could be asserted on account of the work, services, cat of such krprovsmen request Of Lender }venial to Lender advance assurances eatlafadory to Lender that Grantor can and will pay the PROPERTY DAMAGE l"8U LANCE. The following Provfalon s relating to Insuring the Property are a part of this Marlow: MalnlWWM Of keurartee. Grantor shelf procure and maintain policies at fare Insurance with standard eudendsd coverage endosemenq on a repteanent basis for the U insurable wtlus oovenlg all ImProvernente on the Real Property in an amount 3WOdent 104 vow application of any cdneunnw clops, and with a standard mcriPM clause in favor of Lander. Policies shall be widen by such Ifewancs span les and In such form as may be NR@Wably aoospfabte to Lender. Grantor shall deliver to Lander arlMrba Of col,nape from each Insurer conpining a any stlPulNon dot ocvarage will not be canceled or dkninieled without a minimum of ten (10) days' prior written notice to Under and not cwftnkg coverape?In vor h Under wA10iba for m1dure to ? such noaa. Each insurance policy also that Include an endorsement pro ft that Property Ifavor In an area any way by any at omission or default of Grantor or any other parson. Should the Real agrees to obtain and maintain w Flood by the Director of the Federal Emergency Management Agency as a specyt flood hazard area. Grantor special flood fan and area. for the full u nuance. N avalable, within 45 days after notice is given by Lander that to P? maximum npab principal balance of the loan and any prior tens on the properly securing a located in the policy the form of the loam set under the National Flood Insurance Program, or as otherwise required by Lender, and to maintain such Insurance for falls two d o o of within billion Proceaft (6j r?Ilp ptY notify Lander of any loss or damage to the casualty. Whether or not Landers security Is Impatiretl?La mar rat makeander proof of lose N Grantor retain the proceeds of any Insurance and apply the proceeds to do reduction of the Indebtedness, y' eteg the reoetve and the restoration a and d it of t e Property. rt a manner Lander nNr > ? to apply the proceeds to restoration and r?epairaG Grantor Dan shelf repair of ,spice tier the or from tahdory to Lender. Lander shall, upon saNNactory proof of such apendture, pay or ntor restoration N Grantor is not in default under this Morlgage. Any prooseds the which YAth reimb have not been from the pr disbursed rasa ?80 da tailor le_ C real t repair or which restoration of Property shall be used Nast to pay any amount owing to Lender under this Marlow, tender lea aOt Committed b the repair or f hba mind be applied b the ptrcipat balance of the Indebtedness. If Lander h0lds nY prtan to pay accreted full of the and the remainder, e . suc If race stall be be paid to Grantor as Gmnbrs interests may appear. Drocoods after payment In full of the Indebtedness. such proceeds shall LENDER'S DES. If Grantor fafs (A) to keep the Property free of at taxes, Ions, security interests, encumbrances, and other deft, (S) to provide any ngWnd Insurance an the Property. or (C) to nuke repairs to the P commenced that would materially affect Lender's Interests in to rcWr1Y than Lender may do sIs If any action or prooesdnp is that Lender believes to be appropriate to protect Lenders intoa AN o than Lender on Or Paid by Lender for may. but Is not required to, take bear ar Interest eat at the reds charged under to Nob from the dab Incurred or paid by Land the date of f repayment by Grantor. At such ar?aees em will become a part Of the hhdebbdnon and, at Lenders option, will (A) be payable on demand; (B) be added to the balance of the No4anndbe apportioned a pert and be payable with any installment payments to become due during either (1) the term of any applicable insurance policy; or (2) the remaining term of the Note: or (C) be treated asababoon payment which will be due and payable at the Noble me". The Mortgage also will secure payment of atheme ccount amounts. The rights such _ for In Oft paragraph shelf be In addition to any other right or any remedies to which Under may be entitled on would have had. default. Granter tlsuch an toton by Lander shd not be owntrued as curtrg the default to as to bar Lender from any remedy that tt otherwise w old have h DEFENSE OF TITLE. The beder for all such manses Shall survive the entry of any mortgage foreclosure judgment. rag provisions retailing to ownership of the Property we a part of this Mortgage: Tile. Grantor wwmtB tat: (a) Grantor holds good and merkstable tihte of record to the Property in encumbrances other than those set forth In the PAW Property description or In any fps Insurance , be of p elite' free and clear n ion all Is a and final favor of, and accepted by. Lander in comacton with this Mortgage, and (b) Grantor has the full rightPower, and authority a Bute and deliver this Marlow to Under. Defoe of Tills. Subject to to exception In the paragraph above. Grantor warrants and will forever defend the tits to the Property lawful claims of all pwsons. In the even) arty action or proceeding Is commenced that question Grantors ft or the Interest of Lander under this onOW alp the arlo to parti cantors in delmind the action at Grantors axpsree. Grantor may be the nominal party in such proceeding, but Under shall be n1prowl9al In cause to be delivered, to Lander suchh Instruments as Lander may the prOaed? by t counsel of Lenders own ohdos, and Grantor will datver, or Compliance _ _ may request from time to time time to permit such participation. utthat ey Property and Grantors use of the Property complies with all oxlsti ordinances and regulations ofrardar governments! nB applicable laws, Servhal of Prometew All promises, agreements, and statements Grantor has made in this Mortgage shall survive the vocution and delivery of this Mortgage, *Me be continuing in nature and shall remain in full fora and effect un8 such time a Grantors Indebtedness is paid in fut. CONDEMNATION. The following provisions relating to condemnation proceedings are a part of this Mortgage: Proceedinga If any procesdkg in condemruflon is filed. Grantor shall promPOY ncYlY Lander In writing, and Grantor shall promptly take such stops es may ba reasaary b defend the action and obteln to award. Grantor may to the nominal party In such proceeding. but Under aloe be snlNbd to partldpab In the fxoeeedrg and to ba ra(xseented fan the prooesdlrg by counW of its own choice, and Grantor gwig , dMver a ruse to Ener from time to time to permit such Participation. domain Proceedings or by any P?oceedng or purchase t repair Or reafOretlOn Of the Property. The net proceeds Of the award shelf mesn the pr proceeds O the award be applied to the Indebtedness after noys' yes incurred by Lander In Conrhectlon with the condemnation. payment of at actual costs. expenses, and IMPOSITION OF TAXES, FEES AND CHARGES BY GOVERNMENTAL AUTHORITIES. The following provisions relating to governmental fazes, (see and charges are a part of this Mortgage: Current Taxes, Fees and Charges. Upon request by Lander, Grantor shall mmuts such documents In addition to this Mortgaq and take whatever other action is requested by Lander to perfect and continue Landers tan on the Real Property. taxes, as described below, together wNh all apsnaes Incurred In recording. perfecting continuing this Grantor shag ng without Lender for an fhb Mortgage, indttd amaation as taxes, lea, documentary stamps, and otter charges for recording or registering g this Marlow. r?& The following *W oonstlule faxes to which trim section applies: (t) a specific tax upon this We of Mortgage or upon all or any part of the IndebtednNS secured cure by b thiOft s Mortgage; (2) a apadec tax on Grantor which Grantor Is authorised or payments on by type of Mortgage; (3) a tax on this type of Mortga ngWren a deduct from and (4) a specific lax on all or any portion of the Indebtedness or on ge chargeable against the Lender or the hider of the NOW Subeequerrt Tows. If payments of principal and Interest nude by Grantor. stash as an Evert of tax to which this section applies Is enacted subsequent to the date of this Mortgage, this avant shat have the sane ether (1) pays the fate ?a and It ? wa else any or all of to available remedies for an Event Of Default as provided below unless Grantor Lander ash or a suf dent delinquent, a (2) contests the lax to provided above In the Taxes and Lions section and deposits with corporate surety bond or other seolxily satisfactory to Lander. WCUR17Y AGREEMENT; FINANCING STATEMENTS. The following Provisions raising to this Mortgage as a securty agreement are a part of this Mortgage: Securely Agreement. This Instrument shall constitute a Security Agreement to the extent any of the Property constitutes futures, and Lander shall have elf of the rights of a secured party under the Uniform Commercial Code ad amended from time to time. Security Interest. Upon request by Lender, Grantor shat execute financing statements and take whatever other action Is requested by Lender to aK 1825PG0333 MORTGAGE (Continued) Pop 3 perfect and continue Landsrla sscudty keenest in the Personal Property. In addition to recording this mortgage In to raft ply Lando may, at any Ime and without further auw a aation from Grantor, ft suascufad counterparts, copies or "product" of art MOVW 111111MMIL Grantor shall reimbse rod femove, ewer or deteoh the mP qhr for an ear omt Incurred . peAsclrg or coMNWng ti. Security kterest. Upon a dallault, Slid the Property in a manner and at a plant from the convenient Upon ??, Granter spa 4s- t- any Peraonst Property not afbrd to 110010 of writer demand from hander to the convenient 10 Gramcr and Lando and make l evaNabN to Lender within three (3) days after satimi per, by Applicable law. A granted ddreane. The making tddraasee Of Grantor (debtor) and Lander (secured p") from which inlonrrYon conosmi g Ina Security interest FLt1T1#R by this MwWW may be obtaksd (each As required by the UNbrm Comrryroyl Coda) are ee Mabd on this Oro page of tie Mwlpage. a part of thk: ADDITIONAL AUTHORIZATIONS. The blowing provisions relating to father eminences and additional atthotenlors are ortpage: Further Aeemeloeg. At Any tine, and from time to time, upon request of Lander, Grader will make, eaecute and delver, or will aura to be as this case i delMarad, to Lender or 10 L#ndtrh dSstgnee, and when raO=W by Larder, cause to be ttW , warded, marueocrsad l deeds of friar, may be, of such tkmnaa and in Such oboes and places as Lander may class" appraprltlt, any and sl Such ?WM deeds. security agreements, financing steterrsnts, ocnitnudon sblanwrig, inshun aria of Refer allemande, and other documents as may, In the sob o*lw of Lanier, be necessary or desirable in order to etteduate, eonpyye. oerMioatee. oblig , OWWAN, or GrankA Md Milk us ations by prilservis this (Mortggpe as *d and prior taro on the Nft #4 Mortgage. and the Rd, prtrasef Documents, and (2) the Isss and Security it ft is created agrees to the conlrary in writing, Grantor shah rein mnbwse Lander fnow or a?ind mrperims; IrKv by r.ecl with the makers ?ke to in this paragraph. AddM Cn@i AUVWUAllone. If Grantor tans to do airy d the things referred to In tie preceding paragraph, Lender may do so for and In the name of Grantor and at Grantor's aopanse. For such purposes, Grantor hereby irrevocably authoAma tender to make. eaacub. driver, RS, record and do All Other things AS may be necessary or dmkabb, In L eaft sob opinion, to accomplish to matters relerred to In the pmWng paragraph. H Is understood that noting ass tofh harem go require Lander to take any such acoom FULL PERFORMANCE. M Grantor pays all the Indebtedness when due, and otherwise pmts,, ail the obligation imposed upon Grantor under this Motgaps. Lender stela arrcub and deliver to Grantor a sultebb eelefecbn of tie Mortgage and suitable staWnants of termination of any financing statement on flu ayidenoing L.ender% moistly inisin In the Rants and the personal prop". Grantor win PAY, I permitted by aWk" law, any reasonable Isrminslon fee ee ddsi n d by Lender from lme to Ime. EVENTS OF DEFALLT. At candies option. Grantor will be In default under this Monpage it any of the following happen: Payment DO M. Grantor falls to make any payment when due under the Indabtednme. D~ an Oom Pei I ailure Other payment necessary 10 PraFvwd fil? d of Grantor within the or to etsc discharge required by this Mongags to rnaks any Payment for taxes o Insurance, or any of Any Non, "0 ODW Prermtlees. Grantor breaks any promise made to Lander or fails to perform Pr-PIY At the Imo and strictly In the manner provided in this Mortgage or in any agreement related to this Mortgage. FAA Shbmonte. Any representation or statement made or furnished to Lender by Grantor or on Grantor's behalf under this Mortgage or the Related Documents Is tales or misleading in any material respect. ether now or at the time made or Imntehed. 0000" COIagaUltiOn. This Mortgage or any of the Related Documents oases to be In full fora and effect (Including failure of any collateral document to oroate a valid and perfected aeeutty Interest or lion) at any time and for any reason. sea Death (w I for the rsftt Of credits, grantor, the Insolvency of Grantor, the appddment of a racstusr for any put of Grantor's property, any laws b or nY hype of creditor wok A or the cammanoerrent of any proonding undo any bankruptcy or laws by or a against Grantor. However, the death of any Grantor will not be an Everd of Dsleul ti as a result of to death of Granathe fully covered by credit Its insurance. has of he This ropedae AnWft y d*editor or governmenW agency trim to take any of the Property or any other of Grantor's property In welch Lander the claim on which the tail Nhe Nag of or tevtMq on GraN" Accounts with Larder. However. I Grantor dteputes in good tenth wtslher Lender with monies or e properly r bared veld or reasonable, and I Grantor ohm Larder anltltn notice of the claim anfurnish" surety bond Satisfactory to Lender to 3gtlsfy aty #0 the claim. than this dsfeul provlalon will not apply. ?nY grace Period P WL Any bra h by under Grantor the Wm Of any other Wasimant between Grantor and Lander amt is not remedied within Lender, whether atdseng now or later. Including without any agreement concerning arty Indebtedness or otter obligation of Grantor 10 Event All FSng Guaranlor. Any of the preceding events occurs with respect to any guarantor. endorsor. surety, or accommodation party d any of the Indebtedness w any guarantor, endorser, surely. or swOmmodalon party dles or becomes Incompetent, or revokes or disputes to validity of, or Iebft under, any Qum* of the Indabtodrtees. In the went Of a death. Lander, at IS option. may, but 00 not be squired to. Penn the a"aa Erarvtoco t of e? assume unconditionally is obligations arbing under the guaranty in a manner salsitctory to Lander, and, in doing so, oars Rlghl b Cure. If such a failure is curable and I Grantor has not been given a nice of it broach Of the same provision of this Morlpags wMtn the precedino twelve (12) months. I may be cued (and no Event of Default will have occurred) if Grantor, after Lander ands written note demanding one Of such feWro (a) curve the failure within mean (15) days; or (b) I the cure requires more than fifteen (15) days, Immediately inltistee atepe suflldut to cure the tenure and thereafter continues and complain an reasonable and necesaery atspa autncisnt to Produce compliance as anon as reasonably practical. RIGHTS AND REMEDIES ON DEFALLT. Upon the occurrence of an Event of Default and at any lime theraatler, Lander, at Lenders option, may torercise any one or more of the following rights and remedies, In addition to any other rights or remedies Provided by law: Accaienle Mdabbdno$L Lander shall have the right at NO option, after ping etch notices as required by applicable law, to declare the entire Indebtedness immediately due and payable. RR to all or any part of the Personal Property. Lander shill have an the rights and remedies of a secured party under the Uniform Commercial Code Contact Rwtte. Larder $hall have to right, without notice to Grantor, to take possession of the Property and collect the Rents, Including amounts pest due and unpaid. and apply the rat proceeds, own and above Landoy cats, against the Indebtednoe. In furthwnes of this right, Lender than Grartorakmrevoocably aauthor? Untlsrr to Prop" ere UsMOO kum?ts rowived in or payment use payment tfew hhderiscoaof lay M to the Lads name of . f the R Grantor obb t collected by Larder, and Cc14ct the Proceeds. Payments by terente or other users to Lando in response to LAMM% demand 511411 and d to negotiate the same the payments are made, whether or not any proper grounds far the demand existed, Lender may wairclae ft nighty unndder the this a? Mors for alt her person, by apart, or though a rwelver. Paragraph anher In Appoint Realer. Lender 311411 have the right to have a rashly appointed to take possession Of all or arty part of the Property, with the power to protect and preserve the Property, to operate the property preceding foreclosure or orb, and to ddisct the Rata from the Property and apply the PrOCOOds. owroandabove the cost of the reaherahiP, against the Indebtedness. The recsiver may sow without bond if permitted by law. Lender's right t the appointment of a reoelver shell NW whetter or not the apparent vetua Of the Property eoaeeeds the Indebtedness by a substantial ern oud. Employnwt by Under shah not disqualify a person from aervtng as a soeiver. Judicial FOredbeura. Lender may obtain a Judicial dories foreclosing Grantor's inim I In as or any pen of the prop". NOnJ KWW Sale. If permitted by applicable law, Under may foreclose Grantors Interest in ail or in any pan of the Personal Property or the Real Properly by n-qudoist sale. DokWW Judgmer f. Under may obtain a Judgment for any delcleney re"Ming In the Indebtedness due to Lander after appioslon of all amounts received from the eorarclas of the rights provided in this section. Tenancy at Sut wance. If Grantor remains in possession of the Property after the Property is add as Provided above or Lanier dherwlae becomes 0~ to possession of the Property upon default of Grantor. Grantor shad become a bream at aufterancs of fonder or On pucheser of?this latProperty and Shall, at Lender's option, either (1) Pay a rassonable rental for the uee of the Property. or (2) vaate the Prop" Immediately upon the demand of Lender. BK 1 82SPG0334 MORTGAGE (Continued) Page 4 O Sale of No ther Reeradho. Lander shall have of other rights and remedies provided In Chia Mortgage or the Nola or available at few or in equity. PMPWW. NW g ?To the cadent p by apt?abte law, Grantor hereby waives any and all right to have the Property marshalled. In No rights or tiny ache. Lender a1Wl be antltl?id tooWdatit?, public be *in to sale on o? any portionofof the the together or separately, in one asN or by typ,aro Itioap of S" Lender will give Grantor reasonable notice of the time and piece of any public safe of the Personal Property or of the time after which any private sale or other intended d $PCaltlon of the PWWW Prop" is to be made. Unless otherwise required by applicable law, reasonable rtolfa shelf mean notice gives at Nael ten (10) days before the time of ft sae or disposition. Any sale of the Personal be made In conjunction with any sale of the Red Property, Property may M- F 11An of ReeNdes. AN of Lender's rights and romedles will be cumulative and may be warciwd alone or together. An election by Lander to choose any ne 9m n9mad y will not bar Lender from using any oiler romody. If Lender decides to spend money or to perform any of Grantor's obligations under ortgage, OW to sfeectss Lender's lesatlx Gmnore felfure to do so, that decision by Lender will not affect Lender's right to declare Grantor In default Anorneye Filer DtVMsae. M Lender institutes any suit or attim to enforce any of the terms of 06 Mortgage, Lander shall be wooled to recover such sum as the court any od* ae a??, foss at kW and upon any appeal. WanOw or not any court action is Invdved, and to the silent not stponsee Lender Incurs that In Lender's opinion an *m for the protection of Its Inhead or the entorosment of its nights shall become a part of the Indebtedness payable on demand and >f?lfat a r Irate se at the Nola rap from the data of the algertdlfl re unlg repaid. Expanep covered by this paragraph Include, without Imtiaoon, however subject to arty limits under applicable lew, Lender's attorneys' Nos and Lertdera NWf axpsnaee, whetter or rat Mere N a lawsuit, including attarr"' fees and wperaes fee aoolfacion servlae? cant a?aeaegntrM fneearcle, obfaferitvaap arty eubmetlo spy all unction). Appeals, and any anticipated poxHudgment title hwnna, ro the ardent 9 rig tale repata (Indudirtg roreoloeurs reports), surveyors' reports , and appralsal permiMsd by IPPticabb few. Grantor atso will psy any court call. In addition to all lap she ItOT1CE$. Unless otherwtes provided by appltable lew, any rlotloe requires ro be Ion under Mte other same provided by kw. eMectlvs when actually daNversd, when actually mcetvsd by faNleairntN (anuses otlterwlss Maigaga shWh be given deposited e In writing, as d shall be required ftl to Mite efiowrn nsei t?hiMbeg nnlrg they MoaMed in lee united slefee mil, a first dace. OwMW or registered mail postage prepaid, directed nallonalty M w ortgags shill be sent to Undoes addmes, as shown?n v Me b inrtrg Mfarrdure from the holder of any lien which has priority over ft under this Mortgage by gMing ormaal written notice to the otter parson te, ?" fylrp thaAny t p the person Is heto x chai han address t for ndlas purpose of the may f the n his notice or address. For notice purposes, Grantor ogress to a pat a es of Grantoes se pr Person's applicable law, N them le more than are Grantor. any woLender e d n by?nder at to any Grantor Is do curt to address. gUnit= iven t at Grant provided by Grantor's raeporisgity o fell the others of the notice from Lender. Y deemed to be radloo given to aft Grantors. It will be MIsCmIAIE" PROVISIONS. The following miscellaneous provisions are a part of this Mortgage: Mrandreents. What Is written In this Mortgage and In the Related Documents is Grantor's entire agreement with Lender conmr, rig the matters covered by this Mortga effective boundobligated by he chaTo be nge or dmeint Qe or amendment to this Mortgage moat be In wANrp and must be "nod by whoever will be Caption Hidings. Caption headings in this Mortgage are for convenience purposes only and are not to be used to interpret or door* the provisions of this Mortgage. Igo Waftrer by Lender. Grantor unciarstends Lender wig not give up any of Candor's ' hts under this Mortgage unless Lender does so in waiting. that omits to in up of rights, The ante Lenders slays Mtn does n sc mean ny right will will n not an Met have to comply Lender hex given up that right. If Lander does agree In writing to give h appens again. further that NFL^is der do uorn" to a request, that does not mean that ? II the nab ? h Hof this Morlg? Grantor also will be required to consort to ndarelends that just because Lender consents to one or more of Grantors consent rOQUUtL again ti the situation mean arty of Grenfora future requests. Grantor waives presentment, demand for paymeent protest a?nogiadishonor. finds of this bogy. If wet not be that any nof this Mortgage is not valid or should not be enoroed. that fed by Itself will not mean that the rest valid or enforced Mortgage may be found to be Invalid or unenforceable. e, a court will enforce the reef of the provision of this Mortgage awn N a provision of this Morgan. There shag be no merger of the Interest or estate croatod by this Mortgage with any otter interest or "to In the Properly at any time held b or for the bernsllt of LarKdor in any capacity, without the wditn consent of Lender. SUccownir fiders The forms of a , an lab be enforceable his LMor e der anti it be cbinci esso anted Grantor, anti upon (imrttors heirs. Personal representatives successors. Time Is of No Essence. Time le of the ssssnos In the performance of this Mortgage. DEFINITIONS. The following words shoo have the following meanings when used In this Mortgage: Borrower. The word Borrower" meone LUTHER R PALMER and Irduutes an 00-signers and co-makers signing the Note. Envwm arrW Laws. The words'Envlronmental Laws" mean any and aft state. federal and local sfeoles, regulations and adinanoes releft to the protection of human hearth or the environment. Including without limitation the Comprehensive Environmental Rl Liability Act of 1980, as amended. 42 U.S.C. Section 9801, at seq. ("CERCLA*). the Suparfund Amendments and Roras ??? ,and L. No. 58-498 ("SARA', the Hazardous Motorists Transportation Act, 49 U.S.C. Section 1801, at o'?ab^ on Act , of 1 Roc Pub. Act, 42 U.S.C. Section 8901, at seq., or other applicable state or federal laws, rules, or regulations adopted pursuant a and eeavey Event of Dahull. The words "Event of Default" mean any of the ovents of default set forth In this Mortgage In the events of default section of this Mortgage. Grantor. The word "Grantor" means LUTHER R PALMER. Guaranty. The word "G annMa ens the guaranty from guarantor, endorser. surety, or accommodation party to Lender, Including without limitation a guaranty of all or Hazardous des. The words "Hazardous Substances" mean mttotats that, because of trek quantity. concentration or physical. chemical or Infectious charaobrlea?.?y cause or pposo transported or potential hazard to human health or the environment when improperly used, treated, stored. disposed of, or Otherwise handed. The wads "Hazardous Subs broadest sense and include without limitation any and as hazardous or fordo substances, materials or waste as doll ed by used in than wry Environmental Laws. The tern "Hazardous Substances" also Includes, without limitation, petroleum and petroleum b Y or titled under the thereof and asbestos. Y prodoMls or any fraction Improvements. The word Improvements" means all existing and future Improvements, buildings. structures, mobile homes affixed on the Real Prop", facilities. additions, replacements and other construction w the Reel Property. lndebtednaL The word "Indebtedness" means all principal. Interest, and other amounts, costs and woo ses payabie, under the Note or Related Documents, fog *w with aI renewals of, extensions of, modifications of, consolidations of and substitutions for the Note or Related Documents and any amounts amended or advanced by Lender to disc obligations under this Mortgage. topether with Interest on such amounts ProviddedaIn this Mortexperen g Incurred by Lender to enforce Gnntors age. Lender. The word 'Landee means company that acquires any Interest In the a Nsote N BANK its successors and aaslgna. The wads 'aupCessors or assigns" mean anytvlpgpt51G p 3 Mortgage. The word "Mor*W means this Mortgage between Grantor and Lender. bid 1 J Note. The word "Note" means the promissory note dated July 18.2003. In the origInal principal ournount of $21,000.00 from Grantor to Lender, together with as renewals of, extension of, modifications of, refinancl or agreement. The maturity date of thus Mortgage Is July 18, 2018. ^es of, coraCldations of, and substitutions for the promissory rep Personal Property. The words "Personal Property' mean sit equipment, Ixturn, and other arocNa of by Grantor. and now or henaMar attached or afbed to the Red Pmpery; together with so accessions, Personal property now or hereafter owned and of subsltudons for, any of such property; and Puts, and additions to. a and refunds of all rePlAmmorris of. premiums) from any sale or other disposition of the Property with all Procesda (including without NmtteNon all inaormorapa proceeds and of Property. The word "Property" means collectively the Real Properly and the Personal Property. IK I PG 0335 MORTGAGE (Continued p? 6 RsY Property. TM Words 4itW Roparty' mean Mts nal properly, inbrsats and ripMs, as htnMr dsscribad in mh Matpapa. Relabel DoClMttanb. Ths words 'TitNabd Dootatrnls" mean aN Prorttlaery ? txedt aprsemartts, loan aprNntsnb, emAroratwtbl alb 0 >? apresntenb, mtxfpapea, ttssda tN iruat, asctxriy deeds, COINMd tntxgapse, and a1 dher I documetls, wtteUter now tx haraalbr odstktp, smeculad In txnnecgon wlm dts Indsblsdrtetta. ' Ranh. The ward 'Tianb' means aR prasNtt and tuttxe nMs, rawntws Irwwme, ksuss, royaltla, proES, and oMter berttrAb darlwd from Mts PropartY• GRANTOR ACICNOWL®GES ttAVING READ ALL Tl! PRO'V191pN8 OF TNIB MORTf'aAGE, AND GRANTOR AGREES TO ITS TERMS. THIS MORTGAGE IS GH1BI IJ1lDBt SEAL AND IT IS INTENDED THAT THIS MORTGAGE Ni AND SHALL CONSTITUTE AND HAKE TFf EFFECT OF A SEAL® INSTHUMlNr ACCpiDNIG TO LAW. X X CERTIFICATE OF RESIDENCE I hereby cerYfy, mat the predse address of the mtxlpepes, ORRSTDWN BANK, Itenin is p follows: FIANOVER STREET OFFICE, PO BOX flee, SHIPPEN86llat0, PA 17867 ttam?y arAeml ro artp?eq INDIVIDUAL ACKNOWLEDGMENT COMMON1NEAt.TH OF PEMlBYLYANIA ?SS COUNTY OF l ,( /YK ?l ? Y LY/>LC ? on m?, the /? day to Qo proven) b bs the psnwn whose nanw k 1o the ?1 Iaetrumw?M, ar?sc?now sd1Mf?M ?dPsla seascuMd lM wms for tttttrsln oonbined. r? C?n3berl?nd +Cot?I,,,, r. ? .. '.t?' ?iY n/. -r ??^ ?? l `t\ ? 7` 8K 1825PG0336 In rrtirlees wMreof, I Iteraltllto tMt my hand and ollldp aril. Nobry PubNo In antl for ms Stab , j A _. M M .. M A W 13 C3 + _Q T3 1.n ^ ni .? 1300 A O t.n 0 g 0 1 ry O OD C 1 ?.. 3 aka .r =r a ?P 5 7 1 ? P"WEV .ovens 02 1A $ 01.05° 0004623436 JAN 10 200f 7MILED FROM ZIPGODE 17 2 5 i Z a LL O Z o \2 'AN 08 0 a J Y. O < ii I t2 z ? Lf) ID m V0 v E > 2Z oZ a - W o? o. a C o Q V) d O R ?2 W LL d 0 d G C,j m > p , a d 0 0 ID O a b r J 1 1 e I ? U.S. POstal Se rvice ut 0" 1 ¦ (DOmeslic Mail Only NO Insuranc e Coverqgp • . r . OFFI CIA L USE C u Postage $ r? 4 11 0 C- ow Fee S PF / C3 Aetu (Endo?semenm tt R.*, = • \? Cn ` +V q ? Fee (Endorseme Restrtcxed DnteliveRequryired) as C L o v' C3 Total Postage & Fees $ O [7 [ti Exhibit "D" ORRST O" BANK A Tradition of Excellence January 10, 2008 Luther R. Palmer 1805 Furman Street Ruston, La. 71270 7oc? L'cF/o oocZ aygV,7?s c(opy Return Receipt Requested and Regular U. S. Mail ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE is attached pages a e be able to help to save your home v ~JJ?J Hnt,t rn This Notice explains how the program works To see if HFMeD ^. ,, i%^i- .._.. N D You meet with the Counseling Agency game, address and phone number of Consumer r Countv ara IictnA ,# #"- ---j _l -I- - .. .. -- impaired hearing can call (717) 780-1869).. e u This Notice contains important legal information. If you have an representatives at the Consumer Credit Counseling Agency may be able to help explains 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. r MER CRE is dit Exhibit "E" P.O. Box 250 • Shippensburg, PA 17257 • 717.530.3530 • 717.532.4143 fax 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): Luther R. Palmer PROPERTY ADDRESS: 408 N. West Street Carlisle, Pa. 17013 LOAN ACCT. NO.: 180031111 ORIGINAL LENDER: ORRSTOW I BANK CURRENT LENDER/SERVICER:ORRSTOWN BANK HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HO FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS vI = YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTAN('F vni I RAI IQ-r EP CU E CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, you for thirty (30) days after the date of this meeting. The nathe mes e addresses* and to ee hoacon against ne numbers of designated consumer credit counselin a encies for the count in which the property located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's. Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT Brin it u to date).. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 408 N. West Street Carlisle Pa. 17013 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: October 18th--$ 89-43- November 18th __$ 195.72 and December 18tH 195.72. Other charges (explain/itemize): LATE CHARGES--$ 70.72 TOTAL AMOUNT PAST DUE: 551.59 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this $ 551.59. 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 ORRSTOWN BANK ATTN: BETSY SMITH P.O. BOX 250 77 EAST KING STREET SHIPPENSBURG, PA 17257 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 ri hts to accelerate the morta e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgage property IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period. von will nn+ tie ..e,...:--I 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 revent the sale at an time u to one hour before the Sheriff's Sale. You may do so by pavina the tntal amni m+ +k-- ___.& A.- _ s tees a the 'mortgage dsCuring your default inhthle mannedr setp forth mortgage to the same position as if you had never defaulted. s 31 1y Ull:er costs connected with the ling any other requirements under in this notice will restore your 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 5 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: I•0111V yr Lenaer: prrstown Bank Address: P.O. Box 250, 77 East Kin Street Shi ensbur PA 17257 Phone Number: (7171 SIn_9aa4 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be t rtedtby the lender at any time. ASSUMPTION OF MORTGAGE - You MAY NOT sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding attorney's fees and costs are paid prior to or at the sale and that the other equire entgseof 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 THOE 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 DEFENCE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, ?9 BETSY J. SMITH, COLLECTION DEPT. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY.0 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg North 6t' Street Harrisburg, PA 17101 (717) 234-5925 Fax (717) 234-9459 Adams County Housing Authority 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 Fax (717) 334-8326 Community Action Comm. of the Capital Region American Red Cross -Hanover Chapter 1514 Derry Street 529 Carlisle Street Harrisburg, PA 17104 Hanover, Pa. 17331 (717) 232-9757 (717) 637-3768 Fax (717) 234-2227 Fax (717) 637-3294 Bedford-Fulton Housing Services RD #1, Box 384 Everett, PA 15537 (814) 623-9129 Fax (814) 623-7187 Financial Services Unlimited 31 West 3`d Street Waynesboro, PA 17268 (717) 762-3285 °v n^ 1 ° O CI c ! 1 I SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2008-02156 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ORRSTOWN BANK VS. PALMER LUTHER R R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT PALMER LUTHER R _, by United States Certified Mail postage prepaid, on the 4th day of April ,2008 at 0000:00 HOURS, at 1805 FURMAN STREET RUSTON, LA 71270 a true and attested copy of the attached COMPLAINT - MORT FARE Together with The returned receipt card was signed by RETURNED AS "UNCLAIMED" on 00/00/0000 . Additional Comments: Sheriff's Costs: Docketing Service Affidavit Surcharge So answe Y 18.00 6.28 Thomas Klin .00 Sheriff of Cumberland County 10.00 .00 34.28 sfQ 08 Paid by OBRIEN BARIC SCHERER Sworn and Subscribed to before me this day of on 05/07/2001 A.D. ORRSTOWN BANK IN THE COURT OF COMMON PLEAS OF 77 EAST KING STREET CUMBERLAND COUNTY, PENNSYLVANIA SHIPPENSBURG, PA 17257 Plaintiff NO. 2008- 2156 CIVIL TERM V. ; LUTHER R. PALMER MORTGAGE FORECLOSURE 1805 FURMAN STREET RUSTON, LA 71270 : Defendant PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Complaint filed in the above matter on April 4, 2008. Date: August 13, 2008 Respectfully submitted, O' , BAR11 & David A. Baric, Esquire I.D. 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 ?` ?!r ?-., ?. ? ?' ? r-rg -r `- r_ L t " w,; " a C_, -? a,_ V ' ? ? ''?°' ? ' ' ? r-r ,? : ?: ? --<? ?.? i .w. --? ORRSTOWN BANK IN THE COURT OF COMMON PLEAS OF 77 EAST KING STREET CUMBERLAND COUNTY, PENNSYLVANIA SHIPPENSBURG, PA 17257 Plaintiff NO. 2008- 2156 CIVIL TERM V. : LUTHER R. PALMER MORTGAGE FORECLOSURE 1805 FURMAN STREET RUSTON, LA 71270 Defendant PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Complaint filed in the above matter on April 4, 2008. Date: September 23, 2008 Respectfully submitted, JON,. S R D avid A. Baric, Esquire I.D. 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 ?? N W ?? ? ? ? ..? . L' , a ? ?1 ,. .. q ' t J \,. ' 3 ? _ ? G , ? 4 „ `? ?, N ?, 4 ? SHERIFF'S RETURN - U.S. CERTIFIED MAIL I CASE NO: 2008-02156 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ORRSTOWN BANK VS. PALMER LUTHER R R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT PALMER LUTHER R by United States Certified Mail postage prepaid, on the 1st day of October 2008 at 1000:00 HOURS, at 115 COLLEGE DRIVE ST PAUL'S COLLEGE LAWRENCEVILLE, VA 23868 and attested copy of the attached COMPLAINT - MORT FORE with a true Together The returned receipt card was signed by LUTHER R PALMER on 00/00/0000 . Additional Comments: Sheriff's Costs: So answ Docketing 18.00 Service .59 R. Thomas Kline Certified Mail 6.41 Sheriff of Cumberland County Surcharge 10.00 .00 35.00 ? 1012PJ° Paid by OBRIEN BARIC SCHERER on 10/21/2008 Sworn and Subscribed to before me this day of A.D. ?OI?N 1'iR 1 t. i1 i ¦ A?11 ? arMM '? ? or t??1t+s ?pM! 1P 1. wwWto: Lutkmr R. Pabmr 'g 115 College Drive St. Paul's College Lawreweville, VA 23868 7005 2570 0000 3803 29 to W lqwrmrm?p b 400008d 0 Fawn ftOAA for Mwdw Uw 0 kw+wd ma 0 C.Q.D. 4, PA*Wftd tA~ O?Ow' FOO 0 y" 14 06-2156 Civil M Form 1, lOE14 DarwMla Ilrla?rn idlSY8?02•M-1540 `". ORRSTOWN BANK 77 EAST KING STREET SHIPPENSBURG, PA 17257 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008- 2156 CIVIL TERM V. LUTHER R. PALMER MORTGAGE FORECLOSURE 1805 FURMAN STREET RUSTON, LA 71270 Defendant PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly mark the above-captioned action as having been discontinued without prejudice. Respectfully submitted, O , BARIC SCHERFk? Date: November 4, 2008 David A. Baric, Esquire I.D. # 44853 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff 4 ft. CERTIFICATE OF SERVICE I hereby certify that on November 4, 2008, I, David A. Baric, Esquire of O'Brien, Baric & Scherer, did serve a copy of Praecipe To Discontinue, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Luther R. Palmer 115 Colle e Drive Lawrenceville, Vi inia 23868 David A. Baric, Esquire ?? ?? ? .. ? ? ???F a. ` ? ? .? .? ? :x ? w r -