Loading...
HomeMy WebLinkAbout08-2536Pluese, Becker & Saltzman, LLC Robert F. Thomas, Esquire Attorney Identification No.: 70206 20000 Horizon Way, Ste 900 Mt. Laurel, NJ 08054 (856) 813-1700 Attorneys for Plaintiff FRANKLIN CREDIT MANAGEMENT CORPORATION COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, V. NATASCHA THOMAS (RECORD OWNER AND MORTGAGOR) AND JAMES THOMAS (MORTGAGOR ONLY) Defendants. CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH N THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENT Y (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING THE 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, 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 1/800-990-9108 NOTICIA LEHANDEMANDADOAUSTEDENLACORTE SIUSTEDQUIEREDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGBJAS SIGUIENTES, USTED TIENE (20) DIAS DE PLAZO A PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA 0 EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDMAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO 0 NOTIFICACION O POR CUALQIER QUEJA 0 ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO, SUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA. ESTA OFICIANA PUEDE PROVEER DE USTED LA INFORMACION SOBRE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PERMITIRSE A LA IRA DE H A LA CAPA, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACION SOBRE LAS AGENCIAS QUE PUEDEN OFRECER SERVICIOS 1URIDICOS A LAS CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 1/800-990-9108 CIVIL ACTION -- COMPLAINT IN MORTGAGE FORECLOSURE The Plaintiff, Franklin Credit Management Corporation is a corporation having been organized under the laws of the United States of America and having its principal place of business at 101 Hudson Street, 25`h Floor, Jersey City, NJ 07302. 2. (a) Defendants, Natascha Thomas (mortgagor and record owner) and James Thomas (mortgagor only) are individuals whose last known address is 332 Roxbury Road, Newville, PA 17241 (b) Defendant, Natascha Thomas holds an interest in the subject property as mortgagor and record owner. Defendant, James Thomas holds an interest in the subject property as mortgagor only. (c) If any of the above named Defendants are deceased, this action shall proceed against the deceased Defendant's heirs, assigns, successors, administrators, personal representatives and/or executors through their estate whether the estate is probated. 3. (a) The subject mortgage (the "Mortgage") is described as follows: Mortgage executed on: August 4, 2006 Mortgage recorded: August 14, 2006 in Mortgage Book 1962, page 1579 Mortgage re-recorded: December 11, 2006 in Mortgage Book 1975 page 4296 County of: Cumberland See Exhibit "A," Note and Mortgage. (b) The Mortgage encumbers property (the "Subject Property") located at: 332 Roxbury Road, Newville, PA 17241. (c) The "legal" description of the Subject Property, expressed in metes and bounds, is incorporated in the Mortgage. See Exhibit "A," Mortgage. 4. The requisite pre-foreclosure Combined "Act" Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § I680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". 5. The Mortgage is in default (the "Default") because the Defendant(s) failed to timely tender the monthly payment of $891.53 due and/or to be applied to the payment due May 1, 2007 (the "Default Date"), and thereafter failed to make the monthly payments. 6. Pursuant to the terms of the Mortgage, the secured loan obligation has been accelerated. 7. By reason of the foregoing Default, Plaintiff respectfully requests entry of judgment in rem incorporating the following sums: (a) Outstanding Principal Balance $99,348.93 (b) Interest due and owing at the rate of 8.30% calculated from the Default Date through April 4, 2008. Interest will continue to accrue at the per diem rate of $22.59 through the date of entry of Judgment in rem. $8,291.10 (c) Attorneys' fees $1,250.00 (d) Escrow Advance Balance $242.66 (e) Title Search $333.00 (f) BPO/Inspection/Property Preservation $95.00 (g) Release Fee $25.00 (h) Available/Unapplied Funds -$40.43 (i) Late Charge Balance $264.18 (j) Delinquent Real Estate Taxes Paid For $1,336.20 By Plaintiff TOTAL IN REM JUDGMENT SOUGHT BY PLAINTIFF $111,145.64 8. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated or satisfied prior to the Sale, reasonable attorneys' fees will be charged. WHEREFORE, the Plaintiff demands: Entry of Judgment in rem against the Defendants above named in the total amount of $111,145.64 as stated at Paragraph 6, plus all additional interest, additional escrow advances expended, additional late charges and any other costs incurred through the date of entry of Judgment; and Foreclosure of the mortgagors' equity of redemption and that of any persons or entities holding or claiming under them and Sheriffs Sale of the subject mortgaged property. Respectfully Submitted, Pluese, Becker & Salt LC. By: Robe F. Thomas, Esquire Attorney for Plaintiff NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT, (the act), 15 U.S.C. SECTION 1601 AS AMENDED To the extent the act may apply, please be advised of the following: 1. The amount of the original debt is stated in paragraph one of the Complaint attached hereto. 2. The Plaintiff who is named in the attached Notice to Plead and Complaint is the Creditor to whom the debt is owed. 3. The debt described in the Complaint attached hereto and evidenced by the copy of the mortgage/note will be assumed to be valid by the Creditor's law firm, unless the Debtor(s), within thirty days after receipt of this notice, disputes, in writing, the validity of-the debt or some portion thereof. 4. If the Debtor notifies the Creditor's law firm in writing within thirty days of the receipt of this notice that the debt or any portion thereof is disputed, the Creditor's law firm will obtain verification of the debt and a copy of the verification will be mailed to the Debtor by the Creditor's law firm. 5. If the Creditor who is named as Plaintiff in the attached Notice to Plead and Complaint is not the original creditor, and if the Debtor makes written request to the Creditor's law firm within twenty (20) days from the receipt of this Notice, the name and address of the original Creditor will be mailed to the Debtor by the Creditor's law firm. 6. Written request should be addressed to Pluese, Becker & Saltzman, LLC 20000 Horizon Way Suite 900 Mt Laurel, New Jersey 08054.. Attention: Rob Saltzman, Esquire VERIFICATION The undersigned, an authorized representative for Franklin Credit Management Corporation, the instant Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are taken from the records maintained by the Plaintiff and reviewed by the undersigned who has personal knowledge and access to the business records of the Mortgage held by the Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa C.S.A. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: \?'® 16 BY: Nam Title: Loan No. 2375082 (Page 3 of 67) 0 • 0 CERTIFIED TRUE COPY P qwW By: Donald Salbreath 500 Forest Point Circle. Charlotte, NC 28273 (704)665.3I24 debars To: = r EquiFirst Coryoration Attn: Collatoral N y' » 500 Forest Point Circ1F Charlotte. NC 28273 t-..,,,4 (800)272.3417 Paved Number. Prenlisee:332 Roxbury Road, Newville, PA 17241 laaau Abs" 71ttr Lift PW Rererera ma W MORTGAGE DBAiNmom MIN 100200100100598717 words mead in =W$We sections of ft doamuot are defined below and odor word: sm deRmed Is Sectkus 3. 11. 13. 18. 20 and 21. Carada rules reprdiing dw usage of words used in ibis doatmed are abto provided in Secdon 16. (M 'Saatetty lmatsakumt' mnes this dommun. which is Laud August 4. 2006 , toplber whfi all Ridum to this documem. (B) "DOarewar" Is Natatcha Thomas and James Thomas, rife and husband Borrower ifthe wmpW under this SacWk IMttl MM. (C) 'M=r is Motspp Bleemanie Registntion SyMm. I= MFRS is a SWUM mporadon mat Is 9cde8 $olely as a Sondave (Or 1.MW tad Lender's summ m and males. MW Is she Merippe ®der tbla Seenrity 1Mtrm uzL ME= is apidn d and exWet under the Iwa of Delaware, and baa as ed I and talepheme mm w orP.(). Box 2016. Plhn W 48501-2026, tel. (IN) MMM. 1005487 FM MVLVMIA . SkVb Flunky . FannM MftA4ndi M. UNlOmae MrRIMWt Writs Mara db-AIWAInnem Fs. 30M 1101 1? t ? N W40ft PAL YM/ MAP aN?MK ? 1e001tf ,i ^ ,, (page 4 of 67) i • • 0 MVL4mmW s EgvlFirst Corporation lwmderha Corporation organised and esisthtg under the lawn of North Carolina Ldmder'saddmais 500 Forest Point Circle, Charlotte, NC 28273 (P.1 "Nee" means the promiamory none signed by Borrower and dated August 4, 2006 The NOW sutca*MDorrpwrorowuLaftrone hundred thoYStnd and 00/100 Ddian (U.S. 5100. coo . 00 ) plus intetost. Borrower hat promised to pay this dtht in regular periodic Paymm a rd lopay the debt fa fuli not Ittar uro August 1. 2036 (7) "Pnmperty" mean the property to is dewribod below under the hoadug 'Tnmfa of RISW in the Property." (G) "1.umm" means the debt evidenced by the Note, phu immem, any prepsymen rdt W and lane charges dae order the Nate, and aB mat due wader this Security Imtrtmmol, plus inteamt. (M "RidW mere all Ridots to dus Security Inaowom drat are vocuted by Borrower. The following Rides are to be ancoted by Borrower [Meek bme a spplinbla): Aglusable Rate Rift Cmdominiao Rider Second Home Rider Balloon Rider Ploused Unit Development Rider 1-4 Family Rider VA Rider [[[??? BtwaWy Psymect Rider ? tldtUM lvedW ARK Floor/ Prepay Rider M "Appikable Las." moms a>f t mnaliitti applicable fedeeal, tram tad local Itftuem, rallR lam ordimaooea and admhaisnadve cola sad omdets (that have the effect of law) a well as aB applicable fimal, mdb =cIvPIiM:l um. pees, mad Ammmuments" meatm all dam fees, aam memf and oilier chaj a dot ire imtposed on Borrower or the Property by a condoatiaimi m oodadon, hemeowmes association or ahmiiar arplmdion. (IQ 10mchvele Rader Tremefte mean any uaafer of funds, MIMS them a tatssedoa ortgieatcd by Week. draft, or simdlar paper irmbtmaeme, which is initiated dmmo as elemonic 0etmimal. higdkoeic iRaetoumt. computer, Of tmgnrtic cope so as te order. Immuct, or sodlorim a financial instindoo to debit Of credit an amount. Sack term inctoda, but is not limited to, poker-ofKale uoaft , vA*mmW taller macbi ra arm uctions, nufm initiated by telephone. wire nrufem, and automated clearinghouse &Mk 0 "iaotrow %Mm mass dgse items that ate deacutbed in Section 3. (NO "MhOlUmmeme Precmeda" mum fay canpaumi im. witldmeed. aWmd of dosage!, of pr p? paid by smy thild potty (olber dam imurum proceeds paid coder the oovemges described In Sermon S) der: (i) cheap to, or dtmWdfoe of. the Plopetty; (ii) condenmttion or tuber slung of all or any pmt of der Plop a(HI) contoyanoc on lim of eoodca matitm: or (tv) mWepreseacAtiom of, or omhdmw as to. the Value andim Property. pe "mwq p hhaWfanee" touts imRance promeft feeder MOW the molpaymesa Of. OF dd rA on, The LOORIM. 0 "Trundle Payment" mm u the mpululy sabedm)ed ammo dee doe (1) principal and imtmK miler the Note, plum (ii) any i moman trader Seaton 3 of this Samarky Instnrment. 1005087 4%4AVAe sons war. ?. s w u / Fuw 3030 1Jp1 (Page S of 67) • i 'RMA' mews tM Rail Earn Settlem a Prowderve Act (12 U.B.C. Sadw 2601 a NO end is N6 Adm. Roptladon X (24 C.F.R. Part 3MM. m they reltht be ahnr<mded Ohm dm m fore, 03 goy addidmW or smom a letlslrtien at t @ I -ioa floe govem die came a kite muter. As wed k this 3wi t r h memea 'BUPA' refers to s0 rogWmms0a and MOW= 00 an imposed In roped to a related mx r4 a Ices' ewes if the tam does rot qualify as a 'Eede+t0y related mwVV loan' trader RESPA. (Q) "Succa r to bdww of llorrvtreP" mans any party dw has Whoa dde to the Prop". whad w or not that parry has asehwaed Ummer's obliptiora nadir the Note sWor this Security IattrasoerR TRANSFU OF RIGHTS IN THE FROMMY This Security In rwism somm to Lender. (1) the rtMmept of the Lam, end all rowwala. au mkm and oadlfintism of the Nose; and (ii) the pvforahrrroe of lorrower'a earonerhu and ?eeeweets order fhb Secerity kwzvmettt and tie Nose. For this p wpon. Borrower does hereby mmipp, Vw sad convey to MRS (solely as nowisee far Leader and Larder's am mom and assim) red to the snocawoa amt mfr a of bM the fdi0wft d9Awib0d property lenmd io the County ihtx of tt.r%*%Jahdit4al of Costberl and ph-afRueragjwidaiaex See Attached Exhibit A °Auchcrrma11Ybasthe addrewof 332 Roxbury Rood laaa+l Mewville [taarh.Penmylvada 17241 [zip caw ('Property Addeestl): TOGEPHst w1TH dl tiro itnprovemenhn am er haaRar erected m the property, aid an afe netro. r trtnteoaes, and furor= new or hereafter a Part of the All rWww aft and addition sba11 she be ar?emd by olio Smvity Inwitment. All of the is referred to is tl_da yawlry Io?Nnmseot >i ire `Property ' Borrowv trsderatttleds ad +p bdda only 1w tide ee tie faeeaa imMad by Borrower is this Seewitr lowm =4 but, if neca fry to complyy wilbb iew a aratao, Fd6RS (as nooOW for leader and Landw a waxsaots and seers?4mhr) has the rk&: to ameue soy or e0 of oboe Wora m. ineludfql, but not limbed to, the rW to ftwecfow and sell the pro"- and to tdW MW action 1"111101 of Lander incWig. but act limbed to, relenting and anoelist8 this Security 1005987 ® eAlrAiwreu r:erhe _7 rqa« is l tam 3m 1101 (Page 6 of 67) 9 • • BORROWER COVENANTS that Borrower i3 lawfully seised of The add hereby c mmyed sad has the right a rnortyaye, grant and convey the Property and Ib U the Property Is w bmod, totoepl for asrcaatbrartoes of record. Borrower warrants ard will defend geranily the dde to the properly adult all claims and demands, sobjw to cony enanobraaoes of record. THIS SECURITY INSTRUMENT commU tes uniform covenants for national we and ooruditm covenants with 11mlmd variations by jurisdiction to coeetiono a uniform security lastrum eot cover Llf reel proPuty. UNIFORM COVENANTS. Borrower and Lender cove now ad agree as follows L. l;ymaal of Principal, Ister1 -, lea" lsessa, Ptepsymettt (harps, and Lie CbWPL Borrower sto11 pay what date the principal of, and interest on, due debt ovWcaced by the Note and any prepsystumm chargs and Lae dargac due under do Note. Borrower drill also pry fords for Ewmw Iran p mammat to Section 3. Payments due under the Note and this Security Larrmomt fait he made in V S. currency. However, if any cbm* or other imtrmmvcra reserved by Lender as payment tinder the Note or this Smndty Instrument is retuned to Lender unpaid, Leader may require am any or all sulsegaeat paymem due seder the Nate ard this Secarhy bm tmmm be made in ace or more of the &BOwwft fttM. as adeocad by. Lander. W cask. (b) money order: (c) catificd acct, bank cheat. tnammr's check or cathiet'a check, provided my each check is drawn opera an insulation whole deposits are blared by a fedvil ap-7. lorasommWity, or emdty; or (d) Electratic Pundit Transfer. Paymmts ant doomed received by I erhder wbo n received at the location designated In the Note or as such other location as any be de ipaated by Lender In seeotdsaoe with the notice provisions is Section IS. I,nder may -am and paymm or Pied Payment If the payment or partial pigments are hnad6riem to bring the Loan current. Leader may accept any - 3 P -err partial paymm inoulAdat to bring tho Lan cur. . without waiver of may nights haeaoder or prejudice to in rights to rerun suck ptprmeot at partial payments to tiro fulcra. but Lender is ant obligated to apply inch psymatts at the time sock paymaas are mooe)ned It out Periodic Payment is applied to of its whodaled doe date, dm Lander need oar pay Imam on umapplbed their. Lender may hold such uapplied finals until Borrower makes pgmas to brio; . the Lou earremt. If Borrower does to do so within it reasonable period of doe. Leader shall ddw apply mch tWmt or rams Item to Borrower. If not applied earlier, axe fads will be applleil to the oatsoao ft pdnclpd bdmw vmdar the Wane im ovdimady prig to fa mcloswe. No ofbet or claim which Borrower mist have now of In the kvm splost Lander pull relieve Borrower from makbg paymaas do under the Noce and We Soetoily inuroment or performing the covaomb and sgreemem aewred by this Security Inabtsant. 2. Appliadom of Pgmmb w t'rooeeds. Except as otherwise des¢dW In this Section 2. all papa sooepted and applied by Leader ahall be applied in the following order of priority: (s) learnt doe under the Note: (b) principal due coder the Non; (e) asnooats due tender Section 3. Swb paymens &M be applied to awk Periodic Payment In the order in which it beesm ore. Any res ainigg amoom 311211 be applied Am to tare drug x, secad so nay other am oomm due under this security Imrtruaeot, and than to reduce do principal balmoe of the Now If Lander roorivws a payment from Borrow for a delingnaat Periodic Paymem Stich inclodes a sof6ciett amoaa to pay may tree sharp doe. do payment may be applied a the delbtgmam V" m and ate lee cure. If more than cue periodic Paymem is ouumn ft. Lady mq Apply any payment »osiv Gam Borrower w the repayment of ire Poiodic Paymom it, and to the nacre that, each papmmt 10?34r7 wa.aru j4.f Farm3p3s 1101 AI soon (Page 7 of 67) can be paid in tail. To de cram dw any am ealsa aft the peyamot is applied to the 11ih prPOW of owe or arm Periodic Pardo mss, web cum my be oppiied to airy late dta W due. Voluntary prepsyments dill be applied first to soy prepayment o and then as described in the Note. App application of paytaatas. intowa psocee I . or hilseeilameaa Roceeda to principal doe under the Noto still not cxkad m postpone the doe dam, or tieitge the mount, of the Periodic Payments- 3. Ftmda lar Escrow Item. Gomm r shall pay to Lefler an do day Periodic Paymmits we dad under the Note. MM the Note is paid is full. a cram (the 'POW) W provide for p Wmat of aaauas due for. W Mm and adaplaRats and odor item which can attain priority over this So=* laatiumad AS a Urn or eseambraitce on the property. (b) Wambold psymets or pound roars m ma Property. If any: (c) F00310103 for sly ask all iosurotoe "AFOd by Lander under Sectiau S: and (d) Monpp Worm me PXIORkmm. If a". or ary mod peyalr)a by borrower ro lender in lieu of the payment of Mortpp Insurance psaaias to accordance with de provtdom of Seetlm Id. Thus itaa are adled 'Escrow ltaps.' At odillortion or at any tar darinj the cram of the Loan. Lander may require that Conunneity Amaeiallon Does. Fees, and Asa smem, if any, be escrowed by Bttrtoarer, and arch dices. finea and scaprnmtt &W be as Escrow Iran. Borrower shall promptly fomish to Leader all notices of am"Win to be paid wWw this Section. Borrower ahsll pay Leader the Pardo for Escrow law unless Ueda waives Borro er'a obligation to pay the Funds for pay or all emow Iraqi. Lander testy waive Borrower's Obligation to pay to Lender Funds for way or all Farrow k am at any tone. Any aacb waiver may only be fa wri11q?. fa the event of such waiver. Borrower shall pry directly. when and wUere payable, the aomums bye for any Recrow hems for which payment or Fands has base waived by I.emdet and, if Ietder cequlrp, shall Amddt an lender mclpa erida ciao much pmyment within mch time period an Lefler may regdm Borrower's abliptim to male ash payments and to provide tnceipts shall for all porpom be damned to be a eovemm am proem m comained in shit Security Instrimom, as the phrase 'oovauost aced agreecoeat. is aced in Sectim 9. U Borrower is o Wipted to pay Escrow Itetro directly, pursuant to a waiver, and Borrower Ells to pay the so mm fits for an Eaaow item. LetWer may exercise its riglaa coder Sdcdoa 9 and pay such amOYm and Borrower shall then be obligated under Seetim 9 m rmpmy to I aodsr any such hoot. Under soy mvoioe rte waiver an aD any, or an Eacror Item at aqy toe by a notice glum In Mcmdamce with Sect ica 13 aced. upon such revocation, Borrower shall pay to Lender W Punk, and In such amounts dot arc them ranimind under this Se ctim 3. Under may, at any time, molka and hold Nods in an amount (a) sutficim to permit Lander to apply the Pupde at the time specified Imdsr RLESPA, aid (b) at to a xaced pert maximum amoum a leader - tognmrs alder RESPA. Landau shall tytimae tie amount of Funds doe on the bads of arrest dub and redsoable estimates of expenditures; of fame Emm Items or otherwise im momrdaame with Applirabtc Law. The Rinds shall be held in to iadeatim whose dtposhs are irwued by a fedte?t.l,,?a?gency. Fmbotmemality, or entity (Ndiding Lender. N Lender is an imadmtba whose daposks ere so ..o. nd) or is any Padua! Ham Loma Beak. Lender dull apply the Panda to pay the Escrow law no low tun the time specified under RESPA. Lander aloft not dwp Borrower tot holding and applying the Funds, annually saabndng the escrow amount, or ?erif tg the Escrow IN=, unless leader prys Borrower irt, I an do Fonda and Appim" Law ptrmio Lander to make acerb a charge. Unless an thguemheot Is IWde In wrung of Applic" Law requires lowest to be paid on the Ponds, Lender alai) not be required to pry Borrower why bnerest or l nbp on the Plods. Bttttawu and Lauder, can agree in writing. however, that interest Ioos9Bl P... sM is {?,? t??e alPAl wen UL /Z/ ham 371a 141 (Page 8 of 67) i ? 0 • shall be paid on the Putls. lender shell jive to Borrower. without abargc, an enmesh ncaotauiog of rife Funds as regained by RESPA. If there is a stspli s of Ponds held in escrow, at dcftm d wrier RESPA, l!Oder swlf ttecxuw to Borrower for the sum hods in accordance with R$SPA. If shwa is a shortage of Pieria held in asoow, as 4cfMcd order RWA, Lender shall notify Borrower u required by RESPA. and Borrower shelf pry to lender the Imams necessary to mete up the shortsjc In wcm*m w?tf RESPA, but in no more then 12 montbily payments. If there is a deficiency of lands held in escrow, ss deuced us lar RE PA. Lwhder shall rarity Borrowar as tegairod by RESPA, and Bonowcr doll pay b Leader tie =w= meoessery to salae UP do deficiency in accordance with RESPA. but in no atone then 12 soc"y payments. UPm Payment in IWt of all stuns stcaned by this Security Instrument. I ender shall promptly mAmd to Borrower any Hinds held by Leader, d. Chin Lieut. Borrower shell pay all taxes, sesasmants. clmrga, fines, asd Impositions attributable to the Property which an attain priority oval this SepMty Instrument. Machold payments or pound tams on the Property, if any. and Conu amity Aaaiatica Dues, Fan, acrd Assugasc us, if say. To the exact Cat these items ut Eurow Items, Borrower shall pay ftm in the meaner provided is Section 3. Borrower stall Promptly 4wdwSe any lien whirb has priority over tltfs Security IGtwttsest uweu Borrower: (a) agrees is writing to the payment of the obligation roomed by the liar in a tmmar sce plats s to L.adu, bet only so long u Borrower is perfmmiog nteb atpeemeot: (b) Waco the lien in good faith by. or deI I spins: sunkrwmcat of she lien in, ftal proceedings which in Lender's opidon opueu m prevent rite et em of the lion while those proceedings are pending, ben only until such prooeedia js m concluded: or (c) se ma ham the holder of die fiat an agreemm auidh=y to Lender nabmdisa ft do him to this Security Immanent. If Lauder do0<mina that any part of the Property is mIject to a lica which can wain priority over this Security launme nt, Lads may jive Borrower a notice idcutifyiaj the him. Within 10 days of the date on which tint notice is given, Borrower shall satiety the lien or aft am or mine of the smote set tole about in this Section 4. Lawler say nVire Borrower to pay a one-time sharp for a real crate has verification andJm reporting service used by herder In connection with this Loan. 5. Properly boom mos. Borrower slot beep the improvements now existing or hereafter orsesed on she Property formed against tan by fire. wards included withla the term 'exeasded coverage.' and any oChet hazards Lahhding, but no limited to. arthgm&w and floods. farvwhich Teenier requires Iswunce. TW& Warsaw shfil be maintained In the snow" (including deductible levels) and for the periods that Leader rrsinim. What Icarian room pursoent to the preceding amtensm to chop dttrhhg the term of the Lme. The inaarupce carrier peoviding the isnrance sell be chasm by Borrower aabjatY to Loft's Tilt to dimpprova Borrower's dacha, which rigid call not be exercised uaramaebly. Lender may require Borrower to pay, in connection with this Loan, either (a) a on"ene dat'ja for Band mac dcOmhudion. cadfiation and tracking awices: or (b) a meto-thnc obar0e for Good aoao dcwnu t Wm and ce tificados services and rebaequnt chatga each tune aamppimgt or similar ehmps oeenr which toombly OA& Ilhst each detaodtation or certitfatis m. Bm awar shall else be responsible for sire psyn sw of any lees inhpoeud by the Federal 8astgwoy Matagemcot Apmy in connection with the review of any Rood zone delerminatiw tamping from an objection by Borrower. i. 1005991 rare at?A M aeon ny, a a ra ??? Fenn 30" 1101 (Page 9 of 67) If Bono+wr falls to malsaw any of the awaradee described above. Leads may obtain Iwuraact cowaaga, at Leader's optims ad Bmroww s expense. Lander is under on obliptiess to pprchase any P type er wmme of cevmnga. Therefore, auh coverap slrll cover Lander, but aught or errata sa Proses 11"M r, Borrower's egahy In Ilte Property, or the contents of the Property, npinn any d*, bawd or IUMNey and migM pmAde pun or lesser coverage than was prcviamly in effect. Bonowa acknowledges that tie am of the imarance cmusp to obtained might 40ficamly exceed the cost of stimersocit floc Borrower maid have obtalud. Any smmass alsbtrsed by Lender aodnr tltla Section 5:bail I , up additional debt of Berrowa aetorsed by tide Sewtity lestnmrent. Thest amnmts shall beer interest a the Nato rase from ilw date of diskieneasat and shall be pays, with ncb Lateran. upon oodeo from leader to Borrower regm ft payment. All insurances policies rWAred by Laxkr and rauowwle of epee policies shah be iaWM to Leoder'a right to dlespprove such policies, shah inckde a fladad ramVp clause, and taxi] tame Leader a nmtpaee msVor es as addis =d logic payee. Leader dial] hove der rigs to hold the policies and renewal certificates, If Lender requires, Borrower shell promptly give to Lender all wceipts of paid premhmts and ranewd modem. If Bountrwer obtalas any form of insrrenee coverage, not otlterwlae mgaired by Lader. for damage to. or demnstion of. the Property, such policy s1nJl include a eta OW mortgage dam and SW AMC Lander as metgagee and/or es an additional loss payee. In ds even of Loa. BO rmw laB Sire preaipt notke to the insarmice carrier and Lander. Leader may make proof of loan if not meek psamptiy by Borrower. Unless Lender od Borrower otherwin agree is writinsg. any lasueanre proceeds. vwhaher or net the underlying insurance wu tegsired by Lender, shaii be applied to resmatima or repair of the Property. if the reneettiou or repair 6 eoaasmf oliy fruible and LOOdOr'a asperity k aes Ieaencd. DurLq such repair and reatotatioa period, Lender stall have the d& to hold exit laatsm proceeds until Lender Ims had as oppormrdty to Inspect arch Property to mmum the work hu baser completed to Leader's aadtfudon, provided clot such laqncde11 dal be mdesuken Lroapdy. Lender my ditburn proceeds for the impala ad resmratiou in a single payment or In a series of Pte- payments, as the work is completed. Udaa al agreemetr is made in writing or Applirehle Law roodres want so be paid on mock insurance proceeds, I mid ahll not be re¢iised to pay Bonowsr any intetari or aaalup on wcb proceeds. Fen for public adjusters, or other ON parties, m akrsd by Borrower dell not be paid out of the immance proceeds sad shoe be the sole cbl4stion of Borsowa. If do ratanion or repair is amt ecolomfopy femme or Leader'a 6am city would be imeaed, rte Imm'ance Proceeds mall be applied so rte sums swred by this Searity IfatrYlaerd. whether or not den due, with the cw=. if aW. Paid to Borrower. Such fgnraoee paaoseds slap be &W led in the order provided for in Section 2. If Borrower abaadsax the hope" header may file, negotiate and wwr any avaN.ble lasuraoce claim and teirted statsen. If Boaawer don not msperd wltWn 30 days to a notice from Ladder that tie ie/erean artier has offered to asole a claim. then Larder cagy negotim aed earns ft claim. 7M 31l.dq Period will begin when dne notice is giver. In aither event. or if Leader acquires the Property under Seetba 22 ar odowlse. Borrower hereby maips so Lander (s) Borrower's right to may kwAMros proceeds in an i motea net to Mc ed the amounts unpaid Wider the Now or dit Saetrlty lesvinm st, ad (b) asp other of Borrtwer's rights (ether than tie rip to any refbed of iweanted promitaaa paid by Borrower) under all luminesce policies covering the Property. insofar as such siesta in appiiable to fee C6eeraae of the Pn*WW. Latin may we the insurance proceeds cidw to repair or restore de Prapaq or to Pay framers avoid ardor dw Note or dds StckWity Lkatnmkess, wtetlta or sot dies due. 1005907 mow.: q%AA1PAl w" rrr. r w +s Fm,n aMe 11101 (Page 10 of 67) 6. Occupancy. Borrower shell MOM emmish, and use the property u Borrower's pdociPti reeidarnes Mddo 60 days acts tie sac WM of this Seautty Itsmmnast and shall ooatime W occopy the Property as Borrower's principal reddemce ibr at kut one year after de daecof oowpaaq. mops f ceder Wsus in Wnti g, whiab C=W IMp rot be maeararnbly withheld, or anima eateanatieg dearasarseaa erda wbiel' are beyond Borrower's marol. 7. Presavmtten. Mdudmaasce ad Protection of the Property, IarpectIM. Bmrowa d'a hot dsenoy, detmagr or impair the property, allow the Property to deteriorate at to m it waft on the 70010 ty. Whether or no Dan*" is rasiiirtg in die property, Borrower scull maintain do Prophecy in Oder m PMVM doe Property from deteriorating or docrcadrd in wire dm to Its cer.dition. Udess it Is determined purnsn to 5eetbm 3 that repair or restoration is act economieft teenUle, Borrower shall prmeptly repair the Property it damaged to avoid feller deawioradon or damage. If iswrance or oortdeatnatitm ptoaxdI are paid in otto.OWN with dam Ap do, or the taking of, the Propm y. Borrower mall be rapasibie for mpdit or restoring the Property only If Lender has released proceeds for stub PmPOM . leader any dMww proceeds Eon the repairs and ratondon is a sh(gie paymttm or in a solve of pragerk Paymeers In the work 4 amapiued. If the insaramee or mmdea natine , e0e I we not Mffml nt m rapsir Or damn the Property. Borrower Is not relieved of 8ormwer't oblWitimt for the completion 0f such "Pak at restoration. l,eadet Of Its ABM May make raasostable emries upon ad itt ppWous of the Property. U It bes reasonable comae. Larder may kspeci rte bnomitrr of the Brprovuoams M the Prop M. t wtder shall give Borrower notice at tie tine of or prime to Inch so chants Inspection spedlyiag such asoaeble cease. 0. bwnreer'a Leta Application. Borrower 90 be In defaelt If. doing rim Learn appiieadoa Poems. Borrower or atq Persons or entities, M1% at the direction of Barrowar or with Borrower's knowledp or eoosera =eve m.eerWly false, midesdirrg or imaxnvata iotorm.tion or ahtmnmtu m lender (a filed l provide Lender with material iMormadog) in connection with dbe lose, MuwW repreeantlans, idehrle, but am riot limited to, mWaaratiots oomcera ttg Borrower's ocapamcy of the Piowty a Borrower's pc=lpd residence. 9. Proteetles K Iesder'a i ins t to the Progeny and Rights Under this geessuft InallOtant. If (a) Borrower Isis m perfm the amum end egtammw comalmd in da Severity immuum. (b) dtam is a iegai In, ,, ties Wad MI& 00fcanft Iffeel under's IMM in the Property ardlor rIOU under this Sorority Iosurmran (sud? IS a proceeding In taelmtptcy, probate, for condemnation or forkilu , for eakwo-set of a Ilea which tray ands priority aver this Security Instrument or to cIasce law or regnlaioot). ue (e) Borrower has ahmdooed the Pnq=q, than Lender may do and pay for wbetever b rrammwe Or appraprhu In protaa Lmlder's Inuses in We Progeny and ftW wader this security Iranroma& inCludlni protecting and/or arming du: value of due Property. and seteuins endAw repalrls* We Proporry. Loader's zoom ran Irnehide. bw are no limited n: (a) paying arty sums second by a Ilea which, hu primalty over tide Severity lognonvnt; (b) appearing in cant; and (c) pay* ressoaade ssortsys' tees to protect its Internet in dw hw" and/or rights rider this Security Instremem. into eft its eeutmd Mkian to a b drgtcy Proceeding. Seatriry the Pmpeny includes, but is out lilted W. maaigg We Property m oft repairs. change lochs, molaco or board up doors and windows, drain wow from Pte, din ieste building or otber code violations or der!{mw conditions, and bays uts'lides served on or off. Akbw4h Leader may eke acdoo under this Section 9. LuAw titles to have to do so turd is mot ender any dotty or obliption to do a. It is agreed that L&Aw looms no liability for not taking any or all emcee authorized under this Section 9. 1001907 ??e1nVAtown ? /?dr hoar a . L •? Fan 7tr7e Apr (Page 11 of 67) • • 0 Amy mount diebantd by Leader under this Section 9 shall booms additbml debt of Borrower reeaed by Ws Secmrhy ImtIanlaat. These income shall ben tartest at the Note ram (toms to date of dishvsantant and shorn be psytdde, with such interest, upon notice from L.erder to Borrower regnepiq PqWArA. If dds SMi ity lamnammnd is an a kesehold, harrower shalt comply wkh all the provirimr or tea bas. It Borrower acgWm fee We to the PtopeM. dia bachold and the tee dde SIMU not meths mares L alleles apmCi to the mw= in writiol. 10. MWgW Imaunmom. If Lander required Mwtp p Insurance u a cosdlticn of melting the Lead, Borrower shall pay On p udumc required to naimmin the Mlonpp Insurance in effect. It, lbr any reason, the Mmrcpp UWUance cmv"s regdnd by Leader cums so be "chic hoe the moripp iesraer dat previow>y provided such Incur mor and Borrower was reored to male cpernely, dul{maed psymcm lowerd the premhma for Mortpp Iammwme, Borrower shmB pay the premhrns required to obtain cvmW substantially Mmlvmm to rile M4otiM Imunum prevlwsly to dhc6 at a was substuatlally equivalea to tee am to Borrower of tits Mortpttpe Inurrma provtously In effect. tram m sherarte won" Insurer maim ad by Lender. If subgortially agoivabat Monpp Insurance twiemp a cot avaftle, Borrower Wail cantism to pay to Lender the amount of the separately deslgraae ptymma the were due when On inssratme eoverap coned to be in effect. Leader win accept. we mad resin that Peymmtt n a ootMWWkdable lots reserve her JIM of Mmtjap Insurantm. S11ch )11111 reserve 011111 be son-reGmrd", motwillimm ding the fact that the Lame Is mltimimly paid in %U. and Leader shall cot be tequirtld m pay Borrower any ill- m m -, or eat01t1(<t an p :b lost rtmerve. La der on no Im pr n*dfc Ion reserve payments if Mortpp hourance c map (in the amount and for the period thnt leader rWAree) Provided by m hum selected by Lander spin becomes available. is obaioed, del Leader s"Am teI 1 1e r desISDOW payments toward the p mwme for Mortpp luctence. If I emdm required Martm lamrsome a e condidmr of making the Gan and Banuww was requited m make upvardy daipnted paym m towerd the promhmt11 for Morrple Insurance, Borrower shall pay dye press me regctimd to maintain Moetp p b zwm in Whet, or m provide a ocm nAadeble Ions reserve, wtU Lender's requirment for MortSW Insurance ends in acco dsom with any welt m sUccment betaerJt Borrower and Lader prWiding for each tetmimdi me or mail mrnindon is required by AMIcable Law. Nothio6 is dds Section LO Was Borrower's sbliptlos to pay imam a< the rate provided in the Note, movipp Immaoee mW&vdma Leader (or may entity that parchum the Note) for tXrfe? lance h may Iocor It Borrower does not repay the Loan as spaod. Bormwcr is era a party to she Mor*W lotureetcs. Mm pep murerm anlrats their real risk on all such laauram in force from dome to time. errd any color ball agremmem with other parties that share or modify their ridt. or reduce loam. Tbew apt make we on teas mud otuldidoms thus arc satishtxory to are mortpp inaua and the other paty (err puda) to theme, agrommuts. Then aV=mu my require the p insurer to romim psymmis imshig may mum of Ilmds mml" Insurer my lave avllisble (which may includs ttmb obmimed atom Masthye lmumoe per mulct). As a taunt of does ts, Lender, ally pursuer of tltt Note. amdw Insurer, surly mimmer, my other ea". or any affiliate of ally of dm foragohs8, may m ive (d mdy or hdinK*) amounts slat derive from (or migt be deneteriad a) a parties or Borrower's payments for Monp p Inaararce, in tmbanBm far daft or mndigbq the rumtptp Mmuces risk. or rCduft keen. If mob aBr-09 ptovldes dot an Wlpimte of Lender t*u a chum of the inarmes rielt in cidlul a for a deem of the pratduma "M to the Insurer. the an uip me" is ohm [wow 'copdvc reinsmaame.' Fwd-; (a) Any mob spvammob will and d hd the amounts lea Borrower eat creed to pq fun moor ipp: Indarsaea, or my other loan of the Laos. such agram mu alp met means tea aaunt Bwmww wen an for Morlpp Idmmmm, and they wM met vedde Borrower 0 any nand. 1005981 urxru atinl?alosaw rrpa.tre /1? / rem 2M /A1 (Page 12 or 67) • 0 0 (b) AnY such sre®mts will sot atibct the duo Borrower bm - u any - x115 relpact to the hsorlpN ksnRaooa under Use Eomwwna. Prommilm Act of 19M ar asy add law. Tim ttlgbu may bselyde the rfglu to rWdv cmtmin dieciamae, to requed anal Obtain eaaallntlea of th er rmoel?e a rd"d of blortgagea Insurance °~ lseoraaea terminated at the dme n& ass prmnituos that we..neartKd at the tlsra of d oral aeslWiea at twu aasm, 11. Aadpmcw or Miscellaneous Pmemda; Fbrfdture. All Miscellaneous Proends ate hereby reacted m and dual! be paid co Lender. If the PeoWny is damaged, mch Miscellaneous Prooeods :hall be applied to resmndon or mg* of =a if the restoration or repair Is monwnieaily faadisk and Leader's eacurlty is mot leumned. repair OW restoration period. Lender ebdl have the riSM to hold such Miscellaneous Proceeds MU Lender bar had as opportunity to inspect such Property to w ne the work has been compiled to Leader's auisfaction. provided that such inspection shall be tntdosadcea promptly. Leader may pay for the rVaiw ad rtl0 ndm in a single didiumemeet or In a -odes of prolp payments es We work is oosnpiI I - UW- as apamment Is male In writing or Applicable taw roWm imerm to be paid on wAO M%millmnom Ptmocedt. Lender csall mot be required to pay Borrower any Woo or m gimp on sack Mieeallsnms Prooeeda. if the ropontion of apir is no economically :babble or fender's mmky would be )mcood, the hrrmllmwm Proceeds shall be applied ro tae enms se mm by this Securityl mmum e. whether or not then due. with the excess. it any, paid to Borrower. Such MbaAhmm Proceeds sW be applied in the order provided for in Swdmn 2. In the event of a NW tddn;g, derowtim, or lou in value of the Property. the Misoeillatnow Areeoeds shall be applied to the smm mccur d by this Scaniry lmtruaaml, wbodar or mo than due. Wilk the ntetm. it any. paid to Borrower. In tit; event of a partial taking, destruction, or loss in value of dte Propetpr In wMch the fair market value of the Ptopvty Immediately before the pmW taidag, deatruaion, or lots in value Is equal m or Veow than. Ow amoawa of dos soma secured by this SamM Imaumm imm Omely betoro the partial taldmy. destrntxim or ions Is vahw- tn)en Borrower and Leader otherwise epee in writft the cans seamed by Air SWm* Irsuvemat shall be redrroed by Ike amp= of the Miaodlaneous Procaedt amtitipllad by dw tollowiR fraction: (a) the soul amount of the sump seamed immediately before die Partial taking, destruction, or loss in value divided by (b) the fair markat value of do Property immediately bcforo the partial ekin& destractlon, or loos in value. Any balance shall be paid to BmT~. In 11% event of a partial miring, destruction. or leas in value of the propcdy in which the fair aarlost value of the Property ismttedmicly baton the partial addog, dennu a lot, or btu In value is lees than the U30M of the sttmt mco ed iormte' &Wy betom the partial taking, datrueli t. or loss in vain, tmlen Borrower and Leader atbawise agree in wrldW the Misceltaoeom Proceeds sbW be :tootled so the amps secured by fbie Seamiry Instrument %bedter or not the sues we them duo. If the Propt+ty 4 abandoned by Borrower. or it, after notice by Leader M Borrower Ihtt rho Oppwlms Party (w da0sed In the next seammoe) offers m melee as award to settle a claim Ear damsons, But -- tails to respond In Deader within 30 days alter dos doses the tntI is citron, f enda It mrtboriasd to collect stud mooty ft Miscellaneats Proceed: eider ic mioruion or repair of the Property or 1o the scone am mad by this Security Imstmmamt, whether or not than lee. 'opposing Parry' memae the third party that owes Borrower Mi Promaoms Proceeds or the pony apptlmt whom sor"or has a right of action in rapW tu Mianeilarooas rooeede Borrower sadi be is detWt If any anion or procce ttg, wbww civil or ttimiod. b bcgmt (imt, in leridar's judgmeat, could mama in forkimtm or the pro" or other matmimi impahment of L amices bonnet in 1110 Property or 400 trader this Sanrity Imtrmmd. Borrmrer can coin arch a default M d. If aoodsr don has oavrmd, naieslm a provided in Sediom 19. by causing the scion or proceeding to be 1005987 t?.ant°ru s?saa - var. err rr Feat amaa zps (Page 13 of 67) dtaudnW with a ruling that. In Iader's judgment,pf'acbdes f flume of the Property or otba rnadatal impairs" of Lander's instead in die property or r gli as under this Seem* bob--*. The Prooeede of say award or claim for dmsaps that are attributable to tae impairment of Under's LAM M in the Property are hereby stalpe l sad dull be paid a Leader. All a[laodimm o n Proceeds out are ant applied is mess mdoo or repair of the Property shall be applied in die ordcr provided fat in Socliar 2. 12. Burrower Not Res mm* Forbearance By Leader Not a Waiver. Bxte sion of the dm for paymetr or modulation of amortization of die somt.amiraa by this security Iastroo at grmite 1 bl Lender to Borrower or a" Smoeaw in Intum of Borrower cball not operate to release the IWAlty of Banown or may Successors in Interest of Borrower. Leander shall not be n aired to oeatm®oe proceodiage spies my Sucosmor in Imeren of Borrower or w rdm to exceed time far paymoat or oRSrwim mollify amorthaation of do sans sarAt W by dos security laummem by mason of any d®ond made by the arigiaal Bonowa or say Sucoetson in Ieterest of Bwmwer. Any forbore by La*f is of remedy locA ding. wilbout limitation, Lender's aasplaote of payments bum third any O&M eaMec or Successors in lseeran of Borrowa or in setoumc Iris don dm amount dm doe, doll not be a waiver of or pfadnde the exflCife of any right of remedy. Ll. 3dat cud Several LWAfty; Ce sigoerr, Successors and A elps Bound. Borrower comments sad agars tied Borrowers ouiptious and liability duJI be joint and Cenral. However, MY Borrower WW OD'algm this Security l1KCamend bat dose not eaeeate the Note (a "co-Opal): (a) la to-signing dais Setirity InUrumeat only ro mortpp. grant sad owny die c0-signes iaccm in pro Property order de; tams of finis security Instrument, (b) is not personally oblipsod to pay the Haut seed by Ibis 9earity Imtrsmem; and (c) arm that lender and soy other Borrowed can Mm to ac ad, modify, twbeer OF maim may accommodations whin rtprd to die cum of duffs SemwW insramot or the Note wi hout the ewigner's roues. sobjecf to the provision of Session 11. may Successor in Ions of Born er who assents Borrower's odiptmrs seder this Security Inusmtent in wrWaS, and 4 approved by Leader. shill oblaiu all of Batmwarrs righu and bWAMM under ndr SOCnrity itsrnuaent. Bottowef shag am be released hwp Bortpwror's edipdear sad liability under Russ Security Iartntaeot udeas Leader agues to each relaro in writing. The ooveno w aad agrmnr nts of this Security lattmmem shall bind (except as provided in Saffron 20 and benefrt Rae successors mid sadgro of I elder. U. Loan Chergn. Lander may deep Bouowar far ter services performed Itt aximroWON with Borrower's detanht. for die purpose of pmoecliag Linda's toterau In the Property and rV a under this Seanicy Iasnruenenc, ioeludlug, but not limited to. sttoroeys' face, property hmpectias and vahuadioo face. In regard to any other fees, the absence of express andmrIty In dds security Instrument to tfarge a speeft fee to Borrower shall not be Ceaetrued as a probibidas on rho charging of sueb fee. !.ender ayy not cWp foes mtt are ap -sly PMMAI d by !his Security InCtmetat or by ApptiCablt Lew. If rem Loan Is subject m a law which ram nmsimnm loan charge. and that law is finally interpreted to that the Indeed or saber Joan darges collected or to be colicemd In tlOrmeetion wilb•the Lose exam the permitted limits, dim (a) any such loan deep dun be reduced by ft mmamt necessary to taduee tba Chugs to the permitted limit; and (b) my awns alra idy collared ftm Borrower Willa axcte W patmiusd lb ells will be rdlmded to Borrower. Lender nay Choose to males ft teflmd by re I ing de principal awed sander dhe Near or by maldtlg a direct payment so Borrower. If a rofimd MMU pfimeipal, due redndm will Inc treated as a partial prepaymmrt widawt ray prepsyaneit slurp (wbed er or root a pnpyrmaa charge is provided for under the Note). Borrower's acacptaoce of any such soloed made by 111114 PsYllend W Borrower will constbwe a wadvrr of any right of action Borrower might hove arising alt of stash overd up. IS. Nodes. All owkn given by Borrower or Lenda in connection with this Security Inawne t moat be to writlmg. Arty sooee 00 Botrowel In eomeedoa with this Security lasdnimed alsll be detowd to 1015987 earn.: Qk-aAl?A) urea ... „.r +. p? dean 70!! t lot (Page is of 67) have beat given to Borrower wbm malled by fim class mall or when actuiy delivwed to Borrower's notice address if sat by odw mesas. Notice to arty one Borrows shag comdata notice to all Botmwers units Appiirahte Law eapeessly requires otbetwlse. no notice addraa skull be the Property Addreea unless Btarowx bas dwipamd n substitute nodcs addrest by r4doe to LetWer, borrower shall promptly no" tender of Borrower's data( of address. If Lender qe dit a procedure for reporting Bormwr's slow of address. then born ma "I *My repo. a change of tddtew through rhos spodfW procodtae. These they be only an desipaed notice address under this Seority Insnvsoau at any ate time. Any aorioe to Lander shall be given by delivering It at by mailius it by first dun asA to Leader's address stated ba ctu unless Lender lass designated another address by notice to Borrower. Arty notice Is moeedoe with We Sect rity bsumnem d all not be deemed to lave been given to tondo mild actually received by under. if sty notice requited by this $ewrhy Instrument Is also Rgnir d wader Applicable 1". the AWItsibie Law requirment will satisfy the corresponding requirement under this Security Instrument. 16. Gown ms Law; Saverabl}hy, Roles of Construction. This Security boom" skull be governed by Indent) low and do hw of do Jurisdiction In which the Propetty is located. All rights and Apobligations Lecontained In dds a. Security Instrument: are object to any nquinmams and timita im of or 11 might be silent, butssuck atle ce :be ent be ??treed u?y allow the pucks to agree by Contra coubu . In the evma that my psovisioa or dso of Ihis Security Irotrmn or the Note conflicts with Appliceble Law. tact conflict shall not affect otaa pnovisioes of this Security Instrusu m or the Now which can be given affect without the eootliedag praviskom As and in this Security Intrumma: (a) words of the IalWlinne seeder shall mesa std Include e0rra1p0Od1Ag tauter words or words of the femirdtr gander (b) words In the singular shall sum sad ittekde the plaid aced vlee versa: Wd (c) the word '=y' gives sale disaedon without ANY obligation to talc( say sedan. 17. Barroaees Copy. Borrower ftH be given oar copy of the Note and of this Security Ins a neut. 18. Trunde of the Property or a BmaBdal Interest In berswwor. Am wed in this Section 11. 'Ituaesc in Oa Property' moist any kgu or badly tl I I, , in Oc Property. iwivw R, boa riot limbed to. time bendlehl interests transferred is a bond for deed, contract for dead. iauslhow .lea outma of escrow, agrea ot, Otte has of wbidn is do mm?sfa of dit by Borrower at a It= dace to s puchaaer. If all or any part of the property or any Iettereat In the Property is sold or transferred (or if Borrower B tut a uamaah perm and a boadidd fewest in Bormwor It sold at transferred) widrout Leader's prim wrier m comm. I aden may require mmedbate payment in full of all suns sect, by Ohs Security Instrument. However, dds option shall not be c aciand by Leader If web amrriao Is prohibited by Applicable Low. If Lender esetefns dds option, leader abs11 give Borrower notice of mcdcration. The notim shag provide a period of not item than 30 days trout the date Me notice its given in moattlum with Section 15 will" which Borrower mast pay All sums secured by this Security lutrmneaL if Harrower fails to pay these wens prior (o due expiration of this period. Lender nay invoke any rents" permitted by this Security Instrument without firaw notice or demand an Renewer- W. borrower's RW to Relisote After Acceleration. If Borrower now cauln card tans, Bestow. And have the risk to lave aufaremeta of this Security Instrument disco tins it any than prior W the earliest of: (a) five days before sale of the Property pursuant to my power of ale ocotained in Oka Security hu nnow: (b) such o*w period ae Applimble Law might speclty for the mmumsdon of 110"Verees ri0 to rehatale; or (e) aby of a judgment erdwcing Oh Security losmun t. Those conditions me Oat Bortower: (a) pays I.eoder all sums which then would be due audef this Security lowumem lid the Note es if no acceleration had occurrod. (b) pmt any defndt of my other covenams or 1005961 .tit. atiN?AIown ?+rurftt rename 1W1 (Page 15 of 67) &Vumwitn, (C) pop an c>pena iacarred u eaf.ndng this Sewft laauinneot, inClnding, bill not limited m. Rumble moneys, fees. pv.pcrty inspection and ralwdon foes. and sties fops iowrmd for the pttrpoa of Protecting Leader's interact in the Property and rights wrier this Security Inebtment and (e0 lstaea such atxioa u Lacer WY trtstomWy R*IM to assure tint L Aw's intem In the Propany o d riffs srodcr NA Stsasiry Llaanmsem, aid B&Wwer's nbhhPtlon to pay the stmt secured by rids Security imtnaome, shall t it - and-Mad. L ceder taly mgaire 1bu Borrower pay writ reioulesocot arras and OW1111ta In one or snore of the following fortat, ere aelectad by Larder: (a) Cash; (b) mosey order; (c) aWd&d cam, bents dieek, tr ssurces dwck or cashier's check, provided ally oKb checlt Is drawn upon as iastidttian Most deposits at inaaad by ¦ federal ageney, isntrsstnctuatity or eothy: or (d) Eiecnonic Ponds TUNICS- VING tetmsnN mast by eormwar, tilt Security htstrament and nbligatintna Mond hereby shall Mmdit tally effective as If no moderkwe had occurred. However, this right to reiochte aba0 rut apply is th0 one of uoakradon mda section Ig_ m. Sale of Nmtr Ch=P of Lout 611rview; Notice of CAWnea. The Note or a partial barest in the Note (together with dds Sectaity Innrmneet) trot be sold one or more tunes without prior nodca to BMVW4r. A uk ttt16ht result in s change in the mky (botoan as the "Loess 5avinef) Ibat cdltsxa Periodic Paysems On miler tier Noe and this Security Inatmmew and pcrfarms other tnortgap loan servit hl6 OWIPtioma wrier Ma Note. this Security Instrument, and Applicable Law. T km giro wigbt be =1=0=141 te Lena Servicmr mulawil to a gala of the Note. If there Is a ch up CC d a Low he Given Wrhtea aodee of tiro t'hMp which Will ante On ease cud addreas of the sew L.om 9e1riaer, the addreu t0 which paymem ibuld be made and any odor itttotm bm ROPA regaira 15 GDWAW02 wide a notice of tratafer of servicity. If the Note if acid and IIer01RN the Lam 11 servlcad by a LOU SWOM COW than des: purchaser of the Nape, the mortgage laan urvicing oNipdm t0 Borrower win reaasls wlt6 the Lon Se vices or be tra wl6t.ed to a stucco; Lou Servkzr and we sot assn aid by the Note ptlrehalar tmlm od*Ms a provided by the Note purchaser. NOMM Borrower gar Lmidar my conimtatee, join, or be joined to any judidai action (u cidw u isfivk%W nthpat err die member of a dial) dat arises from the other party's actions parwm to do Security ]nsutmmt Of 1111111110601 that rite oilier PAY hat Weadhed any provision of. or cry duty owed by reaon of. this SWAY barinusm, Vail each Borrower a I.endw hu sodfied der othu peaty (witb such notice given in eomplhsce with the requirements of Section 15) of such alleged bratb std aff riled the Odd parq' Iitrao it rmaonabie pried d4a the giving of tseh notice to take cmrecfm atthios. if Applhahk Law prow s lima period which must lapse before eauin actim coo be Calm n, that tine PaW will be deaoed to be rwa -1 le for pwpom of this paragraph. The notice of aooelmll0m std MPM91Y to tzre given m Berraw r Pw=m to ScCCM n and the notion of umicrsdaa given to B-0- ptsawt 0 Section 18 WWI be doomed to satisfy do mice and opportunity to tape corrective action psuvidoa of this Seetim 20. 21. Hasst *w Ssbltaspa. As used in this Section 21. (a) 'Huardoos Sigmasees" are mm wbaomces defttad as UwJe or bsaasdow wbstancet. polluasts. or wastes by Sw4ronmmral Law and the Mk-ft wletsaca: Ps.liae. kerosene, other flunsiable or tonic pdrolcvm 1 , corder poliddee and herAcMu. volad7e aafft s. trrota(ds CoNs(ning asbeatos cc ftnuldshydc. AM radioocdvc materlah, M 'IBuvlronMMW law' mews faderat laws AN laws of the 'm 0" relate ao hailh. where the Property is located slat U* a COVIMMUAW n protadan; (c1 'fimirm®estai deaolp' Includes any stmpome 110110", rseoed(al action, or raaoval action, as defined in Finvitonme tw Law: and (d) se 'Eadmiumw Comdltim' nears a coollides tbat can Cause. contribme to, err otherwise trigger m Favirmner cal 1005967 e++.k ataAl?AI to'wq err ,a., u , ?ane 7e7n IM ?a r (Page 16 of 67) 0 0 , Borrower shat not cane or permit tie prsuthee, me, disImal. stwawe or slaw of any LLsrsrdodt Sabo &n=. or duealM to reisom shy Knordes a Subsmres, on or io M ]s?n?petty Bonowa aluU out do, oat show seyone else ¦a do. "ing off v1% the Properly (A that is to, viol . of say 8rnitosoewl Lea. (b) which t relies m Eavirawaaral CaUlition. at (c) which. tide to the praaree, use. or rdswse of a Huardmas Sobaooe, mum s coodibm that wNwady dkm are value of the ftVmy. The nreoWW nun sarteaees shall not ismy to the uw, or map am the hap" of of small q?ssotities of Haardoha Substances that art sal oeooanaed to be W rop we to normal setwoothll ewes and so maimeamee of oho Property oditrg, nos H ahted M, hawdous substoom in cons ?a lxodh"). Borrower welt promptly give Leader written mice of (a) any Sian, chin, de uad, lawmk or maim st7in by am to-nin nmtsl or reastlatoty agency ro pri party L?volvisK the and coy 1Laurdooa Substance or Emirostmawl Low of wMh Bonmrwr hoe Emil bow (b) gay to - of my Huss as ?S1sisUUnce =0 (c) my cord-1 Biasing. la ft. ditsha[ae, release or threat of by the praartA. as or release of a bHundaa Substaea which advendy offiem the value of the Property. If Borrower tams, or Is notified od uAsasdauro W Of oe.Yfeet V4 the pty. nor my Pd? party. ? nonooval or other trmediMioo remedial atdoaa In aeoadmor with Burimmogral uW, ng herei laha(1 apoor any ?, lAndcr for m GovttoaotrnW Mon, ? ? NON-UNIL ORM COVLiNANTS. Borrower and i:.eeder farther covenant and agree u follows: 22. Amicrodoo; Ra-dlsw. Leader alma give Hotta to Borrower prior to acceleration fdbwk g Bmrewer's brueb of my covenant or sunned In this Security toatrus m (hest amt prior to etxderaeloa uWa So" 16 mks Ayyp?H%abk Low prgd6m otherwlu). leader 60 as" Btareww of, camee other lhi= (e) the delaulq (b) the actlen reWAred to can the dtdhult; k) who the defadt moat be nand; and (d) that falhae to curl the "sit a dill" sway raenk fa cadaaUeo of the am second by this Stkrsrhy kokusau t, fondswure by al psaaedlog mad -k of the Property. Lander ghee fertkw idocn Homer w or the right to eehrai"of crxderatton and the HIM to eeavt in the fweaoeae lxoceelbae the iron-eldatace or a deOsott or uq oWa ddraso of berrowa b seta ummon ad foroeloaue IC Nor dduk Is not evnd as npeciMd, Lander, M Its option may rydre bamodiate poyosad to fal or oil ems mosred by this Swx* tommrst without h tbw damned and may foreclose No Seeorky Lm.tr,medt by jWkia) preemsihm. leader shell be mMtled is collect all aM mso hreurnd k Muft the rousestles WeAded to this Section 22. tacddlaa, but not Baked to, attorneys' tees and cads of alts evidence to the cdont porosilied by A e Lew. 23. Rel.na Upon paymc a of all tsmat waged by this Suavity looramoatt, dhis Stxurity laotrumda gad the state eomveyed shall tesaeisate ad booms void. Area sock ocemrence, Leader stall dbcbasge cod swHafy *0 Seeartry Irrctrrswrrrt. lorrower shah! pay my recorded- coca !.alder any ehax Besrower a See for rw:U this Se;urhg lntrumard, but only If the fee is paid to a third party for services cardered sold the CIM11109 of the fa u Prs AW under Apptirable Law. 24. Walvem tionower, to do e=q=l. gad by Apphh" 4w, waives and selasoa arty error or Wow in precatdiop to enforoe HHs nmat. and bwft wsivee the haoeHt of ay, preodr or am- Iwo providlot for stir of a acution. esraaion of tioa. eseaption from attachmuot. ley and oak, gad Ralowets Pl ioC Borrower's time (o MWWte provided la 3cation 19 shall eoaood so oar: [111OUr prior to the oaswasscem m of bidding at a sherifrs am or other sole purstarr a thin Sanity 26, Plarrhne balm" ibartPF. If any of the debt sectored by this Sawky brcuttmeat bleot to Borrower 0 unglue title to, the Property. this Socar4 Itrtnsuent shall be a Purchase money ssorgage. 27. latesot Rah Attar 3adpond. Borrower plus tort go nisaco t rue payable after j)csWmw is adored m dw Noe or ha as action of nostpp tareclnme shalt he dw rate payebio from cane to Haan adder the Now, 1005997 014MPA) agog car 14 r IS ??? vosan 3038 101 (Page 17 of 67) BY XONWG DEAN, Bmww aaa(pa and apm b the tams ud WVCM s aaW&bW hi this Seagiq 1nlnanant and in am hider eaeentd by Borman and recorded with it. Wituearrs: ?W [AAi?I Yl? (Bead) Natwha Thous e«row lap (seau 0-0 4NWID.W -sene.u ve;z J'O /"? (Sa) (sell) 01mmes Thames go,ro.er .asnawar (Sea) (Sell) -bonowa 48 map 11105907 IftiA1rAI asm ?y 16M is F" 330!9 1101 (Page 18 of 67) commm y "To OF me4snVAMW Cum On ibis, dte A dry of August. 2006 mskn;pwam-.p-onsilysppesrod Nateschs Thomas James Thooss • Coaoty M: , bdorc mc, the )mown to me (or addK*)dy Ptwjm* to be for ptasoo(s) whose cama(s) islafo subscribed m dS widdA iuwmed std aclomwhtdgsd dot hdsbddwy owmed the same for the proposes herein coaahfod. IN WITNESS WHWWOP,1 hemmto set my hood oflio)ai test. My commile u Espites: atweerme h d Pow"" Osef?IlfboMsO.e?btSryPuhre Cwbp !t ?C-ww pa ? a. am Tile orOlR?o CerN1. K Rest oc p . do bmby mnity that the ooext sddrosc of tha witbiawttted lQortgaEee la P.O. Boot 2026. Riot. BE 46!01-2026. VVhaess my bsod dds 4th day of August. 2006 ANW oMM"Im 1005987 ?.6A1?AI snw asp u r w Penn 3m 1101 Z/ (Page 19 of 67) i t In Witness Whemof, the said pa* oftbe fit part has henm o set his hand and seal the day and year fast above written. S IPLA wd Daswrod in *A Pn MCMC Of *WaF. Peters CERTIFICATE OF RESIDENCE I hereby certify, that the precise resides of the ataotee herein is as follows: 332 Rmbury Road NewrWe, PA 17241 Aflw.ey«ASer 11r d+e,ce MEUN CLMNC SERVICES, tt.C 311 N. SCOM FAR 1D. Swrt 700 WWI COUN& M 1M03 COMMONWEALTH OF PIMMVANIA SS: COUNTY OF C u4x4#144 ) On this, the A day of , 2006, before me, a Notary Public, the undersigned Qfilm, personally WAYNE F. PETERS, ]mown to me (or satisfactorily Proven) to be the person whose name is subscribed to the within ke u ncM and acknowledge that he executed the s for the purpose therein contained. IN WITNESS WMEOF, I eraaoto set my hand and official seal. Aa1??arlaitlMutArrra NOL" Nmk Orwsdsetisa Mserft?usso ' L4*-v6ofm MOM on am am (Page 20 of 67) SCHEDULE "A^ LEGAL DESCRIPTION ALL the following des *W reel carafe Wg and ben9 ailuale in Lower Mifflin Towrohip, Cumberland Count'. PermsylwNa, referred 10 as Lot No. C more partlwladq described in accordance with SubdMalon Plan entitled "final Subdtublon Plan for EO9ar S%W. Prepared by Eric L. Oiffenbaugh. Professional Land Surveyor, which sald Subdl @km Plan has bean approved by the appropriate municipal authorba and is recorded in Cumberland County Plan Book 78, Pepe 145, as tdiows• BEGINNING et a set ragtoed spike in public road SR-0987 (Roxbury Rood) at comer of the wilhin deverbad paroN and parcel 8 an the above referred to Subdivision Plan; thence aionp Roxbury Road, North 48 degrees S7 mirM s 49 seconds Eset, 50.00 feet to a point, in line of tend now or formerly of Wayne F. Patae, which Ian& the wilhn desu bad peroel Is being added to as a lot addition; thence along Peter' lards. South 48 degrees 20 mintft314 seconds ftaL 249.10 feet to a set Iron pin, In line of lands now or forreerly of Elwood R. end David W. GuMWP thence along An* of lands of GulsftW, South 33 degrees 22 minutes 56 seconds West, 60.131W to a eat Iron pin at corner of Parcel B; therm along line of parcel B. North 48 degrees 20 mkhules 14 seconds weal 202-50 feet to the sal railroad spike at point and place of BEGINNING. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. BEING Parod No. 15-D5.0411.018. RENO the same promises which Edgar L Shim and Lois A. Stum, husband and wife, by deed dated 00cember 31.2001 and reco led January IA. 2002 in CwOndand County In Deed Book 249, Ps" 4845.9 anted end conwysd unto Wayne F. Peters, a single person, UNDER ANO SUBJECT to building set beck limes, dedicated right of way lines and direr notations and cond8lons as shown on the above referred to Subdivision Plan. taru>sos-0oeot.c?a+D+e+?ooeo+n? (Page 57 of 67) ODUSTASLE RATE NOTE i MW 1002ea1001e6"017 (LIBOR Lade: - Rats Caps) THIS NOTE CONTAINS PRO VISIONS ALLOWING FOR CHANCQS IN MY INTEREST RATE AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN CHANCE AT ANY ONE TIME AND THE MAXIMUM AND MINIMUM RATE [MUST PAY. A" 4, 2006 NewvMe PA (Dan) (Chy) (Sate) 332 Rosbary Road, Newdll% PA 17241 (Property Ad&m) t. 5ORROWF.W9 PROMISE TO PAY In return fors Ioan 4W I hrm rvotivad, I promise to pay U.S. f 100.MAO (this amctmt is called 'pincipal"), plus interest, to the order of the Lender. The Larder is Bquiltinyt CwWmd= . I will nuke ALI payneata under this Note Indic form of cash, chock or money order. I undemttnd that the Linder o'+eY ttansfar this Note. The Leader err anyone who takes this Note by tramfer and who is entitled to motive payments under this Note is called the "Note Holder." Z. INTEREST Interest will be charged on unpaid principal until Cho fait amours of principal has beco paid. I will pay interest to a yearly rate of 11-100 % The latest rata I will pay may chance in amoodance with Section 4 of the Noss Tho interest rate rNuuod by this Section 2 and Section 4 of this Note is the rats 1 vnll pay both before and after any, default desonbad in Section 7(B) of this Note. 3. PAYMENTS (A) Thus and Placer of Payments I will I will ?opal sad interat by maki:4 a payment every momth. paid all o the pi ci on S inters err 20% I will make ?? payments payments on the Lot have ofeach month awry month twit I principal will 'appal sad soy other charges described below that [ may owe wader this Note. Each monthly paymat iL be sppliad m of its ecledalad due dote and will be twphod Co interest before principal. If ore August 1, 2036 I still own amounts under this Note, I will pry those amounts in foil om that dote, which is called the "Maturity Date." I will make my monthly payments at EgdFlrst Corporation, 300 Forage Point Circle, Charlotte, NC 28273 or at a dif event place ifaquited by die Note Holder. (B) Anonmt of my initial Meet* Paymeatr Facb of my initial motth[y payments will be in the emoum of U.S. S 754.79 . TLis amount may lunge. (C) pGathly Payment Changes Chamsas in my monthly payment will reflect changes in the unpaid principal ofmy ban and in die imtamt rate that I most pay. The Now Holder will determine my new interest aft and the changed amount of Lay = *aft payment in aooordtuce with Section 4 of this Nora Multistate Adjustable Rata Nots-Ubor mdse FFSISN(2=) (PannylvaniaVersion) Loco Number 1005967 Page I of 4 Ioitiala (Page 58 of 67) 0 0 4. INTEREST RATE AND MOOLY PAYMENT CHANGES (A) Clia4ge Oaks 'I7ie fntpeit rate I will pay MAY cbattyc on Augod 1, 7411. and on this day every sixth month tbemafter. Fach date on which my itaerest rate could choose is called a "Change Data" (B) The Index Beginning with the fast Qlange Dar, myy interest rate will be baud an an Indent. The "Index" Is the avenge of interbank offered rates for six-month U.S. dotlar•denaminakd deposits is the London market ("LIBOR'). se publisbed in The Waft S&vwJosrna4 The most recent index figure available as of the sing bughi as day of the -1h irmoadiarly prarediog Use month in which the Change Date ocean is called the "Cwmw lnft% if We Index is no kmW available, the Note Holder will choose a new index that is based upon comparable information. The Nor Holder will give me aotiee nr m.i" rn,..i.,,. (c) Calsalatlon of changes WON* each Change Data, the Note folder will calculate my oew interest rate by adding 5790 pamontage poiAU (3.710 %) to the C wren [admin. Tbt Now bolder will that roved the malt ofthlc addition to the mamma ono-eillhde ofone percentage point (0.125%). StMeot to the limits allied is Section 4(D) below, this mended amount will be my new inthaest mat until tim non Change Data Ties Note Holder will then determine the arnount of the monthly paym a that watts be Wooieot to raw the unPW substantially then l am expected to owe at the (grange Date is full am the Maturity Date at my new iskrest race its a y equal payments. The rsmh of this calculation will be the Dew moment army monthly psymmat. (D) Limits N Warmest Rate CYsages The internal rate ) am required to pay c the first Change Daft will rot be gmsftr than 11390% or laa dun 83110 %, Thermfier, myy interest rata will never be increased of decreased on my single Change Data by mho than one percentage pore (I.000SG) from the rote of interest I hove been psyiny for the prmoedint an mood a MY interest rate will mevu be greater dam 14300% or [as d= We initial interest raft provided for in Section 2 of thin Note. (E) Effective Date etChange My new interest ran wilt become effective on each Change Dana. 1 will psy the smouat oftoy new Maidbly PsYment begitming oo the first trtonWly psymcet date after the Change Date until the ®omd army monthly p"Numn changes again. R7 Notice sf chaages The Note Holder will deliver or trail to ms a notice of emy changes in my interest rate and rho amamt army moodly Payment balers the effective date of any clump, The notice will include information required by law to be given me and also tae title and telephone member DF4 person who will answer any question I may bave regrading the notice. 5. BORROWER RIGHT TO PREPAY (A) Prepayment I have the rWm to make payments at any time before they are due. A p"meot of principal only is known as a "p?gaymcm". When I maker a prepayment, f will tell the Note Holder in writing I as daft so. If i make a Now partial prepaymem, there will be no duanga in the doe date or in the amamt of my moony payment Oakes the Holder agrees in writing to those clutoges. My partial prepayment nay reduce die =--t of MY monthly payments after the first Change Date following my partial prepayment, However, any reduction doe to my partial prepayment may be offset by m interest rue increase. (B) Prepayment Penalty In the event, during the fast 2 years afterthe execution of this Nob, f make a props Mom ad the exceeds twenty Poems (20%) of the original principal mmotmt of the, loop in airy twelve (t2) month p t will pay a PrIPaY01" obaW in m hatemmt equal to mix (6) enaniha' sdrmce interest to the commas prepaid which in in excess of twenty permew (20%) of the original. principal amount of *a loan within the twelve (12) Mond, paned The Note Holder w(ll not assess a prepayment penahy after the tad anniversary of the dew of execution of this Note. EF815N Loan Number 1003987 Page 2 of 4 IoitialaL (Page 59 of 67) 0 0 f. LOAN CHARGES If a law, which applies to and which seu maximum loan charges, iaay Warproted as tint the interest or other loco chs" collxtcd or to be collauad in connection with this tom exceed the permitted limim then: (f) any such lots charge &all be reduced by the amour accessary to reduce do charge an the parmiWA limit, and (h)say sums almady eolketed from tae wbkh exceeded pamiuctl limits will be refunded to me. The Nom Hofdcr may chose to make This M&W by reducing the principal I owe urdor obis Now or by making & dhw payment to me. Ifa refund roduces principal, the reduction will be treated as a partial prepaymomL 7. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Lak Charge for Overdue Payments 1f the Note Holder has not received the full amount of any monibly pnym4w by the and of 15 coleadsd days after the date it is due, 1 wilt pay a lass charge to the Note Holdec The omoum of the ehW, will be 3A0 %of my overdue pays W of prioeiyal and interea I will pay this law charge but only once on cub late payment (8) Defaun If 140 not pay the full amount of each monthly payment oa the due it is due, I will be in default (C) Native of Default If 14111 is defwh,11115 Note holder may sand me a wrium notice telling me that if l do not pay the ovadae amount by a amain data dike Now Holder may requite ma to pay immWiW* she full amonnt of principal which ban not bum paid and all the interest that I owe on that amount. 'floe[ due must be at teW 30 days after We date on whkb the nolice is mailed to me or delivered by other meats (D) No Waiver By Note Holder Even it at a time when I am in default, the Now Holderdoes not repire me to pay immediately in full a described above, the Now Holder will still have the right to do so if I am in default at a later time. (E) Payment of'Noto Holdoes Costs and Expenses If the Now Holder has required ma to pay in &11 o described show, the Now Holder will have the right to be paid beck by no for all of its costs sad expenses in enforcing this Now to the extent act probiblaed by applicable law. Those wWcn es iodude, for example, reasonable smomoye fem. L GIVING OF NOTICE$ Ualase applicabfe law Mullet a diff"Int method. Say notice list must be given to me under this Now will be gr??s by deiulveeing it or by mailing it by fast class mail to swag the Property Addmss above or st a diffis. t addrda if I give tbeN m Holdera notice of my difEmm addrtu, Any wtiee that maxt be given to the Now Holder unda this Now will be given by delivering It or by muffing it by fust clue snail to On Now Holder at the address awed in Section 3(A) above or at a difianot address if I an given a notice of shat dilfaent address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE Itmorethan one polo I signs this Now, each penman is fully and personally obligated to "all of the promises trade in this Note, including the promise to pay the full amount owed Any petaom who u a gramme, ninety or eudi not of this Note is also obligated to do these things. Any person who alma over these tabligatiome, inetedrng the obiigadom of a ghrnator, surety or trhdoraer of this Note, is also obligated lokeep all of the pnamiars made in this Note. The Now Heider may oaflxee its Tipts undw [hie Note against tub pen *AIM dtmlly of a aunt a0 of ul loS ather. Titio taoarnl mat any one of as may be required to pay III of the amomnts awed huder this l a. 10. wArmw I and arty ether person who has obligations under this Now wain the righq of paesrarmtem rood to do o of diabomor. "preaemtmaot• wow e die riot to require the Now Holder to demand psymom of amomou dun. "Notice of dishonor moans du right. to require the Now Holder to give notice to other pcrsmu that au studs due have not been paid. MISN Loon Number I D05987 Page 3 of 1 Iaitiala (Page 60 of 67) 11. UNIFORM SECURED N This Nee is a unifona iniNFAM with limited variations in aormajudad.in addition to the ptowtious liven to the NOW HOWcr under this Note, a MOngagc, Decd of Trtut or Security Deed (the "Security hei utnext"). dated the same date as this Note, cm the Note Holder born possible lesson which aught rwak if I do not lamp the premises that I male; in dtit: Note. That Security Instrument desenba how sell trader whet caaditioes I maybe required to make immediate payment in full of all amounts I owo under this Note. Some of those conditions we descried u follows: Transfer of as Property or a Banelicial Interest to Bormwer.lf all or any pan of the rmperty er any ietapt in 16e Property is 60141 or tamsfenvd (or if borrower is trot a natural person and a batel'ie d 'interest to Borrower is sold or onasfarad), without Laedera prior wrinan coamnt, Lewder may, at Its option, cognac imtoedide payment in W1I of ail maims secured by this Security latm rrtent, However, this option ?s0 wt be eaterciaed by Larder if exercise is prohibited by Applicabk Lsw. Lender also dull m exercise this opow if. (a) Bamwer cum to be tmbgtitted b l ender'mforaution rrceqTus by l: mdrs to evaluate tbo insenW irsasfaeeacif a craw loan were beinj made to tbo oamfatui and (b) Umderrressooebly detamtinos that Lxs?der's so=* wM got ba ierpabarl by the roan aaaumpdOn and that the risk of a brLaelt of fury cuvcnsmt of agtaaxatt lot tbia Security lastrurmatis soceptabk blander. To the extent permitted by Applicable Law, Lender mey charge a rusauble fee a, a condition to Lendars comseot b the bag awuaptiols. Lender cosy elm require the Iraasferee to sign sn tramptimr gpuemugt that 'r ut>"Le to Larder and that obligates dun trarsferce to keep all the promises mad sammwrus made in the Nuts and in this Security lrabrratag. Borrower will continue to be obligaxod under the Note and this Security htaautamt unhoa Leader rehouse Borrower in writing. If Leader exxaeion the option to require immediate payment in fall, Leader d WI Siva BrumvKr aetiee of acceleration. The malice *All provide a period of not lea than 30 days from the date the notice is given io accordance with Section 15 within which Borrower must my all sums secured by thin Scou ity ittauoumL If 9orrowar fails to pay these neat peiar to the expiration of this perled, Leader may ievdoe my remedies permitted by ibis Sect rity Instrumma willwut further notice or demand an Borrows. "WT1'NESS THE HAND($) AND SEAL(S) OF THE UNDERSIGNED" (Scup (Sod) Nataseha Thoeus -tlostarrer -garoew (S-1) (Seel) .Borrow -noncan (Seal) EF51SN Low Number 1005987 Page 4 of 4 loitiak (Seal) (Page 61 of 67) • 0 ADJUSTAC RATE INTEREST RATE &R & PREPAYMENT PENALTY Addendum to Note This AMSTABLE INTEREST RATE FLOOR k PREPAYMENT PENALTY ADDENDUM! is made this 41h day of August, 200ti, and smeods the Note in the anotud of U.S. $ 100,000.00 dated the lame date and pvea by dw polaoa(s) wlro signs below (the "Borrower(s)") to EquiFiret Corporation (the "Lander). In additicit tD ells agrcami;m and ptovisium mado in the Note and the Secur* lnnirunicot, and ootwithnandotg -Y provitioas so the contrary mdaiaed in mid Note or the Swurity loa rimimt, Loth the Borrower(s) and the Landes !lather .arm m fellows: ADJUSTABLE MMUST RATE FLOOR This low hu as Intersu Rate `Floor' which will limit the mount the Intent! Rate em decrease. Regardless of any chi m po ion the imdwc, tic Interest Rare during tho tam of this bm will nover bo ktn than dw in"lmerat Rate provided for in Section 2 of the Note. PREPAYMENT PENALTY In the eveoL dutiog the lost 2 yem afro the enceution of this Note, l make a pmpaymed and the pmpsymmt ea0666 rimly peon (20%) of the original principal amount of the boo in any twelve (12) month pewd., I will pay a pmpaytnemt d?urge in u amount equal to sic (6) maodW advance interest on the amount pmpmd which is in .moon of twenty percent (20%) of the origimd principal amount of the loan within the wslva 12) month period. The Note holder will not assess a prepayment penalty alkr the 2nd amnivwssry of the date of aecution of ibis Note. 40a w Nataaths Thomas 1005987 en" (12" PLUESE, BECKER & SALTZMAN, LLC Attorneys at Law ROB SALTZMAN • RSaltzman(a pbslaw. ore SANFORD J. BECKER S Becke r(a?pbsl aw. ore ROBERT T. PLUESE RPluesenpbslaw ore ROBERT F. THOMAS • RThomas(a.pbslaw. ora 20000 HORIZON WAY SUITE 900 MT. LAUREL, NEW JERSEY 08054-4318 (856) 813-1700 FACSIMILE: (856) 813-1720 PENNSYLVANIA OFFICE: 425 COMMERCE DRIVE, SUITE 100 FORT WASHINGTON, PA. 19034 (215) 546-3205 OF COUNSEL: Katz, Ettin & Levine, P.C. The Law Offices-of Barbara A. Fein, P.C. • • PA and NJ Bars Our File #84050 Please reply to: Mt. Laurel, New Jersey March 6, 2008 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on our home is in default and the lender intends to foreclose. S ecific information about the nature of the default is rovided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM HEMAP may be able to help to save your home This Notice explains how the program works To see if HEMAP can hel ou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving our County are listed at the end of this Notice If you have anyquestions you may call the Pennsylvania Housing Finance Agency toll free at 1-800 342 2397 (Persons with impaired hearing can call (717) 780-1869)This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney_in your area. The-local bar ass_o_ciationmay_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): Natascha Thomas and James Thomas PROPERTY ADDRESS:332 Roxbury Road, Newville, PA 17241 LOAN ACCT. NO.: 2375082 ORIGINAL LENDER: Mortgage Electronic Registration Systems Inc. as Nominee for Equifirst Corporation CURRENT SERVICER: Franklin Credit Management Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure. on your_mortgage_for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing 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 D-EF-AULT-(Bring it up to- date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at 332 Roxbury Road. Newville PA 17241: IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS of $891.53 since the April 1, 2007, to the present and the following amounts are now past due: $11,589.89. Late Charges: $264.18 Escrow Advance Balance: $242.66 BPO/Inspection/Property Preservation: $95.00 Available/Unapplied Funds: -$40.43 TOTAL AMOUNT PAST DUE: $12,151.30 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 12,151.30, 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: Name of Servicer: Franklin Credit Management Corporation Address: 101 Hudson Street, 25th Floor, Jersey City, NJ 07302 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay- off the mortgage_debt._ If the lender refers your case to, its attorneys, but_y_011_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 any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. , EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 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: Name of Lender: Franklin Credit Management Corporation Address: 101 Hudson Street, 25th Floor, Jersey City, NJ 07302 Phone Number: 201-604-1800 Fax Number: 201-604-4510 EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs 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 _X_ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume_the_mortgage debt,_prov_ided 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 ARE ATTACHED. M 7160 3901 9845 5309 3638 To?iatascha Thomas 32 Roxbury Road ewville, PA 17241 I i ? SENDER: Je REFERENCE: 84050acts e' PS Form 3800 January 2005 b38 RETURN ? • e C,3?q RE RECEIPT SER Certifi q5 • VICE Retu 9oy Restrii ?ybo ? • .00 Tots) P 0.00 us Postal Service POSTMARK OR DATE Receipt for Certified Mail (e No Insurance Coverage Provided ?C i Do Not Use for Intem6onal MaB 7160 3901 9845 5309 3621 Tojames Thomas 332 Roxbury Road Newville, PA 17241 SENDER: je REFERENCE: 84050acts PS Form 3800, January 200 • 32 . ? 9 3b21 To- RE RE URN _ c 30 0 S y 9x45 ' ?. • . o ?yb0 3q0 • 0.00 ees 0.00 US Postal SerVics POSTMARK OR DATE Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for Irnemational Mail V3 lJ? ? ? SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02536 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT - --- but was unable to locate Him in his bailiwick. He therefore returns the the within named DEFENDANT 332 ROXBURY ROAD NEWVILLE, PA 17241 THERE WERE NO OTHER OCCUPANTS. , OCCUPANT NOT FOUND , as to Sheriff's Costs: Docketing Service .Y/1H/0-- So answers: j 6.00 Not Found Surcharge ?'. .00 5.00 R. Th as Mine 10.00 Sheriff of Cumberland County ? 21.00 PLUESE BECKER SALTZMAN 05/12/2008 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-02536 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THOMAS NATASCHA the DEFENDANT , at 1737:00 HOURS, on the 9th day of May , 2008 at 332 ROXBURY ROAD NEWVILLE, PA 17241 NATASCHA THOMAS by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 28.00 'r Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 S/?y?6P ? 56.00 05/12/2008 PLUESE BECKER SALTZMAN Sworn and Subscibed to By: _ before me this day Deputy Sheriff of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-02536 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TTSnM'A C .77%MLIC the DEFENDANT , at 1737:00 HOURS, on the 9th day of May 2008 at 332 ROXBURY ROAD NEWVILLE, PA 17241 by handing to NATASCHA THOMAS, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 5/Iy?D P ?/ 16.00 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 05/12/2008 PLUESE BECKER SALTZMAN By. Deputy Sheriff A. D. Pluese, Becker & Saltzman, LLC Robert F. Thomas, Esquire Attorney Identification No.: 70206 20000 Horizon Way, Ste 900 Mt. Laurel, NJ 08054 (856) 813-1700 Attorneys for Plaintiff FRANKLIN CREDIT MANAGEMENT CORPORATION Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY oS - as3,? `'T' NATASCHA THOMAS (RECORD OWNER AND MORTGAGOR) AND JAMES THOMAS (MORTGAGOR ONLY) Defendants. CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE NOTICE NOTICIA YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH N 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 THE 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. 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. LE HAN DEMANDADOA USTED EN LA CORTE. SIUSTEDQUIEKEDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE (20) DIAS DE PLAZO A PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHI V AR EN LA CORTE SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO0 NOTIFICACION 0 POR CUALQIER QUEIA 0 ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO, SUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA. ESTA OFICIANA PUEDE PROVEER DE USTED LA INFORMAC16N SOBRE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PERMITIRSE A LA IRA DE H A LA CAPA, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACON SOBRE LAS AGENCIAS QUE PUEDEN OFRECER SERVICIOS JURIDICOS A LAS CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 1/800-990-9108 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 1/800-990-9108 TFWE COPY FROM RECORD to Testlnlony whered, I pore unto set my t" wa of said a>Itw • Pa• r y CIVIL ACTION -- COMPLAINT IN MORTGAGE FORECLOSURE 1. The Plaintiff, Franklin Credit Management Corporation is a corporation having been organized under the laws of the United States of America and having its principal place of business at 101 Hudson Street, 25`h Floor, Jersey City, NJ 07302. 2. (a) Defendants, Natascha Thomas (mortgagor and record owner) and James Thomas (mortgagor only) are individuals whose last known address is 332 Roxbury Road, Newville, PA 17241 (b) Defendant, Natascha Thomas holds an interest in the subject property as mortgagor and record owner. Defendant, James Thomas holds an interest in the subject property as mortgagor only. (c) If any of the above named Defendants are deceased, this action shall proceed against the deceased Defendant's heirs, assigns, successors, administrators, personal representatives and/or executors through their estate whether the estate is probated. 3. (a) The subject mortgage (the "Mortgage") is described as follows: Mortgage executed on: August 4, 2006 Mortgage recorded: August 14, 2006 in Mortgage Book 1962, page 1579 Mortgage re-recorded: December 11, 2006 in Mortgage Book 1975 page 4296 County of. Cumberland See Exhibit "A," Note and Mortgage. (b) The Mortgage encumbers property (the "Subject Property") located at: 332 Roxbury Road, Newville, PA 17241. (c) The "legal" description of the Subject Property, expressed in metes and bounds, is incorporated in the Mortgage. See Exhibit "A," Mortgage. 4. The requisite pre-foreclosure Combined "Act" Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". 5. The Mortgage is in default (the "Default") because the Defendant(s) failed to timely tender the monthly payment of $891.53 due and/or to be applied to the payment due May 1, 2007 (the "Default Date"), and thereafter failed to make the monthly payments. 6. Pursuant to the terms of the Mortgage, the secured loan obligation has been accelerated. 7. By reason of the foregoing Default, Plaintiff respectfully requests entry of judgment in rem incorporating the following sums: (a) Outstanding Principal Balance $99,348.93 (b) Interest due and owing at the rate of 8.30% calculated from the Default Date through April 4, 2008. Interest will continue to accrue at the per diem rate of $22.59 through the date of entry of Judgment in rem. $8,291.10 (c) Attorneys' fees $1,250.00 (d) Escrow Advance Balance $242.66 (e) Title Search $333.00 (f) BPO/Inspection/Property Preservation $95.00 (g) Release Fee $25.00 (h) Available/Unapplied Funds -$40.43 (i) Late Charge Balance $264.18 (j) Delinquent Real Estate Taxes Paid For $1,336.20 By Plaintiff TOTAL INREM JUDGMENT SOUGHT BY PLAINTIFF $111,145.64 8. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated or satisfied prior to the Sale, reasonable attorneys' fees will be charged. WHEREFORE, the Plaintiff demands: Entry of Judgment in rem against the Defendants above named in the total amount of $111,145.64 as stated at Paragraph 6, plus all additional interest, additional escrow advances expended, additional late charges and any other costs incurred through the date of entry of Judgment; and Foreclosure of the mortgagors' equity of redemption and that of any persons or entities holding or claiming under them and Sheriffs Sale of the subject mortgaged property. Respectfully Submitted, Pluese, Becker & Salt LC. By: Robe F. Thomas, Esquire Attorney for Plaintiff NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT, (the act), 15 U.S.C. SECTION 1601 AS AMENDED To the extent the act may apply, please be advised of the following: 1. The amount of the original debt is stated in paragraph one of the Complaint attached hereto. 2. The Plaintiff who is named in the attached Notice to Plead and Complaint is the Creditor to whom the debt is owed. 3. The debt described in the Complaint attached hereto and evidenced by the copy of the mortgage/note will be assumed to be valid by the Creditor's law firm, unless the Debtor(s), within thirty days after receipt of this notice, disputes, in writing, the validity of.the debt or some portion thereof. 4. If the Debtor notifies the Creditor's law firm in writing within thirty days of the receipt of this notice that the debt or anyportion thereof is disputed, the Creditor's law firm will obtain verification of the debt and a copy of the verification will be mailed to the Debtor by the Creditor's law firm. 5. If the Creditor who is named as Plaintiff in the attached Notice to Plead and Complaint is not the original creditor, and if the Debtor makes written request to the Creditor's law firm within twenty (20) days from the receipt of this Notice, the name and address of the original Creditor will be mailed to the Debtor by the Creditor's law firm. 6. Written request should be addressed to Pluese, Becker & Saltzman, LLC 20000 Horizon Way Suite 900 Mt Laurel, New Jersey 08054.. Attention: Rob Saltzman, Esquire VERIFICATION The undersigned, an authorized representative for Franklin Credit Management Corporation, the instant Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are taken from the records maintained by the Plaintiff and reviewed by the undersigned who has personal knowledge and access to the business records of the Mortgage held by the Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa C.S.A. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: `DA (b BY: Nam Title: Loan No. 2375082 (rage a of 67) 9 M-UmWis EgviFirst Corporation 1.wtderYa Corporation orsoraad and existing wrier the laws of North Carolina Leeler'seddressis 500 Forest Point Circle, Charlotte. NC 28273 M 'None" mere the proeahaory sots dyad by Borrower and dared August 4. 2006 TbeNorcsta=11m lurruvreroweaL.adorone hundred thousand and 00/100 Ddlaes (U.S. 5300.000.00 > plus )merest. Borrower has promised to pay this debt in regular Periodic Psysown end loply the debt is gill ad later than August 1. 2036 (i) 'Ptvpafy' waw the propatr )hat is described below under the heading 'Tmmhr of RWn In ma may' (ter 'i?' mums rte delft widmced by ebe Nape. phs haerm, any prtpaymew charges and Isee charges den under me Nose, and all macs due tinder dtis Staff" Insattmem. phs Intent. (BD "RWkW moor elf Ridon to this Security Intrrmeac drat are atowtod by Borrower, The tollowine Riders we to be asewead by Borrower (meek boa a spplinblel. A4PStable Rate Rider Cordominiom Rider Second lime Rider BeHoon Rider Planted Unit Dwelop net Rider 1.4 poorly Rider VA Rider Biweekly Payment Ride ? Odta(s) fapa*) ARK Floor/ Prepay Rider (9) "AypNe" Lew' memo a• aowedin appliatbie hdeesl, siaw std local swum, tttNoiMI*M. vrdbs and adodslasradve rota aid orders (tern hart the effect of iaw) as wdl ¦ all appik&kl 6oai. NOW bbk vial opiniona. P) twig AmodriOom Dear Tees. and Anaomatu• towns aN dam fete, nseaameate and odter IN acs ddt w ist)osed as Borrower of the Propeny by a eoadominiom mociarim hemteowspa association or thaw a rpw=fi n. (IQ 'Na anete Floods Tr= wW means any awkr of funds, ether: M a parsardoa orl8irsetd by eaaek, daft, or "Mat ppr kobwoeet. wN& is lrydawa dwmyh an dedrasie awro(ad, htaphode isasrmoeml, ta)tttp)mr, or stagnedc tape so as to order. kstrat4 or aafhar n a financial ins dasioo as dobit a credit as WMWV. Shah nom i0¢ipdes, bur is not Natiaed to, peinofsale pacaI . 901011021e6 WNW macMa passudons, passion hddamd by adephora, win tnaska, and » asomsead doarbgkawe (14'Unerw how' mew these hums tat ere described in Seedon 3. (DO lbOndleraaaa Promo de smas any ccompouasion. walamatt. award of di nuea, cc pps0co0di paid by any t)tk+d pony (osier Ow insurance proceeds poid order site aovenges described In Saerioa s) lino i11 dump so, or deseracdort of. the Pte)pmty- (f) coadeatn IM or OdW talotg of all Of noy pat Of 00 paoperty, (iii) oonvoym is Kew of coodemeadon. or (iv) mimpraeeodoss of, or oroiadons as R k tier wales otdlbr C redid" of tier Proem, A Nmw pp his onowe means i0itrm Pmmc P4 i esdtr apron the wapaymeat at, or defartt eta, the LONG. (09 "Medic Payment' mesas the n:Vdady sabodelad amom doe !br (1) principal and iaaaaert under tin Note, pha (ii) rg ateocrnts miler Andoe 3 of this So" Iwomeaat. 3005087 rrarn t®•eArAt moor ww r r +s , a fww 2039 tAt (Page 5 of 6?) • i Q)'RMA• eaou Am lid 8ote Sod==* Ptooedim Act (12 U.B.C. Seadom 2601 at Pq.) aM ilt "We at =W be nowded Mae dm to dais. a MY _W tee l _ ?ar?egWniatt tltit pver?Nt some Ir*d eW , At wed k Ikk 11 "k to a 'fed.rtl? da ed Pl od mttpp IoW cues iifo do Lout does rot quality as a "fdardy Wated ? wwVW ? icon' ceder A. (Q)'Semta w b leeeee - of Demurrer" seam soy party do bee ruses tine tb me P.*Mty, whodw or not tau PM ku asnroed Doi won's obligedon raider de)iete "or this Security babamaL TRANSPBR OF RX*M IN THE MOPEM This Sassily halrom a secmes w Lender. 0) tae mpsymeet d tie Loan, sad sop ranetvala, 40120i0116 tad etadl6atI I of do Noe; and (ii) the per(ontw of Borrower's eavenmw and eSmem w under d3? Sgwrhy blattemuM ad do Notts. For this pmpoa. Bornvaw does bereby mortgage, Vast and ooevey to MW (eeleb a• Mosinee for LmWw and LoOer's s wumors and asdgaa) and to On sawamoss and recipes of dE1tS, the fallaritig deuxSbed prgarry loraaed io the County [iyeed%sam*%Jvdadlaa.) of Cumberland ph-ofRUWWSJaiieiC See Attached Exhibit A stkb arteony has nee okkw of 332 Roxbury Rold Neavi l l e Ic iW, Pennsylvania 17241 IZte camel (*Pwpaty Addtras7: TOOMM WIN aU tae improveaerares am or bwMAar Waded am doe pmpany, and an glima -IM ,sbalt sows ba oo+ar?ad firom now or benraJler ¦ Pert of to AN sphommeM and td by dids Severity hanums. A11 of the ?ir left rad to Is Oft 1eSe?e/ "log lNt as *a 'Pmpesty.- Borrow oedardmads and fines drt holds 0* lepi tide LetmreM CL by Bortos er in dis Sat" lsum t, bat, if oeaeaty so mtxpty WIM Idw Of owtam1. MUS ON oomiin for ) fldn sad Lades a m ossfact mad ?q ) has de tWM to eseeiee ANY or d1 of droes inwasm. hdWft. but cot liodrad m, tae ftht so for ose smd no &a Properly: and to Was MV SWOM ragalred -Of IMWW ft=Wig. but mot limited to, tekWq and aoceft this Seaeity INWAMd. 1005!87 ®-eArAImmi ry.awis Pa,wam trot (page 6 of 67) 0 BORROWER COVENANTS dat Boaoww is lairfWy seized of Ow adMe hareby esmsyed cad bar the A& is raortpp, pat end cs'nKy the hope" and the the Propeny is vatacutw d. eaoept for arasallsmon of nwrd. Berwau warrans sd will ddard pteispy the dde to the property spbust all deloused demands, nhjod many eauumbraeoes of io n, . THIS SBCURrrY INSTRUMENT combimx umifmm eovenasu for sutionl vas and soa-osdfmm oovssaw wilt Radval vaisum by Jurisdiction to eoaduas a sdfam security btastt meet combat reel UNIPORht COVENANTS. Bxsowrer and Lander oowaast and ages as fellows: L pspumh of fri ciloot, 3saeel, Becron !seas, Mgayment Cbsrpe, and Lae CbwpL Bananas shalt pay when des the prhidpal of, sad latersn on, the debt wvWmcod by rise Near and any I IP10 'M - I rtI and We MIMPOK due under the Note. Barone: doll also pay tads der Evetow Naps Itrwam CO Secdsn 3. Peymesp due under the Note and Ibis Sat'urby to wino al ahaR be suds Is U.S. wn mq. However, if way ebeek or other iesnnanem raoeirad by lssdr m payment under the Mme or sir L%0M tp Insttunan 4 rmrrued tD Larder utrpsid, Leader may again tbu say a ell adleegaa) psyms- dw ander dw )lore erd this 3waity tasnurem be made in ore or are of the fo kmft forms. as seteaed by Leader. (a) auk: (b) sway order; (c) tormied deck book cbo&. mcnoxer's check or cashier's check provided eery web deck B drawn upon an uadmim whose deposits one lsaaed by a fi+dors, sp.oy. k@Wmo relisy, or mtlty; or (d) Electeonie puss Traafer. Hymn a an dead s=Mvrd by Lender when rs'ee{ved at dos loeaden da gmea d is the Noes or at web other leonroa as any be dullpmed by Leader la accmdsom wbh the natiee VmM m is Seodua 13. Lender May rases and payment ar partial prymsst if the psyas, a partial payments are (aafdaieot on bft Me Lau arrant. Linder may occW say paystml or partial Wyment iswBitdw to bring the Lana ouunmt, wybout waiver of say rijlss hsemuue I or prejrdce to is dillas to n:Me rich pan" or per" payments In 69 Aulum, but Leader is not eMfpsed to apply tads payments a de dean each palms- ace atm*m& H ands Nwiodlc payment Is applied as of ma whedaMd das dose. than. Lender rand as pay iwseet a uat Wkd (leads. Leader say bald nab uwppilod fads nazi! Bmroww moloss payauent to kiwi. the Loss ease a. It Borrower doss as do to wbMn a reasonable pariod of time, Lender shell decor ** W& UMudt Cr MM 010 10 Dwamer. If oat applied sailler. Much Ilatds will be q*W in due eetstooft prlaeipel baoaos' Hader dm Nose humodloody price to Iheeelesers. No et6st or clam whisk Borsv.er MEW have 0aw or In the !bars tuplat Lander MR relieve Borrower ftum malft psyme- due under the None and dds Swaft )newest or pubnu g the twva um and ajretaats saunad by dds Se moty ieosruawt. 2. Ap'plicatiea of Paymeale or Feues'ede BRNO a otherwise described In dole section 2, all psymeew accepted end applied by I.errder shag be spplisd In 1M Mosd% order of ptiorby: (a) Maness due uudw the Nom: (b) principal des' cadet else Nett, (a) emosmu des odor Beefim 3. Sash ps"W" shell be spoiied on a&& Periodic Hymen is do order Its which it berme doe. Any Mub tR MOMS shall be sppNW first to Las aunts, woad on my voter aamute due order this Secorky Iwaums m. and then to ndm As principal Whooe of the Noss. If Lauder modves a payment Ilom Boeoatr far a delinquent Periodic Hyuawt which mchni s a sufficient sworn b pay say less dw p dra, dw peymast may be MW a the ddkgmm psynat and ells' lets CWW. It more toes an Hskudie payment is cmastw ft. Lander may apply eel poyma d, teab s tram Berrewer to On repayment of the Periodic Paymssts if, and to the astam that, each payment 10069!7 sears ?? anew ?sr s r ss F. 7a7a 1101 . (Page 7 of 67) cao be pad in M. To dm amtaa oat may Mom Ctim aft the pymmt is aP911811 to do fall Pwpoen of ode or moor Periodic hymen. ateb mm my be appliod to aq I= dAw due. VoWmuY pmpgaadta doll be applied &a a mW pfcprpwm d wqp ad tos a descdW in dw We. "W sppirntios of prymwsk iom"m proceeds, or misumumom Proom& to prindw doe mder the Now sWI not egead or postpode the due due, or troop the am , . of tin Palodic Paymmn. 3. Fns& far Lasw Itaw. Bonowu shall pay a Lower on der dory Pwkdi9 Fgmwn am due silo the Note. nail do Nom Is pd is MR, a sm (Mt •Pmodh to provide for pun" of sours due for (a) tame iod as ammettb std oiler hors w" ca muds ptionly over an Scm* Imawmar a s Iles of ewombneoe an dw Phopmrty; (b) ImuWd peroaraa or pound rows an to Plopeee3. N sty: (e) promilo s for aq add all lmwm m nrlp nd by Leader udder Section S, and (d) Manpp br wwm pnwbuz d. If may. or my srmt pay" by Borrower to Lsdida In lieu of d0 I q of mwtpp Indsrrou pramimm is wcordmc wilk do provision of Swdm 10. Tbaa 31sos are Called "Famw Itwu.' At adlisadon or at arty dear &wkj die seam of the Lam. LwAw may require do Gnrnnmdb Amociamion DwL Fame, ad Aunmwu, if sq. be atxowed by Borrower, add dash dues. foss and assaawaars airl! rx a Eeoow hu. eoeaww shmB pros?pty Iloerddh to Lander au lwtiora of amaom b be paid nda this SoedaL Bamwsr doB pay Leader the Amdr for PArvw Ions anlat Lender waives Sonowmes obtiptiod to py the Pudds for my or all Estrum Raw La dw may w4l" Sons-,6 ddigatioa b pey p I.eoder Fords for ¦q or all Escrow Item Many tbne. Any ma waiver mq only be In writhe. In the evau of such waiver. Borromror"pry directly, wbom and Mbar pyabla, the smomu due lbr say Numw hems for Mhdd1 paymm of Fads bu bees waivtd by I.esder sad. if Leader mgd m dba11 fremish me I.estdsr raomho evidsrau g such pdymm wkWs seek dme period a Lndar sq mpdn. Boreowmes obligation m amb mach pym m rd a ptowids seceipm dnll for sill ptpmw be d mmed a be a comamm ma agrOmra - combmd is this Sscw* imtnmam. as the phras *cwsaot add apam m* is used is Section 9. If Harrower Is ablipted a pay Escrow Items directly. pwumsr a a waiver. ud Bamww bus 10 pay Iha amours dra for a Em m item. L atdsr mey cmat a ib rwn Md" budos 9 awl pay nab amosn and Borrower shad dm be oW*ud under Section 9 a rapay to I aaeer ag sdcb amoaet. Lads dry jovab Ike waiver as b may or all Escrow Items at any doe by m mtioe shm is acom"m with Sailed 13 add. upon dad rtwamtim bofmwa " pay to Lemdrs aid Froadd, and In mwb smnsw tint are dwa, -gaited tinder dig 9091100 ]. Lender may. M sup timq collar and hold Fords In to Marta (a) nffieiam a pam@ Leda to apply dit Prods at to rims speMW wrier RESPA, and (b) not b macsd do mw duum moum a badw m rogmm wrier RMA. Lender aha11 esetuaa ilk amomr of Foaft bn 00 to bads of ewreat duo dad mnsashle ashmalad of arpaadimm of homm Escrow Umm w othawim in a00memm with Appliasble Law. The ftr4 shall be hod in an idstiodom whole deposks sa ismad by a federal spray. kdt®enWW. of am* (bcMft Lettdar.11lsnda Is n hadoaion whore:deposks an so Irimad) or to m% Peft Now Lam Sal L Laden *4 gply die Prods b pay dw Em mw boom no Leer non dw dorm tpeaded oiler RESPA. Ledar shill not cbwp Borrower for bd ft ad q*7ieg the Ponds. modally su being Ike Hasw aocardt, err tarltyltlg d1e bow low, udm Larder pays Benoww iaterrs- en db Fao& add AppPwble Law panim Leader to antra suck m Dodge. Ualmm an mgrsumm is mails to wrW1 of App[lasble Law mquir s iaae I- to be peg an to Pads. I,esAer doll m be tt 1, 4 sa pry Eontrwa sly iDWM OF UTMIW ON rite Pwds. Bwrower tad Laden CO agram 11 Wfidsj, boweva. mine hnerebt 1D939g) 4R."PA) maoa farm 3m 1181 (page 8 of 67) 0 9 i doll be peld oo din Panda. LAoder shall give to Bormwer, without therm, an armmal aauutia of due Pan& s required by RMPA. It dtcre is a surplus of Punch held is arrow, as dkhood wader RPSPA. Feeder shall aeoo= to Borrower for Ma seas finds Is soosrdaare whb RBSPA. If Own is a donne of Panda held k Borne. as doltmod mow RBSPA. Leader shall notify Bortower a ramrod by RESPA. and Borrower ,tell pry Do Lsadcr the amount accessary to saabr up the shorop in accordance with BOMA, but In so more dau 12 assnddy payments- If these to a deficiency of Ponds held in escrow, an defined uodar RSSPA. Lander dell sottly Borrower as required by RESPA, end Borrower dell pay m Water the: snots aeoaary le make up the deficiency In aeootdatroe with RESPA, but in so stare than 12 momt>tly payments. Upon payment In hall of all sums socrucd by Oda Sewrlty Imhumai. I nudes shall promptly NNW to Borrow any Ponds bald by leader. A. Cheers; Una. Borrowte d" pay all taxes, asaaameots, therps, fines. std fapoaitim attributable to ON Property uAdoh an amin priority over skis 8eiolly Imtrr®eoa, lodnmld psymmas or pound taw on des Psopeegr, if may, lad Community Aso"ca Dues, Pea, aid Asssamaes, if any. To de cheat that than fame an Ewow Items. Borrower sbaU pay them In dw tanner portded in section 3. Borrower shall promptly diadvap say Ism whf& bas priority over Ohs Jsearky 1huroment wins Borrower: (a) apace in writing 10 the payment of the oblipdon nacrred by the lien in a =MW Waptabk to Larder. but maly so long as Borrower is patoroft such apaemeat: (b) COMM On No in Poll NO by. or dkIwds spina adoreemeat of the lien in, No proceedinp whlc? in Les ler's ophdoe drperaue m pravaw de vo6, -, m of &a lien wldk dross proceadinp are pending bon only until oath proaaadiop are cmwkded: or (c) mow= ham the holder of due Bat an , sadsactory to Lasdcr sub wd ea ft do Sun No this Eeeority hamumau_ If leader dommines dot any part of the Propeny Is rnloel to a 1100 wbkh can male priority over this Security Instrument, Leader may give Borrower a notice idCodbing de ties. WNMR 10 days of the date on which dot notice Is Shea, Borrower due anddy tke ft or falter roe or sort of do wtions act forth akin,- in this Section 4. Larder my le"m Borrower to pay a one-time ebargt rat a real count tax verification aadlar nyortird service aced by Larder In a comadon with dris Lao. S. Prepaty hamrsaoa. Borrower ,ball keep deer Wwrovements now aw"inr of hereafter sneered as the Propeegr imsaed apkist ins fry fire, banrda hxladed within tke tdxm 'dameeded notate.' std nay -der bunch indo tag, bor sat I'mdimi to, carogeahes bed floods. fovwW& Leader r"drea insurance. Ibis frsrraaee abO be r0einained in the amounts (iackWhq deductible levele) mad for the panels that r eodx nrproa. What Leads FKWM pursuing to the psersding sraaroes M cum 4014 the tam of de Lore. The iewraFt carrier peoridimg the Imurua shun be nA 110 by Borrower iskjoct to Laoder't A& so disspp sun Borrower's elue?m, which ricks dealt not be exere'W mmessoMbly. Isnder MY require Borrower m pay, in contemns %* din Robe. eddror (s) a oYa41® slurp for NOW nee dwoolomtioa, aettaadon-and umUng swim: or (b) a mwdma chaps for Good aces ftle ainmtin and eeetibatlae sesvlors and subm" m chars, a&& Bme rewsppiap of similar damn sever wbidd reasonably might aft d such deassdnafm or oardfieatim Borrows stall also be sapmosible for the: Payment of my Ones imposed by din %ftrai B sup" Monopmsut Apaay In coneacdon with der review of say hood nee ddersimtiar teadthrg foss an objection by Borrower. 1005991 .rare Gk~A) were rep s r ee ??? Pen. 3000 1101 f. (Page 9 of 67) If Borrower falls to maimm sy of die Dove w dt m-W abort. Latdw mry obtain, Isoatan,K owvwsys, m Loaves option, and Harrower'. eaptvtre. Lmaa is tinder w obliptim b ppreI oar tu*39w qp or moount of tovo Therefore, web coverep ftN Dover Lender, ho 04M Or 11111131 not promo bomww. Dwrower s aplty In uti Property, OF Wt cmnrar of tito Psaptrty, apts. qq d016 bsm M or liability err nght pmvWe ywer or hnwr caves jn dm oar pr-owdy In effect. Borrower aebowhdps tint the raft of the imu moo coveraje w obtidmd mijltt sipdfAWY meted tit: and of iorn,raote that Bormwa coW hove obaloed. Aay mom S&uratd by Leader coder dda Swd n S dmV become adddm d debt of Bwnma seared by tide St=by ln,sanmt m. Theaa ansc mm duill hear iawm at thn tiara new hoe %** daft: d disbarment and shat) be psyabts. w(Ib such hUM. span, mike ham Lender to Borrower saquestiq, psymem. AD laerraaoa polices roomed by Lmdar and rmtawdo of oeeh polkiae shag be Old"m w Leader's rVA 0 dimggwvm nek polities, shah labda a erertd"d mortpje tlww, and d all o Larder es xm%o et mdfor n an, sddidood Ion payee. Lm dw shill hove the ft % to hold ate pdides and renewal otndiceses if Lauder regdtes, Bonawer AGN Pran,tpdy give m Lsoda ail rat44 of pall I era neewat wekw. It Benowa obuiar cry form of innrnme eoverelt. not dhmwiw mgnited by LONIM for damap to. or dwnuotwe, of. the Property, sour polity shill irclwdt a swmin d m xwv done era dad hams [.wader es tocog [pee mWor ore m additions) icon, payee. In tar event of low. ft am shall jive prompt rotke to the imormo a ardor sod [.ender. Lender may mils proof of law if cwt made psoaptly by Bonower. Unless Lender od Borroww Wmwia epee Is wd j, a q inemanee proceeds. vdwdter or not die w*rlyirt j inw ome ww ro tired by Under. 81011 be applied ill rerserafaa or repair of the Property. if the rwmration w rgnk 4 eooncooko y hadble era Leodec's warky fa n,a haaeaed. Dwl% wth repair ad mmmim period, leader slat[ bare the rf jLt a hold oath homme proaads tmtB Leader has had w oppormllty to krpm mob Property to aatme the wok has been carnplesed to Leader's ntisbe on, provided that nth Mspscdm shell be Ind nil= promptly. Looder may dMww proceeds fw the npabs and reerwatioo is a sin le payment or in a sndes of pstt jrslc paymmnu on the work is . Unless an, s jlemteet LL made in, wrkfrrt or Ap 1c" Law mge)rm bomm so be [pact 00 wth lolwanee protcods. Loader shill nor be ro pind b pay Bestow my interest or cramp m each pr0eeeda )bra for pdblie adjoamre, or other tiara pasties, reload by Dwmwa dill cwt be paid au of the irron e, proceeds and &aB be the join abliption of Bor owes. It dr tt smftn or np* is tic ommomkaily hwMte or Lm dm'i .carroty would be Nwwcd, the lmran,ee proceeds 1141 be applied lo We ham scared by tWs Scowky Ieshnmerd, wk4m or not &n due. with On momm. If sty, paid to Bonoww. Such imrmee proceeds ftll be apps led in the ender pevridad for in section 2. if ihxma aban,dons the hope". Loader may Nit, oejoltow end erttk cry araihnbfe ln,esran,ae ddm old nrJam I mom. If Summer done not tors; I widdo 30 days m a mace Isom Loader dku dm immarem owrier bw [1111 1 to eels • claim, dreg I A der pry mptbu end softie the ileum. Mm 3Ddny Pviod will bgOn pion, ffie soft is liven,. In dldw event. or if Lender ecoolm the Prapagr under Section, 22 w Am la. Bomwo hereby waijm lo [.coder (s) Boeropoes riom to say imtrwaw proosede h an mm m not to .honed the amomtta opeld under ilr Note or thk Seetrlty lomm a m. and (b) aty ether of Bomww'a sights (odor dean the rip to any mfbnd of umareed pnr sow pad by Borrowed miler all isnnn,ce policies t0vwfn,(t dw Ptopcz. itrofar w m h riou are eppbcdtle to the Dorenp of the Propwgr. Laadar cry we the bw mm pratxed i tuber to rapsk or crane On Property of lopay 1 1 -s sapid wav the Noe w this Scorky bwnrrem, wbedw w ea diem duo. 1005907 -list .. t""I" row 7.0 N RZF Rwn, 2= 101 (Page 10 of 67) 6. t)orspeoey. Borrower shall otaapy, emmish, aW lwe ibe PMporty m Borrower's principal modeem wldda 60 days titer des samotion of AM Sacwhy Imnua m old :ball cosh d to occW tba Property as Bmaowu's principal rddentce for at k ut one year of do date of oatspaM. nips Lod" odnare asters 10 *ritittl, or" cousin #AD not be wvc m * wMbdd, or u MW atensatial exist whir] are beyond Borrower's Control. 7. Peauvalids. Meal use ce dad 1Matactlen of the Prepartrt Itapectleas. Borrower " not dooncy, dea ap or igWr do Property, allow the Properq to detwianta or Commit wads on the ?eopery. WbOw or war Bonewer is miiq in do Property, Borrower stall maw dos Property is order 10 111er1 e1 ds Property from dewleratice or d[sxtsiel is vshte due to ba condition. Video; it Is dmenalaed purawn to Seaton 3 dna repair or raloratioa is not economically famW, Barrows shall primly npk dre Property if dam pd to avoid ttsrdnr detaioratbn or damap+e. V isauam or omdcrosdm prgxs I an paid is aoweaba with 6olate to. or the UMM of, the Property. km war oW be sespoasibk for sopdrisl or reatorks the Property only If Leader has mkuod psooae I fa o d PWPOm. Lender nay diabww prseeeds tar the repairs and ressoruioa u a A* pymm or 10 a amiss of prows payonla ter do work Is Co®pfaad. If the bameanm Of Cos k=MdM prooseds as rot sufficient m repair or raaogc &a Ptopaty, Borrower is trot mftvcd of Borrows': obiiptims for dw Completion of such repair of rastorstioon. Lander a Its U ft my snake rwsonaMe dudes apoa and ImppWom of ft Prapmq. It It bat reaaarble cause. Laden may bapm an inarim of the improvemwss on the Property. i Awl live Barowtr notion at the dos of or prior to am* an interior iaeMedon sp dtjft sutcb ressouaMe eon. L DWMWW'a Lev Apptlatln. Borrower shag be In default If. duugtl *a Law appikarimt I*oens. Borrower or aq persons or easiWs soul at der direction of Borrower or witb Bonower's Iowwmp or consent lave maseWly W", nisleadiws, or ittaearsts information or aaemaumi to Leader (or Mad to provide La dor wide alrsrhtl lubm adou) Is comudon wrh dw taco. MumW teprssnmlleue ?topde, but ass dot Boleti s0. repsamwdoru nonce ninl Borrower's ocapawey of the Picpaty Y Basuwws p ftod realdOM 9. PselsalMw of Lawler's Laerat to the Property sod Rb Ists tlwler No lawrfq imkmm*L If (a) Dossom fad a potrbrs the covenou and Wouseaw eo®10ed 10 this Swaarry Imutsmut. (b) lions is a low 41 do d& Sonny basemen (O K Ipimicuddlnl hen". p d ass, for Mmis metes a ta ? efor adornment of a No Sim Walt stale priority owe. this Security Immanent or ro edoroe IM or rgmimiaoa). or (o) Borrower Ins abandoasd do Pwpeeq. tlo s Under may do and pay for wbatever Is reasonslAc, or tmant, lac fAg - Inl ptwud/al ?ir ft value of do Property. and Prolog ad ilpas moire Audds r Secariq Laudie Property. Landers aedsna an kwbdo. !at an not linhod m: (peyigl say smns aocnto I by RValft a Has wbkb lass prtosky aver this Sam* ]rtseronrsnt: (b) appearkV In cent: and (e) psyirl sasesaNe msroeya' fora to protect its Gansu in the Propany audkw rilha awdor side Security Iswrrm asst. Inclvdia{ IN soared polities is a INIMIOM ay prooeeditt{. Serarinl the h" P"Y 10dades, 1031 6 mt liadad W ass4y On PrWuly to ore repairs. shaap looses, replan or board up doors aid windows. drat wart from pipes. alliamh lad" or odta code violation or dsalaoat madittmn, asd lave atilides patted os car off. AhO nO Leader rosy Oita aetba sdor Ws Sectkn 9. Lmtda does dot lave to do so sad is ant Miller asp d0ly or abhptfv lo do so. It is agreed dw Leader Items no liability for ad Wft aq or all actions wderind Model this Satin 9. 1O8i987 Baas: ?ARVAr Man nr.a.r re 6?/ Fern WIN 1101 (page 11 of 67) 0 • Any tattoasna db b ned by Leader mudor ON Station 9 shell bcoomr sddidwo dtbt of Borrower .toured by this Sworhy Imu mmem. Them sameness shall boas :owed w the Note rase fun On ease of didsrammt and shad be psysbie, with swh interest, upon notice from tender to Borrower mWeatng P Segrity hmormat is m a Isualwid. Ba mma Shell ooorpfy with edt die pmAsiow Of the teen. It Harrower aogaim fee We to due Property. the )enbnW tad the tee tide 00 NO mange uteu Leader agree to dM merger in writing. 10. 11, IS - lamona a. If leader required Monts lerrence as a condition of mdit the Loo, Boc.ma also pay do potato, mob" to Maitwin do Morgap ho mme in affect. it far any retests. ms Mon" laser mce eevaags to" by Leader tens to be avathble trot dre orortpga lmttmnr ? pmviowly plod" much Ismnsmm and Honors vent rapdad to male tepa early deall-W Paymea toward the pstham far MorWp Ingrance, ionowet shall pay the premiums 1ega4ed a tbtd® cwcnW wbpasiaoy egsivdm m tbt Norgsgo lnmoruse pmvimly in dibet, at a stn snbu=UIY "aivalam to do non to Borrower of the moot ge Ionnung previously In dbct. Oam sa? gam t morrttgs burster selected by LaMar. V a*st *Wiy O"valset Mortopa breorsmee eororap is eat available. Borrower doll cmisae to psy m Laada tit: smo m of the upaavJy ddpow pgrm slut wore doe trhea rte Imaortmto c vera{e ceased to be in effect. Lauder wM swept. aaa sud nits mw psymem a as a oow"f adsble lose room In liar of Mon" Insurance. Sub lose teurve *AN be aw,ve ord", no"Whemding do feet that the Lms is ultimudy paid is fell. sad Laden MIND not be requited so pay Borrower any adsnrjt or c mings on stab foss snore. La der cell so lsepr esquire loss reserve paysaeb If Mortgage lmarmwaee toveeap (in the women and for the period Thor Dater ngdre) provided by as Iaeoeer selsmad by l.adar again btoondts available, is obtalmd, end Lander tegmlre sepaately du4nmed paymmds toward the prat I B for Mortpp Isnnnce. If Leda[ requited Mmtpgn Lewrormm u a wmHon of mslday tae ton mod Borrower was raldmad m mtebe upwateLy enip.ted paytoenas lowasd the pre A fa Mortpge umarance, Btresnwt shellpsy tls pdemitm tog , te malstdH MorgW lamas in ndlna. of to provide a man-refabbfe Lou reeve, matt 1. NWA mqAmmm for ? P?ehg ? ietninmka or math mmaI tI I xtpdtad by Applkahle Nothise ie d& Section 10 sdho Borrower's oblipdon on pay Insam a the ante pttrrided is the Nate Motdpp lasmrane0 reitaborm Leader (or my ady dot putelumas the Nee) fbr cesub low It may low It Dooms dose ant mpay the Lou s asrum Borrower is mot s party do fee MONISW hsasanas. Mottgttgt dorm enlmae dldr tete) risk to all sech bmw"m in forte from time to time. turd try assertions tugremoma with other parties then shm or sadify their risk, ar redaw hrnp. Those opesatants rte on amt red oo Wdm dot are astalkmo y to die mmWv inmate ad the arm party (ter pnrtlne) a time ngtemars. These agre®tMS sspr M*6 this frorgaga bwmtr to ado pgmass sing ley smmt of Oasts tint dm sorlpo ku mnr may bane svdisbla (whicb may imdwo ka t dtaimel from bdmdpp Immormove ptnmiss) As s u of d of die Now, another Insurer. Only rekdmem. As emupe Lander say ptneloser my Other eat". or any aAOf 8 r or the. hggpbq, rosy twelve (dlroaly or bdhv*) momma that derfvs from (or aught be davesurined aa) a portion of Borrower's Payments fee kfartge lasaramr I in exdnmdp far dstlag or modifying the tswta 8 mauWa risk. OT tedtr I )Dow Lf such Woos" pt van Was rem affBime of Lades tales a sham of the immes risk is cAcbmW ter a >dest: M the pmub ms paid to do iamm. the smopmant is areas m mM *c** a reianars- * Pwdsr. (a) A" sMti gnemmis wE mat mikes fee amommb tat Bermwer Ise mWeed U tray fen ? aroma Bwmww vM we jW umlpgs L epesla a, end they w® net mode for mnr u may nWL 1005987 wrrru f we"PA1mrsw asp e.r rte ??? ram ]03a rAr • (page 12 of 67) 0 • • (b) Amp autb aps®mta will not affect de dda borrower hn . If any - vMb rvaput to the MwtPP Ynraon -dw Im Hesirwrres Proloctiw Ad of 1908 r tW other 4w. Theam v1pu mq beeMs the ftk to rwodve nmrtds dedwarwr to raw-A and obtain c a nhilw of dw MasWV INOMMa. to be" the Mertgagp lamranm bradme M astsmadow. ar8to to scalna a reload d nap Merwat Insurance Premiums that -cm ¦ Mw"d at the than at marl, effiNd ter at trslaatloo. 11. And of 1Mlsed4maaw Prscmdep Pbrfdhim A11 Misodlemmus Proeeeds are hmsby aaipred a drill be paid to lands. If do Property It damaged. ash Mismilaneous Preeeeds :hall he sPpW to rucention or repair of 110 Property, If the mmmados of repair Is emmoamiemlly losable and LswWs =cux y b act lowers ti. baring tads rep* dd renorWoo period. leader ship have tln Tight to bold wob Mbcellucon Prase I uwB Laden har Ind as oppsriwity 10 IMP= well PMrM to easo - the work has been cwt dal to i elder's "d6faa(on4 Provided dial sale IllsI toe " he rrd wWm promptly. Under mess pay for the rePdn and uatondim in a dVe didwaemem or in a sales of pro$= payments as the work is ooaylaad. Ualm w agresmsat It mda In wrWua or Applicable tau rpslres irlaow to be paid on ate) Miaurnaaeova Pmoeede. Leader *sU not be roquirod lo pry Borrower am irtaac of emaisp on nch MiaoNfaemua Pracaeda. If the tseroution or raplr u m acoaomhatly >Easibk a l easier's saeetity w=W be lenoW. the Miscolligipoiss Pfoocedt alrdl bo applied to d w ergs sacdred by this SaeurYy Iaaaamcat, whnlhr OF nm then tole, with 9e ecooess.-H atty. paid to Bowater. Such blisodlaneon PrOCUM sMB be app8ed in do ardw provided for is Section L In do rvem of a MW tdit. daandon, or loss In value of the Proper, dare M udbnwu Proceeds dial) be applied m the same mound by aids Security lastrumem(, whWw or no than des, with sire easma, if NOV. PW to borrower. In We event of a padd dYdag, destruedoq or loan in value of die Propelpr In whkh dw fair aarbe vase of OW Property WAMdbWy before da MM ukfag, dcomcdoiL or loo is valet: is opW to or paler than. tiao omoost of 60 wan sawed by side Saealty Iuservo m immedidely betas the partiid ukb*. dweetioo. or ions is valac, vision borrower and Leader sbawiae agra in wnuag. tiro arms aaapad by this Sawrby htaaamnat *0 be rdoesd by On amount of do Misedham Procaedc unltiplied by sire fdlowWB ftaedmt: (a) ds soul wows of the wma wwW (mnodlmcly belong die PON LMn$. destruction. or Ices is valsa divided by (b) do fair taaka value of rM hopes ty immediw* ode the partial taking, desaaetion. or loss in "lm. Any babmoe" be paid to Boftowes. Is On event of a prod sddng, d@Knxd n, or harm in vahie of me Propa(y in wbidi ft fair rrdmt value of the Property Mertedi "y before tine partial a". deanucdoa, or loss is value If less than the tstatat of rke nos moaned htmtmdiatdy bdot die partial W*, dauu* 1, or loan in voles. idea Honoartr and land- adwwim tpoe in writing, d w Misoellsown Proceeds sha0 W applied to the cams ascend y sh?in .?r?rhy InOMMm wMelltet OF ant the inn am then doe. If de Pmpaty It dando ed by Borrower, or H, An notise by Lash to Dancer &u do OPP IRS Pasty (a *&W W dse test smowAO din w make w award to mode a claim for dasurk Dosowrr fats In ttslpad 10 Loader within 30 days after da dam the notice is than, Lesdet Is tatI I I to oeUea and apply Mro Miooellmraua !rowed elder to mmadco or repair of tiro hopmsly or (o rho wan sotatosd by? MIS 5 WA ft lute(0mea. whetoer or not Om doe. 'Oppoaiag Pity' scrams toe siwd patty dtm owes Bolcom MiaoWnnoas Proceeds or did: party mgdast wbom borrower baa a ri& of necion in rwm a Mfaodlssr0w Prooads. Balwaar doll be is dab ob if any talon or proceeding, whaltor civU or abaind. Is b%w *K in Landor's jndpeeat. *odd result in forhbwe or the Property a odw noww jopaitatam or 1.113ars 10014110 in 60 Propmy or deft miler thb Seorky Idaaamed. Borrower can are web a ddavlt and. H aoedaarim hu ooaorrod, rolown as pmvidrd is SoWw 19. by missing The action or proceeding to be 1006987 (q-APA1 maea r+? ?1 car. nr rs fmwr. iota 1101 (Paste 13 of 67) dbmbsed witb a ru iwp that. In Lender's judgmen, Was fortetmrs of the P.Opmty or mbar OK"W impaitmat of LwAW* inugm in Ow Prapwty a t has under olds Smorky I stromeat. 17he proooadt of ripe ewsrd or claim for damps clot are saribetable to thq imptirnnM of Leader's {Merest In the Property are bars" anipa and, emu be pow 0 Laden. All 1llaodlessea Rarwede test in no applied to restoration or rgWr of the Praimly AMU be applied In tore order provided For in Section Z. 12. Barrewar )Mat Raiaaadl Forbearance By Leader Net a Wahmr. Hatunde f of the time for payment or modifkaka of moadsaaiw a tine u ms umaed by ells s cudty lmtn mm jp- w by Laden to Borrower or my SuaoeaMr is latest of Borrower then am operate to rebus the 1bb ft of Borrower or any See mum In bsawat of Borrower. Calder shall am be t-gnh-A to commum pooomdirpr apiap my Succomor is Imam of Boeower or to refwe to mend time tae ptymest of etthtarris SO" ssortisadon of tltt: wens sopxW by tole Smcudq Imumam by resw of any demand made by the orWW Borrower or ay sucomms in hdaw of Borrower. Any fotbswce by Leader is eseaehetg Lay at remedy ioctedins, [without liodufion, Leader's soccim itap of psymme u bvea third pences. catilles or Successors in )merest of Borrow or in smomrs leas ehw Ow amaeme clue der,,hall rot be a+einr of at preclude ohm emcke of aq r{ght amt remedy. 13. Joint and Smral LlsbihMyt Corsi pang Swomors und Auden Bound. Barrows 0areanaa and agrms the Boervwar's abliptions mad O "by " be joint ad sword. However, may Borrow who a0440 able Smoky lntttaseol ben ties not Crenate the Noe (I "catigstv7: W b co-tlpttift this SeeuMry btarmoest only to martppe, pest and amwmy the w4tm es Won In Be Propeay aer the terms of cola Socarily Iwtnomt: (b) h ON peraoedly oblipaw w past an was vacu ad by this Security bw met; aced (c) agrees that loader and may other Borrow m a=rea to extend, modify. forbear or mebo any aceammmlaims wbb rcgrd to she tame of thh Seem" Im mmot or the Now without the co sip er'm coma[. ssbjeet w at PM46oa of Ution is. ay Sacearor in hdcrost of Batanwer who tnswat Bvnwm & obligtioa miler Cods Smoky Instrument is wriprnp, ad b appawaad I alder. AM oblair all of Borrower's tigbu sad baeAu under Orb Smoky Inuumem. Brrrowt uteri sot be tolass I ham Borrower's oblipaiaes aid 1WOky aader Ihb !easily bestromeM aeless Leader specs to mint tdars is writing. The cu exe q and spcaesnrats of this Security lutnemem " bind (except se provided is semen 20) and bandit tee slI omeorm and stigma of leader. 11. Lean CLrpse. Lade any charge Bonoww fees for services performed k comedies with Botrewa's WON. for one purpose of ptaacaft (order's immat In the Property ad fWA Under this Sec" law amwo, iockAs 1, but not limited to. stsoreeysI toes, propetp brpembs and YabYfion ha. Is regard 0 any Other fors. the mbesss at eoeI - - aadwity Is rah Seats IW loruvou l to aha'p a spoeMs fm av Barvow *A not be cmatmed a ¦ prahibiden as the charging of nice fee. Leader may not chaps left Chat we a pudy probibbed by ilia Security Inosmmt or by Apolubk Low. If do Low b a ftea s a bw which sm ms loon lam ehngs. and that low Is finally interposed so tiro the ieteaess or other loan dbrSm collected or to be collsomd In connection wWdee Lea seamed the penekod UnW, flex (a) say ode loan dotpe don be reduced by Iht i moms nlai0ery to reduce too CWP soothe pis duW lirir and (b) story mama draft collected Prom Borrower welch aWWW pwmitbd )kndts wN be riles I ten DMMm. Leaden 1My cbooae b anlae ilia alhtd by tadamI tee palodr owed ender the Nam or by tamping s direct paytaem b Borrow. lr s rdwd milves pf M*d, ON redaedor will be tested a a prtbf V. -.-m--- withmt my prepaysewt charge (whaher or not a pwptpemaM charge is pvo+dded for tinder tine Nos). Borrower's saxplmce of pry meh Wand made by diem psymms w Donvm wg coseteos a we*" of say tilt of action Borrower d* bees sisigp ON of amb emewpa 15. NeMloes. AN rake givca by Dwmwcr or Leader in connection with tldt Sww* InsbumMt am be Is wtift Any notice to Boraowet In eamt W m with this Smoky hammier sWO lee donned to 10959!7 ww• f "IFA) eta .... n a v p? Jana pas! tat (Page 16 of 67) • r • 0 have bm jives to Bawer when ntdW by Ilm dw mull or whom actually delivered to Bormwoes moths address if sent by other now. Notice to any arse borrower doll mmdmxa notice to ad Sorm- Bales AppUmbte law mryeady ngalres otborwin. The motive address Pull be the Property Address odes Boom- has dmdjnmd ¦ sit kow nodes Weiss by moots to tauter. 8orrmw AW promptly notify lerdar of Bottom Is ch&W of address. If Lender tpedlin a proeediare for reporting Borrower's chmp of address. den borrows dull oady tepat a d& W of address throagl disc spadBW procedure. Mme may be ally an daipmd notice address sneer this Security Intrusions at may ome time. Any mmdco to Lender " be given by delivering is or by awV% it *by first doss will to I mdsaaa addcaW swe6 beam soles laden has dtsijemed another addrm by amine to Barmwer. Amy notice In eommreedon with No iecority bavmnart shag not be dosmcd m bm been given m Larder =99 adally rocaived by Leader- It any notice ngmhred by Qk Seautry Warmest Is oho rmgorad radar Low. the Applicable Law ngohmm will as" the cotrvspotWaj requirement under this bonwim. 16. Governing Lawl gnerabilky; Arts of Ccotrurtiom. This Security Immovan u shall be governed by neutral hw and the low of to Wsdktlm Is which the Property Is locaaad. AN riglu sad momea'vud Is dds Seemly Istramo m an object to any rmaireme ms mom! dim WIM of J kA Applicable Lw WSM or Imo kitly Nlaw io paNm to alto. omtrset car 11 majht be ddlat, but marl dines shall mote used a s psldbirion srmieu apetaem by oatsaes. In On event tlmt any provision of dauo of tithe Security IrtNrmssat or die Note conflict with Applicable LAw, such o"IK mail rot affect con provisions of tut Severity Irmmmea or do Now which ceu be gi.ea efface wbkm the aasNothe provision. As mW in dhh Security lmaewmmt: (a) wads of the mosalhte gender shut use mad Include conrapaling neuter words or words of the fmirdw gan4r, (b) work In** singular shall mean ad lecher the plord add vice vase; and (e) the word 'may' gives sale dkcredcm wiftol; may oblip tioo to mlce arty maim 17. Bm wmem Copy. Borrower shall be jives m co" of Pte Now tad of Ms Socaft IrA mhent. fig. Wencher of On Lhsrpnty or a Daklml Imterst in bano+wer. As mod in this Smmioa IN. 'lawast in to, &m beeshM imeasetc ttao wed is boa commet for dead. iinstalment Woo camtract or mcmar agreement. rte Imam of wMch is the trnda of tide by Borrom m a atmrc date to a pmd mmvr. 1f ail a say past of clot lropeery oe nay Irtlere>m h me hoperty is sold or iseriersed (or if boerowv k not a nmaal mm ad a bemXkid imam in Aonvwa is sod os aamforrod) without Isdoes pdor wrlam caeaak Lades try require h>modlme payment in fell of all stmt seaaad by this Sevarky Inmummm. However, this option shell not be eaaehsmd by Larder if mch ammcime k lmobibiamd by ARMkev If Lander assides dds opdom, Lander clad give Borroww notice of sooekntion. The motion mbag provide a period of ma ben cbwm 70 days I mm tlu does sir mocha is hives to aooorduce with Section 15 within whleh Msower motes pay all acme su+red by this lkaeity tamnuat m. If BommW We b pry demos, sums prior to doe expired= of dhh period. Leader mossy invoke ary mot" petmlavd by risk Sm rky lostromo m without Nndeer notice or desttmad an Barrows. 1!. Noasswa's Right is Adum After Aadersdon. If Dom ma maser aestdn coaUtims, Bonowot SW have the right so Inca enfotcesem of tuts Ammo ty laanumeld Amomti med at nny time prior ca do m ism of: (a) five drays before sak of the Property ionum to ail power of ode voemimed in this Suavity baamesmml (b) rmeh other period a Appllcebk Law mire rpedfy Nor die mmiadm of Borrowees tills m relostaW. or (e) aft of a judg arm a ftdmg Of Smority ldatrtsuml. Tbm coodkiosr me dud Bmwww.. (a) pays Leader Weems which Om would be dote tinder No Sams* lm mom red We Nee a It no accderati= had oemrrcd; (b) cures ary defooi of may ash r covenants car 1005981 rr.h¦ at-"MI sees r.r a r» roue 3m 11M (Page 15 of 67) agi-maras; (a)"afl aga,srx israrrad is eniorc6tg unit Searfry hero manor, inclaft, but not Ranked to. ressomde aammeya' face. Iaspeution and vshudm het. and odw tams !earned for me purpose of psote dog Laadar's in the Property and rights under "Securky Instrument: and (d) What such action as LwAW mq Isatmably r"dm to assure dry Leader's fataaet In the Pra!pett) and Film under this Somily Laausmeo[, and Borrower's obi(godon to pay do am secured by rims Security boamer . ek9 ceedma uusuharupd. Lender may nVi a (bat Borrower pry each mkhwhaoemt rams and CXPONO k ore or more of the 10116wift form. MA selected by Leader: (a) tavlt: (b) m0aey Order.. (c) 1, 'A,d cheek, bade duck, troaaarar t check m a bier's check, provided any sad cheek Is drawn ups an institadom whom deposilt are bummed by ¦ h dwW yeoey. bonn!>mdty or eo(kr: or (d) Rkemook hinds Ttamtk. Upon nkusemeou by Borrower, this Security 1wummat and oWpt m secured bereby that smrak tally affaetive a If so amderatim had occurred. However. thin right to romstate sW1 cot apply In the ate of scalaadou under Smion IL 20. Salo of Nolan Chmp of Leas Serviced Nodes of Gdarmm The Note or a pefft it mw to the NOW bapdma widr dais Secorrmy lnsuarmead can be sdd ore or note than Without prior raft a Borrower. A Wen might rent in a rhasge i0 me cothy (dtmwa at the 'Loan Savkcr') 1611 ttoiWs Peaiadic Paymants We wrier the Note ad this Security Wstmmem and pcdbm Other mor" loan M'dckug aWipdm wader des Note. this Security Immanent, and Apphe" Lw. Thee go WW be use or aeons Amen of the Lam Saww' m vmdmd to a We of the Note. If there Is a cbmgs of tits Laos Servicer, Burnam wm be puce writes motion of Wt asap whla wll mate ow macs ad sddrm of the new Lam Serriaer. me address to Maim payments d=W be made and say odmr kdbtmadm RESPA regoiros In oomection,&ida a notice of a - h of serviche. If the Note is sold ad thalaaflilr the Len is asrleed by a Loam Swvioet outer am the purcbaaQ of drc Nate. de mortgage Irmo sesviehg oftsdom to Burrower wilt mmala w M the Low Savkw or be w oodaned to a account Lana Sersiov and are act w®Mi+ rid Ronewer LeMor rams commem, Join, or be joined to my jodkim) action (as either an Wlvidaal lingua or dams menbar of a curs) that arises Fran the other party's action poraunnt iD 08 Socu ity Instrument or that hugs diet do other pang has branched suer provision cf. or any duty owed by reason of, this Secuaiy Immurement, wtl wrh Bormwer of Leader has aat(fied tk other party (Wids tars notice gives is oampif aux with the rogaireaer . of Section IS) of mach alleged b meb std dferied the OdW pry I I r a mumaUc pa(od WWr (her gift of such mmkc to take cm.o tiwe ad= U Appliuahk Low prow ida a dome period which cwt elapse Isiaee curtain madam cam be tal s. Ikt time period will be deemd lD be rwmobk for pWpaa of Vds praagrapd The notice of aoodmadon and 0/pW"IW t0 are given to Borrower paranaot ro Seeden 22 orb the monies of moderodon !Ivan to Borrower puusrat . to Seadon 10 abal be dtamW to satisfy the cerium and opporaWW to tale coned e action im, Isic of nit Section 20. 22. ltosraloso Srbatmom. At used In this Secdom 21: (a) 'Haatdom Substanm' acs most nebetampa dW d Y tone or baaaNoa sobstomaaa, pedaaama, at womas by Soviroommesl Law and dw foilowl% mktmecos: Polka. kamam, can Omsasbie or manic Poin"m pradow, made peatim" cad h- I W'se. vote le solvam ra mmids containing ubwm at b raddalyde, sd radioactive mmriab: (W 'Rovltaawrtd Law' umm kind lawn and lawn of tk jurisdiction tshere the Prepmiy is bled that Most to bftft of" at anVYarlmelta) protection, (c) 'Snwbaamental CMmmp• fact"ra any seapooae estiaa, rsraa 9 ' action, or removal nation, as ddbmd in Seviromoomd law-, Ord (d) as 'Favirommmi Coaditim' scorn a condition that oa own. eonaibwe to, or othNwin mWet as 8svinesome) 1005997 w+,r: ®•WMIM"m ns. +awa I Form am J)" ?1 r , (Page 16 of 67) • 0 0 Hanover dull ad cane or permit to pradseheeI meet. d4osai. aerye a mlw of smy llrdom SaAdmea, or draatmt to memo my Haardm Subamea, on or io the Proroppeerlrtyy Hatovtt dial) to do, mot allow dome aloe a do. amytdrh8 the Prapeiq (a) no it to violatoa of wry Brnirammral Law, (b) vbrOi traoled m Emviromam=lien, or (e) wMcb. doe to the prereM&I-Omw n,roe. or ralaa aoiff a com Haan! Shrbs SWy 10 11m: d th a m M' or ad+rerady mdfo r hem ? P?top?ae(rll go oedt' 07 &oij Humdow Smbrtaiom dirt ut rd napped m be dpprapristm to moimaors ad to mniormsmes of der Prgeny (iaetodiaS. but rat limimd w mwdom mumem is oavamet produeo)• em m AW pan" on Colluder W. notice of (d) my dale, denmd, Wwdak or otba swm by am Tom mental of reYtdatory agar err ming: the am/ toy Hatardam Sttbtoooe ithmaral far of wbhr? of n"vU hu sad imowrb , (b) my PANrmmeanld Condition. inch aimS bh t at HurAld lo, mod' so iod. lentos. dischup. rdmte or direst at td. of my )taradwa Sabatssee, and (c) any ooadimoth -coed O A- preside - or votme of a Property. 16;;-m.lodras. a IS mtiw Hamdaua SnbsMaoe Mddh mdvsady at& the value Of the if br nq of mmatalie 1 err amthmiq. err arq pdvahe pasty, dw my amoral or ? of aawwyy Amrdom f +eoa a?ihp tf?e Phopsrty is neeaaaa y. taarmww W" ?ro?tl? 1.mkr fad?tmdnd6Maoaadddia?rradlA°dQe. Lew. Notb q basis dAatl comma a" ow kwon on 2L A t Rummilm I.mdermien give Lamiler notice Dar ?e t p ? dw and agm as follow Hmmewo'a brmcb of wq osrsnsnt or aeraeeat in 06 Saarity at euumuw Amt mot pdw is meedaadm order Section 18 inks Appbmbk law p vvMm stharbe). L ndtr dwl anal Doerr wr at, snood alAer IhimSt (a IM nebula; (b) the action repined to con the ddnakt id roam the dwm a mmt be UK* and M that hbwe to awe aw ddsmil m may rtrnk In soo . - 9 of the mm tdmamad by Ibbt SKW* kdrtmsma. brmdswe by amid prmeadist mad aM of tie Pt%wV. [wader shell hetha ink m farm wr of *A rl#t is naiad, sir meaiwmdm and thedW M semi in flue foradadmte procaedfae tM non-ehdalaw of a deddt or any other dtdeaes of awnwsr to aeodamil m and torsdowve if the ddmk Is ad Bred a apsemad, Lmdor of iM OPIM -9 m4WM MMO Mp p yawal In fall of all am monad by fife Sstortity Ieetrsmo wifhml fwdw dttamd mid EW firs A dds Seport bmarrmmt by indidni ml. Iwmder y IedMbB NOW da: 11111111011 to, MIN eey ei ' t? d d-moot of ups evidence to she a? pa? b22. ? A Loco. 73.1Rdw- Upon payment of all alma taoamd by this Sdwrlty InWomam. cod Sawlty imsteaman bad do auto cm- -myad LW mumbo u and Ie - void. After amok omrmmoe. Leader *AD disdw8e and md* d* Security Borrow dog pay rqr recombdom coats. leader may dwW Bthreora a fee for 1- 1 this %m irky ieomimam, bid only 1f dm he it pmid to a ddrd "for mvka remdend rod the dhar81 of die [a b pftwiitW coda ApokableLa«. defeoa pWnl otaadiapd amfcraem dds Send ddmrnaasdt Applicable bmraby wWm the hem dk uW.I -emw - aat i Imm prpdt Amy at ammdov, maaarlon of time. eam gdon Lrom moubnant, kvy and mle, and 2S. Bdmadaaed Pwled. BortvwWs time to m mole pwAded in 3amlom i9 daH woo to trod ID do oaeasaoamroa Of bidding at a alrriff'd &do err other ode pmnnun o dds Smsiry toomawL M Pwdn Mang MwtPpe. If any of the debt deauN this Sma* Imemtmeaa b" IM a Boamwer to aclaim tick m tie Praprrty, dds Seomrky imdtrm em"ben a p x Ame asammy swVW. 11. 0atasd hale After ].dprmL Bmower agmm did ft amm talc pmyable sfrtr a jod/ooert is amaad m do Nom or in as acts m of morlppe fooclaaa doll be do no puydbie from mom to dma tmdw dr NOW. 1005987 rut 014tOA) ntam r,p is r u /?? tome awn 7101 (page 11 of 67) BY STONING BEAM. Bw wwa s M*a mod wees b the terms med coaeoma wea w hl this Seawity bwMnCnt aid iw st 0 Wf OWW" by BarTMV VA r- I I vA* K. Wk..: L ? 0 GIOND Nataseho Thomas 4k"mw _ (SW) -bwmww _ (3041) -(Son _ (Sean -meno.w 1005987 00"PAInsw M ??r,a Twni 3M IMI 4hwR"w Ts0.T) apes Thoees (Page 18 of 67) • COWONWIALTS OF FEMSnVAMA, (,U+Jn4 4 Oa ", the ' 1 dry of August. 2006 undetaijsrdafim.paaatwllyappowW Nataseha Thomas i Conaty w: , before me, the known to M (ar y PAN to be the pessao(s) whom ausae(s) Wort wrbacdhed to do wMa hsuHm?rnt and b*W deal bddwAbcy cwoA d the sale for the pwpoaa berets oontsbwd. IN w)TNM WRMtBOp, l beteonts sat my bud of trial seal. My COOMWN Papist: OoasewsmNlr d pwww lwiy OusrtA t?ok?i 0. welrr wets _ Yu? ?? ?G Dltta Oe4os 9sra. t*,wat. psi' Tut ortNttaa sty eaaanrslpt 4eaa ose. ?. leas CartlOeW eE A ? . do hereby m?ily tAat me oorreet address of d+a kwithis mined, Mert08Eee is 11.0. Bos =. Ilia. M14Ml-M2& Vlrimeu my bard this 4th day of A V:?7 Alas d1(al/ya 2005987 ft"PAIMM ftp 10 r n , 4z-1- Ymo i0sa llal (Page 19 of 67) 8 r In Witness Whereof, the aid party ofths fast past bet ha ctu to set his hand and seal the day and year first above written. SIPA WA Dd Nwed In to Aaonoe of ?l (om? *Fa . Peters CERTIFICATE OF RESIDENCE I hereby ccrdfy, that the precise - of the G antee herein is as follows: 333 Roxbury Road NewvWe, ?A 17241 FIDFUN CMNG SIMCM, LIC 3d l K Sawa nun w. Wn20 ,..n W lem M 1No COMMOMMALTH OF P$NNSYLVANIA ) ss: COUNTY OF Cu-kWW on this, the day of , 2006, before me, a Notary Public, the undersigned ofow peesoaally WAYNR F. PETERS, Imown to me (or Budd Amily proven) to' e the peeaon whose swne is subscribed to the within kwwwnent, and acknowledge that he executed the for the pugxm therein contained IN WTrNESS WHEREOF, I set my hand and of dal seal AewinaaSaUSfMrMharie Alo(ery Tublic NwMwaiii L tbmAOaSaeIL gan)Fdm fl,EweM thaw nee A aaow (page 20 of 67) Vq SCHEDULE "A" LEGAL DESCRIPTION ALL the funding described real state I*V and being Nhmb in lower koft Towtihlp, Cumbeedind County. "Film Y1vVnKsioo Plan for LoI Nm. C more perticubdy described i? ammomn00 with Subdivision Plan Wiled Edgar S1tW. prepense by Enc L. Oftnbeugh. Professional Land Sur ism, wtddh said 8ubdvisbra< Plan has bean apprmved by the appropriew municipal atrlhomes and is recorded in Cumberland Counly Pin Book T8, Pop 145, as fallow BEGINNING at a M railroad spike in pubic road SR-M? (Roxbury Road) at comm of the when dsscrtbad Prat and parrot 8 an the show referred to SubdiAmica Plan; thence None Roxbwy Rood, Non1Ah 49 depress 51 Minion 40 seconds Eset. 30.00 feat to a point, In ine of lend now or formerly of Wayne F. Peters, which lands ft wain demcltbed pwcW is being added to as s lot addition; thence Ww9 Peters lends. South 40 degrees 20 rriMr6ro 14 sece0ds East, 248.10 feet be eN iron pin, in fine of Mr.& now or forrawly of ENnrood R. and David W. GuW . t io nce Wong lie of Isrbs of Gu", South 31 depress 22 minutes 53 seconds WaK 50.13 feel to a set iron pin at Comer of parcel 9, thence stomp ka of parcel B. North 48 degrees 20 mfttes 14 seconds West, 282.59 fen to the MI rallrmad spite et point and place of BEGINNING. CONTAINING 0.2914 am , In secondome with the above referred to Subdivsion Plan. BEING Parcel No, 1515-0411.Olt BEING the woe prondssm wMch Edgar L Stum and Lois A. 90n, husband and wife, by deed dated December 31.2001 and receded Janwry 11. 2002 in Ctanbwtsnd Caxhty in Deed Back 249. Ps" 4845, granted and conveyed unto Wayne F. Paten. a single pennon. LINGER AND SUBJECT to baNiding mat bads lkwC dedcaued right of way ilea end omen notations and o, dilm s ms shown on the above refe, to Subdivision Plan. p kR0M ept.PFDMAr1Q5-0040hHSJ (Page 57 of 57) 6VUSTABLE RATE NOTE i mm 10OX01001063a1717 (LIBOR lad" . Rau Cops) THIS NOTECON AINSPROVISIONSALLOWINGFORCHANGESINMYiNTUMTRATEAND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN CHANCE AT ANY ONE TIME AND THE MAXIMUM AND MINNUM RATE 1 MUST PAY. Aspens 4. 2006 Newvme PA (osao) Lary) (buts) 332 Roxbury Rooad, Newdlls, PA 17241 (Mpag P4. , ) 1. eORROWBWS PROMISE TO PAY 1¦ roars fora Im"I have mwived, I promise to pry U.S. S 10000.00 (dw wwont iscalled 1princW), on imere t, lo alb ostler of the Leader. The Lender is E4ttil9W Carpersdm . I will MAC All payneats usda this Not in the form of cask chock or mosey order. I understand dun the I order may basfr this Nora. The Leader or anyone who askew this Note by transfer mad who is entided to maive paynteob tuoder this Nm is called t6e'Noto Hakim." L INTEREST Interest will be clmpd oa acpaid principal until rho full auwuot of principal has been paid. l will pry iat~ at a yearly rate of 0.700 %. The iotetett rate 1 will pay may Chen in lcoonduaea with (,coders 4 of the Note. The bmc cu rat required by Ihi Seem 2 and Section 4 of thu Naa is the tab I will Pay both bcforo and SIVO any de6ult duanbed in Sectian T(B) of this Note. 3. PAYMENTS (A) Tb'e sod Place of Payments t w)S Pry psiaeipai and Woat by makiat a paymwa awry atonth. 1 wA male ay aoalhly paymm on the tat by of" month begs nitt0 an Septaabar 1. 30% I w71 mdse dwn poymans awrymoni umd ( have pad all of the ptbcW aed immat sod other charges daa%ed below the I any awe under Ws Note. Each maulaly paysecm Will be applied as of its scheduled due dais and will be applied so inbrat before y?Ipd. if as Ampm t, 2036 1 stillov o mmo al s order Ibis will Note. I ?l ?Woa aamooman pinayfnaD no athm date which Is called the "Mshuity Uaa' EgaiP4st 1y ,!Od ell icon Point CLrek , Chuiotte NC 20273 or at a dill rag place if"imd by the Note Holder. (B) Amamat of My lulus/ MoMW Payraoab Each of my iaidd awAMY paymem will be is the atttatot of U.S. S TS4.79 . Tbis aaoaot may ohaoye (C) Wathly Payment Cbages chow in my nosily ysyaeat will rouse, in the unpaid prleclpd ofmy loan and in 90 WOW ate that f mat pay. The Not Holder wM daermine my now macrost rate and the chmped amount of my moaddy payment errs accordance wM Section 4 of this Note. M 11 Adauble Rao N61e4Jbor lados EFOISH (2100) (Paaasylvania Vasion) Lora Number 1005907 Page 1 of4 Initiak (Page 58 of 67) 4, VrrEREST RATE AND MCOLY PAYMENT CHANCES (A) Ciao Data e fotetett wee I will pay may ehmp an Augod 1, 2141. and on, that day every Sixth mamlh 16etalla. Each data on, which oy interest me could change is called a 'Change Dam' (B) The bin Beginning ?Ih the fast Change Date, my imeresl rate will be based m an ladee. The-"index" Is the avenge of iuebw* offFC rata for sbo-momb U.S. dollar-denomixWed dcpo" is the London manner ("UBOR•)) a pAKsbod is The Mill Sdase JQ-WL The most rococo Index figure avaiable m of the fxubut bon day of do mono immediately peee ft doe momdt in v&M the CM4.0 Date occurs is abed the " Omtteat M?an% if t a Index is NO lmaa aw8abte, ON NOW Holder will rinse a new index &m is bred upon c®Pmable k0mation. The Note Holder will give me notice of this choim (C) Calculation of Changes Before and Charge Dam, the Note Holder will calculate my new intomt no by adding 5790 porecom e Pools ( 3.790 %) b the LWMA tadex. The Nos Holder will then round the rook oft h addition eo the moron 0100-61IA r of one parentage point (0.123%). S*tct to do kenkt elated io Section 4(D) below, this wended escort will be my sew iNIUM Mee 4mti1 the am Change Dace. The Note Holder well than deeermine the amount of the moodily payout that would be sulliaiew m spay the tuvW pxmexpal that 1 m expected to owe st lho Change Dam ion full on dw Maturity Dale at my now immrrt nee in suh .,,.liy equal payments The cult of this calculation will be the new amount of my waft psymouL (D) LAut[e an Interest Nam Change The boxcar rm I am regmind to pay m Ilea fuss Cheap Dam will to be vow than 1130054 or love sham 8310 1A. Thata6er, inteest rate will nom be inaeased or deemsed on my do& Change Dale by runt than me twCoetw pant (1fram the rate of barest I have been, pa?igg fm the sax W DAL My hau st use wig eeva ba puts due 14.7OO% or Ins than xhe initial morest ass for m Secdm 2 of dale Noce. (9) Eltaative Date of Change My new bearost ram wiB become off 4 ive on each Change Dam. I will pay the awouol of my newmonWly paymeal bmi au g on, the font mtoothly payment dam ear the Change Dam umul the mount of my monthly psywAM chaagea agai e. (IR Notice dChaua ran Note Holds will deliver or mail to con a notice of any changes in ttooyy i?toner raft and the amount of my monthly psymeed 681oee *C affective due of any duo. The notice will ixuclutde ia6ormetion required by 1. to be given me and abo the title and telepleox ammber ofe pence who will tmswer say gsouiom 1 may have sorwing the notice. S. BORROWER RIGHT TO PREPAY (A) Prepayment 1 have the tight to melee payments at any tieaa before they fro dttr A pmMemt of Prb* el only is 6m m no a "pm>payos m". Whin I mike a prepayment, I will tell the Note Holder im'wp I an doing no. ff I miles a partial papsywwK lbee will be no changes In the due due or in to atot mt oftey monthly pgment Dam ohm Now HoWor apeas in -umg so those changes. My partial p Waygmv may reduce, 4e amazat of my monthly payments Change Date following my partial prepayme nL However, arty reduction, due In my partial peepeymeot may be ofbr by am maters me imeremsc. (B) Prepayment Pesky In, the event, dtrlag the first 2 yon after the execution of this Nile, I make a proMovot and the woods twenty pereomltt (22e0%) of due original priLipal ammad of the loam k an twelve (12) monde _wID Pay a at (20% y osigital priochW amount tuut of *c km within the twelve 1I month Period Hof Holder will sarong a f the prepayment penalty after the tad anniversary of the date oCecaation of this Note. EFIIISN Loan Number 1003997 Page 2 of4 luidalsmLL (Pays 59 of 67) 0 • f. LOAN CHARGES If a law, which applies to add which sea maximum loan chortles. 'r interpreted jr that the interest of other ban edarges eoileaed or to be collected is eoamwliom with this leas exoeed the pe miaed Iimib. attm 0) airy sub lam cha=r gt li be indeed by the smotam nee "my 10 M&M the t:batge 10 die pamiaed limit: end (h) way sums almody collected from lime which exceeded ended iieti4 will bas mfitaded in me. The No1s Hilda may abom 10 male this rahmd by teducag the principal I owe under dim Now or by mldag a dhvd payment to me. Ifa mfsed reduces principal, the induction wed be treated as a partial prepaymeml. 7. BORRO%VZR%FAILURE TO PAY AS REQUIRED W Lade Charge hr Overdue Paym mss if the Nose Holder bas ant received the full emawm of amy nu mtldy payaaat by do ad of IS calmdor days altar he did, it is due, [will pays less charge m the Now Holder. The amount of the eba . will be 3d10 % of my ovordw paymew of principal and imtercaL I wig pay this We charge but only once on cseh hie pymeae (3) Ocfauk If 140 not ply the full amount of each monthly payment oa the date it is due, I will be in default. (C) Nodee of Default If I am in defaah, dim Noes holder may surd me a wriono notice telling me that if I do ant pay the overddae mount by a etatsIa does, de Now Holder may require m to pay inspaw only the fall amamr of prioapd which .has n be= paAe isamd ll the ns rot theeI owe an the amom. Mat due must be at least 30 days allot Ihs dtle on hkb the (D) No Waiver by Note Holder Even it a a time who I am in tbfanlt. the Now Holder does not torloim me to pay immediately is fill a do-and above, the Noes Holder will still have the right to do so if I am m def alt m a Isdn time. (Z) M)aeat of Waft Roldde Can sad Espemaee If Ole Now Holder has regsbW use to pay In (WI as described above. the Note Holder will haw dw AsId to be paid back by no for all of its come and exptstsu bt varmdog this Now to the estm ant probblwd by applicable law. Tbow wpm= itsda le, for example, tameable attorm yt fees. !t. GIVING OF NOTICES Utdas ham saquim a diffinot method. any notice tat must be given to we ender &k NOW will be vex by des using $ or by m=. it by fast ekes sail to the a the Property Addrma above or at a difromot addceaa it gars on Hoidot a taboo of my d0bro tt eddreaL Any areice bat Twat be givam to the Ntus Holder under this Nate wgl be given by deGvedag it or by meaft it by Gal wises aaill is On Now Holder at the addrw saved in Scetioa 3(A) above or at a diSarsat address if 1 am gives a notice of Ihad dilfagol addles. 9. OBLIGATIONS OF PIRSONS UNDER THIS NOTE If more dwa son;ert, wgml this Nag, out person is gully and personally obligated b limp an of the Maim made in hie Note, including the promise b pay The full amoom owed Any person who is a gtraaoesr, ately or eadmw mf lhia Now h Ww obligated es do time gunge. Any paean who alma ova there obliipi ioar, mhhdisg ties obUpdons of a surety a enrdeger of title Nme, it also obligated fo keep erg of dam prmnfara mace (a thin Nok The Note Holds may mfora its Tights under dth Note 4dw each 0immii ladividually or against erg of n logaha. Tleis record; that anyone of us maybe requirw to pay all of the amounts owed under thin Note. 10. WAIVERS ,;,.t,.. I dud city athu person who has obligations under bait Note waive die rigita of praatlmeot Wd linden of diahonor.'Preentatast• mess die r' b retlaire the Note Holder to demand paymed of ammmis des "No6oe of dim one mass eta right to require the Note Holder to give notice to afar person that nawaols due have as ban paid. La EFSISM Lear Number 1005987 Pager3 ofd WAAAP (Page 60 of 67) 0 0 11. UNIFORM SECURM LNO& Th6 Nola is a unikara ' wkb limited varkilmu it some jodsd' Io addition to the prowliodr given to tie Note Holder soft ibis Note, a Mongage, Deed of Tno or Sect0y Dad (ft'580Ay IutltlttlORM dated the --daft r"Non. y:ouces dm Note Holder 6sia porabla loner wlieh aig)rt nsok if i do sot bep the promises lint 1 maloe is ilia Noce That Security lattromatt desenbea how and tattier whet oosditisas I may be required b maim immadiale payment in full of all amounts 1 owe utdef this Now. Some chime eosdhionc aft descrbbed u follow : Trander of ma hsperty or a Beediclel laterw in Bmsoww if all or any pert of the pp?tpppp??ettyytY any 4eterm in the Pro" is soM or taosferred (or if Borrower ism a sah" person and a bwtetieid'mrreat in Borrower is sold or traosfutod), without Landes prior wriooa cossent. Lander may. at Its o isn ptba, to pane nedids poymsat m fiLU of all am secured by this SeoA* Instrument. Howswr, this opioa &V Aot W caarciasd by Lawler if exeteise In prohibited! bbyy Applicable Law. I Potion also shall not exercise tYb option if (a) Bottswx eassea to be sobatilmd Io l ettda itdamutios tcwweA by Leader to evaluate *A bttteaded traaafhaao u if a now Im wma bob% made ao the buueferee; and (b) Lender remosably delarmises that Le does aacticky will not bv'6np&fivd by d- I- ' s and rhat dw risk ofa breach of any cv+eoast or sgtanmcat bn tbb Security t is accept" to To 6te utest pem+it ed by Applicable Law. I ender may chorgs a nuattable tae a a oaodition b Lssdnr s consent be the bas assumption. Lander may also require the transferee to ttig it an ramptiea a6mamest fiat is seoepftble b Ltardsr and that obligaw the transferee b kexp all tits peombss and agmenrems made in list Now and m tin Saariry lusssmaan. Hareswer will eastinue to be obligped tinder the Moto and Phis Seveity Lsmtommt tmless I,eoder telasaaa Bono+vc is writigg. If B.aadsf saareisq the Option to tesptire mtmedialt payment IA fall, i ender tdlall jIYO Ht?OVMar sodco of aecelatstion Tic aotbce shop provide ¦ period of sot lac than 30 days tiross 6ts tWe We sake H Sim in aeoorda.ee will Sxtioa is witbia wlricb Bmro.v.r meat pay aL cams aoatrad by iii 3eour4y Iawoatwt. If Bonovrer falls m pay these sons prior b the espiretion of this parlod? I.anda may isvdx any rmtodia perodmed by ibis Severity Issatmam willtoat farther notice or deautd os Borrower. "WITNESS THE HAND(S) AND SEAL(S) OF TILE UNDERSIGNED` 6-wka rtv (SOaQ (S0 (Sup (SW) •Boeoaw -tlonrw ( ) Pal) -9a,ow. asnv+sr MISN Low Number 1005987 Pop 4 of 4 lsitials (Page 61 of 67) 0 9 ADJUSTAIR RATE INTEREST RATE &R & PREPAYMENT PENALTY Addendum to Note Tkb ADAWABLE RdIEREST RATE FLOOR & PREPAYMENT PENALTY ADDENDUM u me& t w 46 day of Auk 2006, and anaeds sloe NOW in the MOW of U.S. S 100A00.00 dried the same dace and pro by the paaon(s) who signs below (the "Borsawa(s)') to Equifiret Corpordion (the "Lander'). In addition to do egteemoms and provisions made in the NOW and the Secorky kwumenk end nawidsItla tg MY provisions, to the contrary eeamieed in said Note or the Smarity luzbvmant, both dw Beetower(a) end the I ender Halter epee n follows; ADJUSTABLE MEA[ST RATE FLOOR This loan has as b wm Rah 'Flow' which will limit rho amount the Interest Rate w Of OW clamps in dm Judea, the bttamt Rate during the tam of this lent will new be tees sham the b"d Ietaett Rats FavWcd for in Section 2 of the Note. MVAYMETIT PENALTY In the event, during the fad 2 yeas: aha the exoe i4m of this Note, I male a prapaymant end dr ptepeyawa etweads twamy pwooet (20%) of the o4ial ptbteipl amount of the lose ie att)'twelve (12).aaet~ emod, I wtu pry a propaymeat dtage m sa ameuot equal b sit (G) mattw advance ineaed w the attttamt; I which ie in ae mess of twatsty petoeet (20lG) of floe origtsel peiocipe) ateeuet of tbs fan wilhir the twelve (12) o>odh period. The Note Holder wW not areas a Prepaymeot penalty after the 2nd anrdversary of the" efateeu d" of ibis Noe. (Uday)IIAW Natneha Thttmes 1003987 tttw (Iz" PLUESE, BECKER & SALTZMAN, LLC Attomeys at Law 20000 HORIZON WAY SUITE 900 ROB SALTZMAN • MT. LAUREL, NEW JERSEY 080544318 RSaltzmanapbslaw.orQ (856) 813-1700 FACSIMILE: (856) 813-1720 SANFORD J. BECKER SBecke a?obsliw-orQ PENNSYLVANIA OFFICE: ROBERT T. PLUESE 425 COMMERCE DRIVE, SUITE 100 RPluesenpbslaw.orq FORT WASHINGTON, PA. 19034 (215) 546-3205 ROBERT F. THOMAS • RThomasApbslaw.org Please reply to, Mt. Laurel, New Jersey March 6, 2008 ACT 91 NOTICE OF COUNSEL: Katz, Ettin & Levine, P.C. The Law Offices-ofBarbara A. Fein, P.C. • . PA and N1 Bars Our File #84050 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached ?pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. 64U?Itb The name, address and phone number of Consumer Credit Counseling Agencies serving our County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397.(Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney_in.your area The-lo-cal- bar_ass-ocia.tion?ma-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): Natascha Thomas and James Thomas PROPERTY ADDRESS:332 Roxbury Road, Newville, PA 17241 LOAN ACCT. NO.: 2375082 ORIGINAL LENDER: Mortgage Electronic Registration Systems Inc. as Nominee for Equifirst Corporation CURRENT SERVICER: Franklin Credit Management Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure- on your mortgage for thrty__(3.0) days from the date of this Notice.-During that. time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT [30} DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing 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-MORTGAGEDEF-A-, JL'I'-(Bringit.up-to--date). - NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at 332 Roxbury Road Newville, PA 17241: IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS of $891.53 since the April 1, 2007, to the present and the following amounts are now past due: $11,589.89. Late Charges: $264.18 Escrow Advance Balance: $242.66 BPO/Inspection/Property Preservation: $95.00 Available/Unapplied Funds: -$40.43 TOTAL AMOUNT PAST DUE: $12,151.30 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $12,151.30, 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: Name of Servicer: Franklin Credit Management Corporation Address: 101 Hudson Street, 25th Floor, Jersey City, NJ 07302 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay_ off--the mortgage-debt, If the_lender refers_y_our case to its attorney_s,.but?!o?clwe_ 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 any time up to one hour before the Sheriffs Sale You may do so by pUing the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 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: Name of Lender: Franklin Credit Management Corporation Address: 101 Hudson Street, 25th Floor, Jersey City, NJ 07302 Phone Number:201-604-1800 Fax Number: 201-604-4510 EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs 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 _X_ may not (CHECK ONE) sell or transfer_ your home to a buyer or transferee who will assume the mortgag_e_ 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 ARE ATTACHED. 7160 3901 9845 5309 3638 Topatascha Thomas 32 Roxbury Road ewville, PA 17241 SENDER: 1e REFERENCE: 84050acts PS Form 380 0 Jarwa 2005 RETURN Postage S3pq E RECEIPT SERVICE 9?y • R O ? qO1 . • Restrh •?'yb Total PC. 0.00 US Postal Series POSTMARK OR DATE Receipt for .? Certified Mail ??- /1 No Insurance Coverage Provided U I Do Not Use for Intemation I Mail 7160 3901 9845 5309 3621 Tojames Thomas 332 Roxbury Road Newville, PA 17241 SENDER: .le REFERENCE: 84050acts PS Form 3800 Jarwa 2 • 32 RETURN ? ?`a2?+ 0 RE (a3p9 0 s 9845 • • . Val 0 • ?1b0 3 • 0.00 0.00 US Pastel Servit:i POSTMARK OR DATE Receipt for Certified Mail No Insurance Coverage Provided l' Do Not Use for Iniernstional KW O€ :b d Z Z bdl 8401 da Pluese, Becker & Saltzman, LLC Attorneys At Law 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 Rob Saltzman, Esquire Attorney ID NO.: 53957 856/813-1700 Attorney for Plaintiff 84050 Franklin Credit Management Corporation, Plaintiff, V. Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only), Defendants. TO THE PROTHONOTARY: PRAECIPE TO ENTER JUDGMENT AND ASSESSMENT OF DAMAGES Kindly enter Default Judgment in favor of Plaintiff, Franklin Credit Management Corporation, and against Defendant(s), Natascha Thomas (Record Owner and Mortgagor) and James Thomas (Mortgagor Only), for failure to file an Answer to Plaintiffs Civil Action in Mortgage Foreclosure within the time provided for by applicable law from service thereof. Service was made on the Defendant(s) by Sheriff of Cumberland County as follows: Natascha Thomas (Record Owner and Mortgagor), served on May 9, 2008. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-2536 Civil Term James Thomas (Mortgagor Only), served on May 9, 2008. Assess Damages as follows: Total Demand in Complaint $111,145.64 Interest due and owing at the rate of $22.59 per diem from 4/5/08 to 6/17/08 $ 1,671.66 TOTAL JUDGMENT TO BE ENTERED $112,817.30 PLUESE, BECKER & S LTZMAN, LLC By: Rob altzman, Esquire ,4ltttorneys for Plaintiff r Pluese, Becker & Saltzman, LLC Attorneys At Law 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 Rob Saltzman, Esquire Attorney ID NO.: 53957 856/813-1700 Attorney for Plaintiff 84050 Franklin Credit Management Corporation, Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-2536 Civil Term Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only), Defendants. Sworn to and Subscribed before CERTIFICATION OF ADDRESSES I, Dawn Killen, Legal Assistant, of the Law Firm of Pluese, Becker & Saltzman, Attorney for Plaintiff, Franklin Credit Management Corporation, hereby certify that the Plaintiffs correct address is 202 Hudson Street, 25`h Floor, Jersey City, NJ 07302 and the last known address of each Defendant is as below. Natascha Thomas (Record Owner and Mortgagor), 332 Roxbury Road, Newville, PA 17241 James Thomas (Mortgagor Only), 332 Roxbury Road, Newville, PA 17241 I certify that the foregoing information is true and correct to the best of my knowledge, information and belief. me this 1 PLUESE, BECKER & SALTZMAN, LLC By: Dawn Killen, Legal Assistant - JENNIFER EISER NOTARY, PI)BLIC OF NEW JERSEY `IDf .2221929 _ .:' MY. CQMMI.SSION 0010 smog; Y Pluese, Becker & Saltzman, LLC Attorneys At Law 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 856/813-1700 Rob Saltzman, Esquire Attorney ID No.: 53957 Attorney for Plaintiff 84050 Franklin Credit Management Corporation, Plaintiff, V. Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only), Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-2536 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND S.S. I, Rob Saltzman, Esquire, being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained either by or an behalf of the Plaintiff herein named and that such investigations, including inquiry of the U.S. Department of Defense via their website, https://www.dmdc.osd.mil/scra/owa/home, and/or records indicate that the above-named Defendant(s) is/are not in the Military or Naval Service of the United States of America or its Allies as defined by the Servicemembers Civil Relief Act 50 U.S.C. Appx, sec 501, et seq., as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Natascha Thomas (Record Owner and Mortgagor) Age: Over 18 Residence: 332 Roxbury Road, Newville, PA 17241 Employment: Unknown Defendant: James Thomas (Mortgagor Only) Age: Over 18 Residence: 332 Roxbury Road, Newville, PA 17241 Employment: Unknown PLUESE, BECKER & SALTZMAN, LLC By: ob Saltzman, Esquire Attorney ID No.: 53957 5" t rv- Alt, Pluese, Becker & Saltzman, LLC Attorneys At Law 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 Rob Saltzman, Esquire Attorney ID NO.: 53957 856/813-1700 Attorney for Plaintiff 84050 Franklin Credit Management Corporation, Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-2536 Civil Term Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only), Defendants. CERTIFICATION OF MAILING I, Dawn Killen, Legal Assistant, of the Law Firm of Pluese, Becker & Saltzman, Attorneys for Plaintiff, hereby certify that I forwarded to the following Defendant(s) on the date(s) listed, by regular mail, a copy of the Notice of Intention to take Default Judgment, Rule 237.1: Natascha Thomas (Record Owner and Mortgagor), 332 Roxbury Road, Newville, PA 17241 James Thomas (Mortgagor Only), 332 Roxbury Road, Newville, PA 17241 PLUESE, BECKER & SALTZMAN By: Dawn Killen, ega11 Assista n t Pluese, Becker & Saltzman, LLC. Robert F. Thomas, Esquire Attorney Identification No.: 70206 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 (856) 813-1700 Attorney for Plaintiff 84050 FRANKLIN CREDIT MANAGEMENT CORPORATION COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, v. NATASCHA THOMAS (RECORD OWNER AND MORTGAGOR) AND JAMES THOMAS (MORTGAGOR ONLY : No. 08-2536 Civil Term Defendant(s). NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa. R.C.P. 237.1 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the Court your defenses or objections to the claims asserted against you. Unless you act within ten (10) days from the date of this Notice as set forth below, a Judgment may be entered against you without a hearing and you may lose your property or other important rights and may be liable for money damages. You should take this Notice to a lawyer at once. If you do not have a lawyer, go to or telephone the office set forth below. This office can provide you with information about hiring a lawyer. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 1/800-990-9108 NOTIFICACION IMPORTANTE Usted esta en incumplimiento de su oblicacion legal de presentar, ya sea personalmente o por medio de su abogado, una declaracion por escrito y por no haber presentado por escrito sus defensas a los cargos que se han presentado en su contra. Si usted no toma accion dentro de diez (10) dias de la fecha de esta Notificacion, se registrara una sentencia en su contra sin audiencia y usted podra perder su propiedad u otros derechos importantes y podra ser responsable por danos monetarios. Lleve esta demanda a un abogado immediatamente. Si no tiene abogado, vaya en persona o flame por telefono a la oficina cuya. Esta oficiana puede proveer de usted la informacion sobre emplear a un abogado. Si usted no puede permitirse a la ira de h a la capa, esta oficina puede poder proveer de usted la informacion sobre las agencias que pueden ofrecer servicios juridicos a las personas elegibles en un honorari o reducido o ningun honorario. 1. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 11800-990-9108 Date of Notice: June 3, 2008 PERSONS SERVED: Natascha Thomas 332 Roxbury Road Newville, PA 17241 James Thomas 332 Roxbury Road Newville, PA 17241 PLUESE, BEC SALTZMAN, LLC. `J By: Robe Thomas, Esquire Attorneys for Plaintiff CASE NO: 2008-02536 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THOMAS NATASCHA the DEFENDANT , at 1737:00 HOURS, on the 9th day of May 2008 at 332 ROXBURY ROAD NEWVILLE, PA 17241 NATASCHA THOMAS by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 28.00 Affidavit .00 Surcharge 10.00 .00 56.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 05/12/2008 PLUESE BECKER SALTZMAN By: _ Deputy Sheriff of A. D. r CASE NO: 2008-02536 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THOMAS JAMES the DEFENDANT , at 1737:00 HOURS, on the 9th day of May , 2008 at 332 ROXBURY ROAD NEWVILLE, PA 17241 by handing to NATASCHA THOMAS, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 So Answers: R. Thomas Kline 05/12/2008 PLUESE BECKER SALTZMAN By: -?_ Deputy Sheriff of A. D. Sworn and Subscibed to before me this day . . SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02536 COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT OCCUPANT but was unable to locate Him in his bailiwick /Y P'?w RTIT T TTTT TR/17']T Tl1T1 L, He therefore returns the the within named DEFENDANT OCCUPANT 332 ROXBURY ROAD NEWVILLE, PA 17241 THERE WERE NO OTHER OCCUPANTS. Sheriff's Costs: Docketing Service Not Found Surcharge NOT FOUND , as to So answers: 6.00 f? .00 5.00 R. Th as ine 10.00 Sheriff of Cumberland County .00 21.00 PLUESE BECKER SALTZMAN 05/12/2008 Sworn and Subscribed to before me this day of A. D. a lew OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS ONE COURTHOUSE SQUARE CARLISLE, PA 17013 CURT LONG, PROTHONOTARY TO: Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 Franklin Credit Management Corporation, Plaintiff, COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Natascha Thomas (Record Owner and NO. 08-2536 Civil Term Mortgagor) James Thomas (Mortgagor Only), NOTICE PURSUANT TO RULE 236 Defendants. Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above-captioned proceeding as indicated below. Curt Long, Prothonotary [XX] Judgment entered by Default IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Rob Saltzman, Esquire, Attorney ID 453957 PLUESE, BECKER & SALTZMAN, LLC 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 856/813-1700 Attorneys for Plaintiff W/ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Franklin Credit Management Corporation Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only) Defendant(s) To the Prothonotary: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST From 6/18/08 to 12/10/08 @ $18.55 per diem Total (Costs to be added) Date: June 13, 2008 Note: Please attach description of Property. NO.: 08-2536 Civil Term $112,817.30 $ 3,264.80 $116,082.10 Ro Saltzman, Esquire ttomey for Plaintiff 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 (856) 813-1700 Attorney ID No.: 53957 File #84050 9 H ?o M N 00 O 0 z W H oz ¢ a a? o zz O H C cd p0 ? H U ?z o ? U W H ? z? "~ U z o CC ~' W U a z w lzi Lu IJ ( 1 { { t1 N ^ Q Q V rj `b9 41, V4 a w E O rZ 1 { Nt N z N M M V Y r1i cd sa, sue, 4 J? M? 'Q o J I/ TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center line of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. ti TAX PARCEL NUMBER: 15-05-0411-018 TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE: This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-2536 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FRANKLIN CREDIT MANAGEMENT CORPORATION, Plaintiff (s) From NATASCHA THOMAS (RECORD OWNER AND MORTGAGOR) AND JAMES THOMAS (MORTGAGOR ONLY) (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTON. (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 $112,817.30 L.L. $.50 Interest FROM 6/18/08 TO 12/10/08 @ $18.55 PER DIEM -- $3,264.80 Atty's Comm % Atty Paid $212.00 Due Prothy $2.00 Other Costs Plaintiff Paid Date: JUNE 17, 2008 (Seal) C . Long, ro ry By: Deputy REQUESTING PARTY: Name ROB SALTZMAN ESQUIRE Address: 20000 HORIZON WAY, SUITE 900 MOUNT LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 856-813-1700 Supreme Court ID No. 53957 PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation, Plaintiff, V. Court of Common Pleas Cumberland County Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only), Defendant(s). Docket #08-2536 Civil Term CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Rob Saltzman, Esquire hereby certify that I am the attorney of record for the Plaintiff, Franklin Credit Management Corporation in this action against real property and I further certify that this property is: ( ) FHA - Tenant Occupied or Vacant ( ) Commercial (X) That the Plaintiff has complied in all respects with Section 403 of the HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 which may include but is not limited to: (a) Service of Notice of Defendant(s) (b) Expiration of thirty days since the Service of Notice (c) Defendant's failure to request or to appear at a face-to-face meeting with the Mortgagee or with a Consumer Credit Counseling Agency. (d) Defendant's failure to file an application for financial assistance with the Pennsylvania Housing Finance Agency and/or the denial of such application. I further agree to indemnify and hold harmless the Sheriff of Cumberland County for any willfully false material statements given herein. Respectfully submitted, PLUESE, BECKER LTZMAN, LLC BY: Pb Saltzman, Esquire Attorney for Plaintiff Our File #84050 c"?' 'ors ?' ?'?: ? ? ° -?c3ta? G? c- :xr : _ _ + / l_ ,? ?? _ ?? t i?1 . ?-^' l..? .?, i -- ?? ^? ? 1 PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff din Credit Management Corporation Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY v. Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only) Defendant Docket #08-2536 Civil Term AFFIDAVIT OF LAST KNOWN ADDRESS I, Rob Saltzman, Esquire, Attorney for Plaintiff, Franklin Credit Management Corporation, hereby certify that the last known address(es) of the Defendant(s) is/are as below: Natascha Thomas (Record Owner and Mortgagor), 332 Roxbury Road, Newville, PA 17241 James Thomas (Mortgagor Only), 332 Roxbury Road, Newville, PA 17241 I certify that the foregoing information is true and correct to the best of my knowledge, information and belief. Respectfully submitted, PLUESE, BECER& S LTZMN, LLC BECK BY: R Saltzman, Esquire ttornev for Plaintiff Our File #84050 " C ? ?. ? ? ? ? ? ? ; ?. __?.`. ?° + ?., ? „ - ?;;?? ?? +' ? PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation, Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only), Defendants. Docket #08-2536 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Franklin Credit Management Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 332 Roxbury Road, NewAlle, PA 17241, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. 1. Name and address of owner(s) or reputed owner (s): Natascha Thomas James Thomas (Mortgagor Only) (Record Owner and Mortgagor) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 2. Name and address of defendant(s) in the judgment: SAME AS ABOVE 3. Name and last address of every judgment creditor whose judgment is a record lien on the real property to be sold: None. 4. Name and address of the last recorded holder of every mortgage of record: Franklin Credit Management Corporation (Plaintiff) Our File #84050 Name and address of every other person who has any record lien on the property: None. 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: Cumberland Co. Dept. of Commonwealth of PA Domestic Relations 6th Floor, Strawberry Square P.O. Box 320 Bureau of Individual Tax Carlisle, PA 17013 Inheritance Tax Division Commonwealth of PA Dept. of Welfare P.O. Box 2675 Harrisburg, PA 17105 Dept. of Public Welfare T.P.L. Casualty Unit Estate Recovery Program P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105 Attn: John Murphy, Dept. 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax Special Procedure Branch P.O. Box 12051 Philadelphia, PA 19105 Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property, which may be affected by the sale: Tenant/Occupant 332 Roxbury Road Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. #4904 relating to unswom falsification to authorities. June 13, 2008 PLUESE, BECKER & ZMAN, LLC Date BY: b Saltzman, Esquire Attorney for Plaintiff Our File #84050 ? r.a ? a C c? ,,,,? ' Tom ? ww '?; .,..r . -. ... r,... x ?. ' des y ,? ?,i „} ?; ?? ? e"?- OF PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 for Plaintiff Franklin Credit Management Corporation Plaintiff, V. Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only) Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY Docket #08-2536 Civil Term NOTICE OF SHERIFF'S SALE OF REAL ESTATE Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 Your house at 332 Roxbury Road, Newville, PA 17241, is scheduled to be sold by the Cumberland County Sheriff's Department to enforce the court judgment of $112,817.30 obtained by Franklin Credit Management Corporation against you. The Sheriff's Sale will be conducted on December 10, 2008, at 10:00 A.M., at the?Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 or, in the alternative, at a location to be determined by the Cumberland County Sheriff's Department. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to Plaintiff Mortgagee the back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call Rob Saltzman, Esquire at (215) 546-3205. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. Our File #84050 r You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Rob Saltzman, Esquire at (215) 546-3205, or by calling the Cumberland County Sheriff's Department at (717) 240-6390 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Rob Saltzman, Esquire at (215) 546-3205, or by calling the Sheriff's office at (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Cumberland County Sheriff on or about thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Distribution sheet is posted. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Our File 084050 d OW TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along fine of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center fine of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. A TAX PARCEL NUMBER: 15-05-0411-018 TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE. This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. N -? ws ? -- r Franklin Credit Management Corporation VS Natascha Thomas and James Thomas In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-2536 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 Rob Saltzman. Sheriff's Costs: Docketing 30.00 Poundage 2.05 Levy 30.00 Prothonotary 2.00 Law Library .50 Surcharge 40.00 $ 104.55 ? So Answers: R. Thomas Kline, Sheriff BY__j Real Estate S eant s/?o?es #02. rv?cL. R-*- ;?13 q`d k PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 for Plaintiff Franklin Credit Management Corporation, Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only), Defendants. Docket #08-2536 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Franklin Credit Management Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 332 Roxbury Road, Newville, PA 17241, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. Name and address of owner(s) or reputed owner (s): Natascha Thomas James Thomas (Mortgagor Only) (Record Owner and Mortgagor) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 2. Name and address of defendant(s) in the judgment: SAME AS ABOVE 3. Name and last address of every judgment creditor whose judgment is a record lien on the real property to be sold: None. 4. Name and address of the last recorded holder of every mortgage of record: Franklin Credit Management Corporation (Plaintiff) Our File #84050 5. Name and address of every other person who has any record lien on the property: None. 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: Cumberland Co. Dept. of Domestic Relations P.O. Box 320 Carlisle, PA 17013 Commonwealth of PA Dept. of Welfare P.O. Box 2675 Harrisburg, PA 17105 Dept, of Public Welfare T.P.L. Casualty Unit Estate Recovery Program P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105 Commonwealth of PA 6th Floor, Strawberry Square Bureau of Individual Tax Inheritance Tax Division Attn: John Murphy, Dept. 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax Special Procedure Branch P.O. Box 12051 Philadelphia, PA 19105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property, which may be affected by the sale: Tenant/Occupant 332 Roxbury Road Newville, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or 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. June 13, 2008 PLUESE, BECKER & ZMAN, LLC Date BY: b Saltzman, Esquire Attorney for Plaintiff Our File #84050 PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY V. Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only) I Docket #08-2536 Civil Term Defendant NOTICE OF SHERIFF'S SALE OF REAL ESTATE Natascha Thomas (Record Owner and Mortgagor) James Thomas (Mortgagor Only) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 Your house at 332 Roxbury Road, Newville, PA 17241, is scheduled to be sold by the Cumberland County Sheriff's Department to enforce the court judgment of $112,817.30 obtained by Franklin Credit Management Corporation against you. The Sheriff's Sale will be conducted on December 10, 2008, at 10:00 A.M., at the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 or, in the alternative, at a location to be determined by the Cumberland County Sheriff's Department. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to Plaintiff Mortgagee the back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call Rob Saltzman, Esquire at (215) 546-3205. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. Our File #84050 You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Rob Saltzman, Esquire at (215) 546-3205, or by calling the Cumberland County Sheriff's Department at (717) 240-6390 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Rob Saltzman, Esquire at (215) 546-3205, or by calling the Sheriff's office at (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Cumberland County Sheriff on or about thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Distribution sheet is posted. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Our File #84050 } ' TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center line of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. TAX.PARCEL NUMBER: 15-05-0411-018 TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE: This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-2536 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FRANKLIN CREDIT MANAGEMENT CORPORATION, Plaintiff (s) From NATASCHA THOMAS (RECORD OWNER AND MORTGAGOR) AND JAMES THOMAS (MORTGAGOR ONLY) (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTON. (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 $112,817.30 L.L. $.50 Interest FROM 6/18/08 TO 12/10/08 @ $18.55 PER DIEM -- $3,264.80 Atty's Comm % Due Prothy $2.00 Atty Paid $.1240 Other Costs Plaintiff Paid Date: JUNE 17, 2008 Curtis R ong, Protho (Seal) By: Deputy REQUESTING PARTY: Name ROB SALTZMAN ESQUIRE Address: 20000 HORIZON WAY, SUITE 900 MOUNT LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 856-813-1700 Supreme Court ID No. 53957 JurasiaS alinsg Iua2I g 80 OZ `S t isrignv :aiva •uiaxau pariodiooui oouajajaa sigl Xq pus 1ijm siip T 411m poi g «V„ llglgxg uo poquosop AlInj aioui toZI. Aingxo d ZEE sie pa.ioqumu put, UMOUX Vd `)(iunoo putijaqumD `digsunmoy uiUjWianmoZ ui pajennis f4.iado id pew aqj ui isajalui s juepuaiap aip uodn patnai 3ji,iogS DID 80OZ `S 1 jsn$nV up to# alus al a' MOW Pluese, Becker & Saltzman, LLC. Robert F. Thomas, Esquire Attorney Identification No.: 70206 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 856-813-1700 Attorney for Plaintiff 84050 FRANKLIN CREDIT MANAGEMENT CORPORATION Plaintiff, V. NATASCHA THOMAS (RECORD OWNER AND MORTGAGOR) AND JAMES THOMAS (MORTGAGOR ONLY) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-2536 Civil Term Defendant(s). TO THE PROTHONOTARY: PRAECIPE TO SETTLE, DISCONTINUE AND END Kindly settle, discontinue and end the above captioned matter without prejudice. PLUESE, BECKER & SALTZMAN, LLC. BY: Ro . Thomas, Esquire # G ' (10 Pluese, Becker & Saltzman, LLC. Robert Thomas, Esquire Attorney Identification No.: 70206 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 856/813-1700 Attorneys for Plaintiff 84050 FRANKLIN CREDIT MANAGEMENT CORPORATION Plaintiff, v. NATASCHA THOMAS (RECORD OWNER AND MORTGAGOR) AND JAMES THOMAS (MORTGAGOR ONLY) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-2536 Civil Term PRAECIPE TO VACATE JUDGMENT Defendant(s). TO THE PROTHONOTARY: Kindly vacate Judgment on the above captioned matter without prejudice. PLUESE, BECKER & SALTZMAN, LLC. BY: Rob F. Thomas, Esquire 1 fW V- -? L. f`