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LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
IN 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690 ATTORNEY FOR PLAINTIFF
EMC MORTGAGE CORPORATION, COURT OF COMMON PLEAS
ATTORNEY-IN-FACT FOR
JPMORGAN CHASE BANK, N.A., AS CIVIL DIVISION
TRUSTEE FOR CERTIFICATEHOLDERS
OF BEAR STEARNS ASSET BACKED CUMBERLAND COUNTY
SECURITIES TRUST 2005-SD4,
MORTGAGE PASS-THROUGH ?/?j
CERTIFICATES, SERIES 2005-SD4 NO. a$ - 3a ID Civi k (errA
800 STATE HIGHWAY 121 BYPASS
LEWISVILLE, TX 75067-4180 COMPLAINT IN
PLAINTIFF MORTGAGE FORECLOSURE
VS.
RICHARD G. EMORY,
A/K/A RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL 17011
DEFENDANT
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the court your defense or objections to
the claims set forth against you. You are warned that if you fail to do so the case may proceed without you
and a judgment may be entered against you by the Court without further notice for any money claimed in the
complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
800-990-9108
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF.
IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE
VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN
EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT
FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE
NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD
THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO
CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT
UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690 ATTORNEY FOR PLAINTIFF
EMC MORTGAGE CORPORATION, COURT OF COMMON PLEAS
ATTORNEY-IN-FACT FOR
JPMORGAN CHASE BANK, N.A., AS CIVIL DIVISION
TRUSTEE FOR CERTIFICATEHOLDERS
OF BEAR STEARNS ASSET BACKED CUMBERLAND COUNTY
SECURITIES TRUST 2005-SD4,
MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4 NO. d f _ 3,Z D-a ( T.cu,,,_
800 STATE HIGHWAY 121 BYPASS
LEWISVILLE, TX 75067-4180 COMPLAINT IN
PLAINTIFF MORTGAGE FORECLOSURE
Vs.
RICHARD G. EMORY,
A/K/A RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL, 17011
DEFENDANT
CIVIL ACTION MORTGAGE FORECLOSURE
1. EMC Mortgage Corporation, Attorney-in-fact for JPMorgan Chase Bank, N.A., as
Trustee for certificateholders of Bear Stearns Asset Backed Securities Trust 2005-SD4,
Mortgage Pass-Through Certificates, Series 2005-SD4 (hereinafter referred to as
"Plaintiff") is an Institution conducting business under the Laws of the Commonwealth of
Pennsylvania with a principal place of business at the address indicated in the caption
hereof.
2. Richard G. Emory, a/k/a Richard Glen Emory (hereinafter referred to as "Defendant") is
an adult individual residing at the address indicated in the caption hereof.
3. Plaintiff brings this action to foreclose on the mortgage between Defendant and itself as
Mortgagee by Assignment. The Mortgage, dated July 9, 2004, was recorded on
July 14, 2004 in the Office of the Recorder of Deeds in Cumberland County in Mortgage
Book 1873, Page 2715. A copy of the Mortgage is attached and made a part hereof as
Exhibit `A'. Plaintiff is now the legal owner of the mortgage and in the process of
formalizing an assignment of same.
r 7
4. The Mortgage secures the indebtedness of a Note executed by the Defendant on
July 9, 2004 in the original principal amount of $135,900.00 payable to Plaintiff in
monthly installments with an interest rate beginning at 7.90%. A copy of the Note is
attached and made a part hereof as Exhibit `B'.
5. The land subject to the mortgage is 50 Old Orchard Circle, Camp Hill 17011. A copy of
the Legal Description is attached as part of the Mortgage as Exhibit `A' and incorporated
herein.
6. The Defendant is the Record Owner of the mortgaged property located at
50 Old Orchard Circle, Camp Hill 17011.
7. The Mortgage is now in default due to the failure of Defendant to make payments as they
become due and owing. As a result of the default, the following amounts are due:
Principal Balance $132,906.94
Interest to 5/16/2008 $14,411.52
Escrow Advance $321.25
Accumulated Late Charges $161.11
Accumulated NSF Charges $10.00
Recoverable Balance $1,327.54
Other Fees Due $36.95
Cost of Suit and Title Search $550.00
Attorney's Fees $1,000.00
TOTAL $150,725.31
plus interest from 5/17/2008 at $35.96 per day, costs of suit and attorney's fees.
8. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchase at Sheriff's
sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be
charged.
9. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a
defaulting mortgagor with a Notice of Homeowners' Emergency Mortgage Assistance
("Act 91 Notice") 35 P.S. Section 1680.403c.
10. The Notice of Homeowners' Emergency Mortgage Assistance was required and Plaintiff
sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to
the Defendant by regular and certified mail on January 29, 2008. A copy of the Notice is
attached and made a part hereof as Exhibit `C'.
11. The Mortgage is not a residential mortgage under 41 P.S. Section 401 because the
principal amount of the Mortgage is in excess of $50,000.00 and, therefore, Plaintiff was
not required to send the Act 6 Notice of Intention to Foreclose.
WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the
mortgaged property in Plaintiff s favor and against the Defendant, in the sum of $150,725.31 together
with the interest from 5/17/2008 at $35.96 per day, costs of suit and attorney's fees.
Law Offices of Gregory Javardian
BY:
G ory Ja r is
ttorney ID . 55669
Attorney for Plaintiff
EXHIBIT `A'
i?.5. agd?Fs I?
Prepared By:
FIRST HORIZON HOME LOAN CORPORATION
5901 COLLEGE BLVD, 3RD FLOOR
OVERLAND PARK, ICS 66211
Parcel Number. County: 47-18-1302-113 City:
DEFINITIONS
?:i:CO D:A" Jr DEEDS
COUNTY-PA
'04 JUL 14 fill 11 16
Return To:
FIRST HORIZON HOME LOAN CORPORATION
S901 COLLEGE BLVD., 3RD FLOOR
OVERLAND PARR, KS 66211
[Space Above This Line For Recordist Data)
MORTGAGE
0049256902
Words used in multiple sections of this document are defined below and other words are defined in Sections
3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are also provided
in Section 16.
(A) "Security Instrument" means this document, which is dated July 9th, 2004 ,
together with all Riders to this document.
(8) "Borrower" is
RICHARD G EMORY AAAL yl
Borrower is the mortgagor under this Security Instrumnt.
(C) "Lender" is FIRST HORIZON HOME LOAN CORPORATION
Lender is a CORPORATION
PENNSYLVANIA - Single Family - Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1//01
®®-6(PA) (ODDS)
Page 1 d 18 MitlalS.?
VMP MORTGAGE FORMS - (OWNI.Ml
OK 1873PG27 IS
organized and existing under the laws of THE STATE OF KANSAs
Lender's address is 4000 HORIZON WAY, IRVING, T% 75063
Lender is the mortgagee under this Security Instrument.
(D) "Note" means the promissory note signed by Borrower and dated JULY 9th, 2004
The Note states that Borrower owes Lender
ONE HUNDRED THIRTY FIVE THOUSAND MINN HUNDRED & 00/100 Dollars
(U.S. $ 135, 900.00 ) plus interest. Borrower has promised to pay this debt in regular Periodic
Payments and to pay the debt in full not later than AUGUST 1, 2034
(E) "Property" means the property that is described below under the heading 'Transfer of Rights in the
Property."
(F) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges
due under the Note, and all sums due under this Security Instrument, plus interest.
(G) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following
Riders are to be executed by Borrower [check boa as applicable):
Adjustable Rate Rider ? Condominium Rider ? Second Home Rider
E9 Balloon Rider El Planned Unit Development Rider 1-4 Family Ricer
0 VA Rider El Biweekly Payment Rider ? Other(s) [specify]
(H) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations,
ordinances and administrative rules and orders (that have the effect of law) as well as all applicable final,
non-appealable judicial opinions.
(I) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other
charges that are imposed on Borrower or the Property by a condominium association, homeowners
association or similar organization.
(•n "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check,
draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic instrument,
computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an
account. Such term includes, but is not limited to, point-of-sale transfers, automated teller machine
transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers.
(K) "Escrow Items" means those items that are described in Section 3.
(L) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by
any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i)
damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property;
(iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or
condition of the Property.
(M) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on,
the Loan.
(1) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the
Note, plus (ii) any amounts under Section 3 of this Security Instrument.
0049256902 E
irti6ah:
®®-E(PA) Mw) Page 2d is Form 3039 1/01
n 1873PG27 I
(O) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its
implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time,
or any additional or successor legislation or regulation that governs the same subject matter. As used in this
Security Instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a
"federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan"
under RESPA.
(P) "Successor In. Interest of Borrower" means any party that has takers title to the property, whether or not
that party has assumed Borrower's obligations under the Note and/or this Security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: (i) the repayment of the Loan, and all renewals, extensions and
modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this
Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to
Lender the following described property located in the county (Type of Recording Jurisdiction]
Of Cumberland [Name of Recording Jurisdiction]:
All that tract or parcel of land as shown on Schedule ¦A" attached
hereto which is incorporated herein and made a part hereof.
which currently has the address of
50 OLD ORCHARD CIRCLE
CAMP HILL
("Property Address"):
[Street]
[city), Pennsylvania 17011 (Zip Code]
TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements,
appurtenances, and fixtures now or hereafter a part of the property. Al( replacements and additions shall also
be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the
"Property. "
0049256902
®-6(PA) (ow) inidids:
® page 3d is Form 3039 1/01
6K1873PG2717
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has
the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all
claims and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-tmiform
covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real
property.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges.
Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and any
prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items
pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in U.S.
currency. However, if any check- or other instrument received by Lender as payment under the Note or this
Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments
due under the Note and this Security Instrument be made in one or more of the following forms, as selected
by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check,
provided any such check is drawn upon an institution whose deposits are insured by a federal agency,
instrumentality, or entity; or (d) Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location designated in the Note or at
such other location as may be designated by Lender in accordance with the notice provisions in Section 15.
Lender may return any payment or partial payment if the payment or partial payments are insufficient to bring
the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current,
without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in
the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each
Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied
funds. Lender may hold such unappiied funds until Borrower makes payment to bring the Loan current. If
Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return
them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under
the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the
future against Lender shall relieve Borrower from making payments due under the Note and this Security
Instrument or performing the covenants and agreements secured by this Security Instrument.
2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments
accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the
Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to
each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to
late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal
balance of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a
sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the
late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from
Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in
0049256902 lnitiala?
®g-8(PA) (oooe) Page 4 of is Form 3039 1101
87 3??27
full. To the extent that any excess exists after the payment is applied to the full payment of one or more
Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be
applied first to any prepayment charges and then as described in the Note.
Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the
Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments.
3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under
the Note, until the Note is paid in full, a sum (the "Funds") to provide for payment of amounts due for: (a)
taxes and assessments and other items which can attain priority over this Security Instrument as a lien or
encumbrance on the Property; (b) leasehold payments or ground rents on the Property. if any; (c) premiums
for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any,
or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in
accordance with the provisions of Section 10. These items are called "Escrow Items." At origination or at any
time during the term of the Loan. Lender may require that Community Association Dues, Fees, and
Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item.
Borrower shall promptly famish to Lender all notices of amounts to be paid under this Section. Borrower
shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds
for any or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Funds for any or all
Escrow Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower
shall pay directly, when and where payable, the amounts due for any Escrow Items for which payment of
Funds has been waived by Lender and, if Lender requires, shall famish to Lender receipts evidencing such
payment within such time period as Lender may require. Borrower's obligation to make such payments and
to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security
Instrument, as the phrase "covenant and agreement" is used in Section 9. If Borrower is obligated to pay
Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item,
Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated
under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow
Items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall
pay to Lender all Funds, and in such amounts, that are then required under this Section 3.
Leader may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply
the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can
require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and
reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law.
The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality,
or entity (including Leader, if Lender is an institution whose deposits are so insured) or in any Federal Home
Loan Bank. Leader shall apply the Funds to pay the Escrow Items no later than the time specified under
RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the
escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and
Applicable Law permits Lender to make such a charge. Unless an agreement is made m writing or Applicable
Law requires interest to be paid on the Funds, Lender shall not be required to pay Borrower any interest or
earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the
0049256902 a -MZ ;e
®®4(PAl (ooos) Page 5of 16 Form 3039 1/01
8K ! 873PG27 ! 9
Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by
RESPA.
If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to
Borrower for the excess ftids in accordance with RESPA. If there is a shortage of Funds held in escrow, as
defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to
Lender the amount necessary to make up the shortage in accordance with RESPA, but m no more than 12
monthly payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall
notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up
the deficiency in accordance with RESPA, but in no more than 12 monthly payments.
Upon payment in frill of all sums secured by this Security Instrument, Lender shall promptly refund to
Borrower any Funds held by Lender.
4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines, and impositions
attributable to the Property which can attain priority over this Security Instrument, leasehold payments or
growl rents on the Property, if any, and Community Association Dues, Fees, and Assessments, if arty. To the
extent that these items are Escrow Items, Borrower shall pay them in the mariner provided in Section 3.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to
Lender, but only so long as Borrower is performing such agreement; (b) contests the Lien in good faith by, or
defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the
enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded;
or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this
Security Instrument. If Lender determines that any part of the Property is subject to a lien which can attain
priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10
days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the
actions set forth above in this Section 4.
Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting
service used by Lender in connection with this Loan.
5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the
Property insured against loss by fire, hazards included within the term "extended coverage," and any other
hazards including, but not limited to, earthquakes and floods, for which L=xL-r requires insurance. This
insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender
requires. What Lender requires pursuant to the preceding sentences can change during the term of the Loan.
The insurance carrier providing the insurance shalt be chosen by Borrower subject to Lender's right to
disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require
Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood zone determination,
certification and tracking services; or (b) a one-tine charge for flood zone determination and certification
services and subsequent charges each time remappings or similar changes occur which reasonably might
affect such determination or certification. Borrower shall also be responsible for the payment of any fees
imposed by the Federal Emergency Management Agency in connection with the review of any flood zone
determination resulting from an objection by Borrower.
0049256902 WOWS: i ®-B(PA) (OM) Page e of 1e Form 3039 1/01
1etct873PC2720.
If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance
coverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any
particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might not
protect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, hazard
or liability and might provide greater or lesser coverage than was previously in effect. Borrower
acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of
insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall
become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at
the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender
to Borrower requesting payment.
All insurance policies required by Lender and renewals of such policies shall be subject to Lender's
right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as
mortgagee and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal
certificates. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and
renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Lender, for
damage to, or destruction of, the Property, such policy shall include a standard mortgage clause and shall
name Lender as mortgagee and/or as an additional loss payee.
In the event of loss. Borrower shall give prompt notice to the insurance carrier and Lender. Lender may
make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in
writing, any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be
applied to restoration or repair of the Property, if the restoration or repair is economically feasible and
Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to
hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work
has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly.
Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress
payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires
interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower any interest or
earnings on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not be
paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is
not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to
the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to
Borrower. Such insurance proceeds shall be applied in the order provided for in Section 2.
If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim
and related matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance
carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30-day period will
begin when the notice is given. In either event, or if Lender acquires the Property under Section 22 or
otherwise. Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount
not to exceed the amounts unpaid wrier the Note or this Security Instrument, and (b) any other of Borrower's
rights (other than the right to any refund of unearned premiums paid by Borrower) under all insurance
policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender
may use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the
Note or this Security Instrument, whether or not then due.
0049256902 wea??:
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6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence
within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as
Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise
agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances
exist which are beyond Borrower's control.
7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not
destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property.
Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent
the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to
Section 5 that repair or restoration is not economically feasible, Borrower shall promptly repair the Property if
damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in
connection with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or
restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds
for the repairs and restoration in a single payment or in a series of progress payments as the work is
completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the Property,
Borrower is not relieved of Borrower's obligation for the completion of such repair or restoration.
Lender or its agent may make reasonable entries upon and inspections of the Property. If it has
reasonable cause, Lender may inspect the interior of the improvements on the Property. Lender shall give
Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause.
8. Borrower's Loan Application. Borrower shall be in default if. during the Loan application process,
Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or
consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed to
provide Leader with material information) in connection with the Loan. Material representations include, but
are not limited to, representations concerning Borrower's occupancy of the Property as Borrower's principal
residence.
9. Protection of Lender's Interest in the Property mid Rights Under this Security Instrument. If
(a) Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b) there is
a legal proceeding that might significantly affect Lender's interest in the Property and/or rights under this
Security Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for
enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or
regulations), or (c) Borrower has abandoned the Property, then Lender may do and pay for whatever is
reasonable or appropriate to protect Lender's interest in the Property and rights under this Security
Instrument, including protecting and/or assessing the value of the Property, and securing and/or repairing
the Property. Lender's actions can include, but are not limited to: (a) paying any sums secured by a lien which
has priority over this Security Instrument, (b) appearing in court. and (c) paying reasonable attorneys' fees to
protect its interest in the Property and/or rights under this Security Instrument, including its secured position
in a bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property to
make repairs, change locks, replace or board up doors and windows, drain water from pipes, eliminate
building or other code violations or dangerous conditions, and have utilities turned on or off. Although
Lender may take -action wider this Section 9, Leader does not have to do so and is not under any duty or
obligation to do so. It is agreed that Lender incurs no liability for not taking any or all actions authorized
under this Section 9.
0049256902
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Any amounts disbursed by Leader under this Section 9 shall become additional debt of Borrower
secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of
disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting
payment-
If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease.
If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender
agrees to the merger in writing.
10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan,
Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. If, for any reason,
the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that
previously provided such insurance and Borrower was required to make separately designated payments
toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain coverage
substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to
the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer
selected by Lender. If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall
continue to pay to Lender the amount of the separately designated payments that were due when the insurance
coverage ceased to be in effect. Lender will accept, use and retain these payments as a non-refundable loss
reserve in lieu of Mortgage Insurance. Such loss reserve shall be non-refundable, notwithstanding the fact that
the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings
on such loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in
the amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes
available, is obtained, and Lender requires separately designated payments toward the premiums for Mortgage
Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was
required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower
shall pay the premiums required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss
reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement
between Borrower and Lender providing for such termination or until termination is required by Applicable
Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note.
Mortgage Insurance reimburses Leader (or any entity that purchases the Note) for certain losses it may
incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may
enter into agreements with other parties that share or modify their risk, or reduce losses. These agreements are
on terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these
agreements. These agreements may require the mortgage insurer to make payments using any source of funds
that the mortgage insurer may have available (which may include funds obtained from Mortgage Insurance
premiums).
As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinsures, any
other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive
from (or might be characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange
for sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an
affiliate of Lender takes a share of the insurer's risk in exchange for a share of the premiums paid to the
insurer, the arrangement is often termed "captive reinsurance." Further:
(a) Any such agreements will not affect the amounts that Borrower has agreed to pay for
Mortgage Insurance, or any other terms of the Loan. Such agreements will not Increase the amount
Borrower will owe for Mortgage Insurance, and they will not entitle Borrower to any refund.
0049256902
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(b) Any such agreements will not affect the rights Borrower has - if any - with respect to the
Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights may
include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage
Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any
Mortgage Insurance premiums that were unearned at the time of such cancellation or termination.
11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby
assigned to and shall be paid to Lender.
If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the
Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During
such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until
Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's
satisfaction, provided that such inspection shall be undertaken promptly. Lender may pay for the repairs and
restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an
agreement is made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds,
Lender shall not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the
restoration or repair is not economically feasible or Lender's security would be lessened, the Miscellaneous
Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the
excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in
Section 2.
In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds
shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if
any, paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market
value of the Property immediately before the partial taking, destruction, or loss in value is equal to or greater
than the amount of the sums secured by this Security Instrument immediately before the partial taking,
destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the sums secured by this
Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the
following fraction; (a) the total amount of the stems secured immediately before the partial taking, destruction,
or loss in value divided by (b) the fair market value of the Property immediately before the partial taking,
destruction, or loss in value. Any balance shall be paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market
value of the Property immediately before the partial taking, destruction, or loss in value is less than the
amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless
Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums
secured by this Security Instrument whether or not the sums are then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing
Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails
to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and
apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sums secured by this
Security Instrument, whether or not then due. "Opposing Party" means the third party that owes Borrower
Miscellaneous Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous
Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in
Lender's judgment, could result in forfeiture of the Property or other material impairment of Lender's interest
in the Property or rights under this Security instrument. Borrower can cure such a default and, if acceleration
has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a
ruling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of
0049256902 6iisais: •(S'
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Lender's interest in the Property or rights under this Security Instrument. The proceeds of any award or claim
for damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned
and shall be paid to Lender.
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied
in the order provided for in Section 2.
12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for
Payment or modification of amortization of the sums secured by this Security Instrument granted by Lender
to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or
any Successors in Interest of Borrower. Lender shall not be required to commence proceedings against any
Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization
of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or
any Successors in Interest of Borrower. Any forbearance by Lender in exercising any right or remedy
including, without limitation, Lender's acceptance of payments from third persons, entities or Successors in
Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the
exercise of any right or remedy.
13. Joint and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants and
agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who
cosigns this Security Instrument but does not execute the Note (a "co-signer"): (a) is co-signing this Security
Instrument only to mortgage, grant and convey the co-signer's interest in the Property under the terms of this
Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and
(c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or make any
accommodations with regard to the terms of this Security Instrument or the Note without the co-signers
consent.
Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's
obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of
Borrower's rights and benefits under this Security Instrument. Borrower shall not be released from
Borrower's obligations and liability under this Security Instrument unless Lender agrees to such release in
writing. The covenants and agreements of this Security Instrument shall bind (except as provided in Section
20) and benefit the successors and assigns of Leader.
14. Loan Charges. Lender may charge Borrower fees for services performed in connection with
Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this
Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In
regard to any other fees, the absence of express authority in this Security Instrument to charge a specific fee
to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may net charge fees
that are expressly prohibited by this Security Instrument or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so
that the interest or other loan charges collected or to be collected in connection with the Loan exceed the
permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge
to the permitted limit; and (b) any sutras already collected from Borrower which exceeded permitted limits
will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under
the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be
treated as a partial prepayment without any prepayment charge (whether or not a prepayment charge is
provided for under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower
will constitute a waiver of any right of action Borrower might have arising out of such overcharge.
0049256902 Inieal94?
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15. Notices. All notices given by Borrower or Lender in connection with this Security Instrument must
be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have
been given to Borrower when mailed by first class mail or when actually delivered to Borrower's notice
address if sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless
Applicable Law expressly requires otherwise. The notice address shall be the Property Address unless
Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptly notify
Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change of
address, then Borrower shall only report a change of address through that specified procedure. There may be
only one designated notice address under this Security Instrument at any one time. Any notice to Lender shall
be given by delivering it or by mailing it by first class mail to Lender's address stated herein unless Lender
has designated another address by notice to Borrower. Any notice in connection with this Security Instrument
shall not be deemed to have been given to Lender until actually received by Lender. If any notice required by
this Security Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy
the corresponding requirement under this Security Instrument.
16. Governing Law; Severability; Rules of Construction. This Security Instrument shall be governed
by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations
contained in this Security Instrument are subject to any requirements and limitations of Applicable Law.
Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent, but
such silence shall not be construed as a prohibition against agreement by contract. In the event that any
provision or clause of this Security Instrument or the Note conflicts with Applicable Law, such conflict shall
not affect other provisions of this Security Instrument or the Note which can be given effect without the
conflicting provision.
As used in this Security Instrument: (a) words of the masculine gender shall mean and include
corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and
include the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to take
any action.
17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument.
18. Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18,
"Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited to,
those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow
agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser.
If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is
not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written
consent, Lender may require immediate payment in full of all sums secured by this Security Instrument.
However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall
provide a period of not less than 30 days from the date the notice is given in accordance with Section 15
within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these
sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security
Instrument without further notice or demand on Borrower.
19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions,
Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior
to the earliest of: (a) five days before sale of the Property pursuant to any power of sale contained in this
Security Instrument; (b) such other period as Applicable Law might specify for the termination of Borrower's
right to reinstate; or (c) entry of a judgment enforcing this Security Instrument. Those conditions are that
Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as
if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all
0049256902 nrua?r??
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expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys'
fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's
interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may
reasonably require to assure that Lender's interest in the Property and rights under this Security Instrument,
and Borrower's obligation to pay the sums secured by this Security Instrument, shall continue unchanged.
Lender may require that Borrower pay such reinstatement sums and expenses in one or more of the following
forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or
cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal
agency, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this
Security Instrument and obligations secured hereby shall remain fully effective as if no acceleration had
occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18.
20. Sale of Note; Change of Loan Servicer, Notice of Grievance. The Note or a partial interest in the
Note (together with this Security Instrument) can be sold one or more times without prior notice to Borrower.
A sale might result in a change in the entity (known as the "Loan Servicer") that collects Periodic Payments
due under the Note and this Security Instrument and performs other mortgage loan servicing obligations
under the Note, this Security Instrument, and Applicable Law. There also might be one or more changes of
the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be
given written notice of the change which will state the name and address of the new Loan Servicer, the
address to which payments should be made and any other information RESPA requires in connection with a
notice of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other
than the purchaser of the Note, the mortgage loan servicing obligations to Borrower will remain with the
Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser
unless otherwise provided by the Note purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an
individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security
Imtntment or that alleges that the other party has breached any provision of, or any duty owed by reason of,
this Security Instrument, until such Borrower or Lender has notified the other party (with such notice given in
compliance with the requirements of Section 15) of such alleged breach and afforded the other party hereto a
reasonable period after the giving of such notice to take corrective action. If Applicable law provides a time
period which must elapse before certain action can be taken, that time period will be deemed to be reasonable
for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant
to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to
satisfy the notice and opportunity to take corrective action provisions of this Section 20.
21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those
substances deemed as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the
following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and
herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials; (b)
*Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate
to health, safety or environmental protection; (c) "Environmental Cleanup" includes any response action,
remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental Condition"
means a condition that can cause, contribute to, or otherwise trigger an Environmental Cleanup.
0049256902 .a5-(:f
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Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous
Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do,
nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental
Law, (b) which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a
Hazardous Substance, creates a condition that adversely affects the value of the Property. The preceding two
sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous
Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of
the Property (including, but not limited to, hazardous substances in consumer products).
Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit or
other action by any governmental or regulatory agency or private party involving the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any
Environmental Condition, including but not limited to, any spilling, leaking, discharge, release or threat of
release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a
Hazardous Substance which adversely affects the value of the Property. If Borrower learns, or is notified by
any governmental or regulatory authority, or any private party, that any removal or other remediation of any
Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial
actions in accordance with Environmental Law. Nothing herein shall create any obligation on Lender for an
Environmental Cleanup.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following
Borrower's breach of any . covenant or agreement in this Security Instrument (but not prior to
acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower
of, among other things: (a) the default; (b) the action required to cure the default; (c) when the default
must be cured; and (d) that failure to cure the default as specified may result in acceleration of the
sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property.
Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert
In the foreclosure proceeding the non-existence of a default or any other defense of Borrower to
acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require
immediate payment in full of all sums secured by this Security Instrument without further demand and
may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all
expenses incurred in pursuing the remedies provided in this Section 22, including, but not limited to,
attorneys' fees and costs of title evidence to the extent permitted by Applicable Law.
23. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument
and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and
satisfy this Security Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee
for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the
charging of the fee is permitted under Applicable Law.
24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or
defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or
future laws providing for stay of execution, extension of time, exemption from attachment, levy and We. and
homestead exemption.
25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour
prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument.
26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to
Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under
the Note.
0049256902 1*191iP
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BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this
Security Instnunent and in any Rider executed by Borrower and recorded with it.
Witnesses:
_ (Seal)
-Borrower
_ (Seal)
Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
0049256902
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DUKI(1873PG2729
Certificate of Residence
I,
the correct address of the within-named Mortgagee is
4000 HORIZON WAY, IRVING, T% 75063
Witness my hand this day of
, do hereby certify that
Agent of Mortgagee
COMMONWEALTH OF PENNSYLVANIA, County ss:
e4 , CUIMBRLAM
day of 0 w before me, the
On this, the
undersigned officer, personally appeared
RICHARD G =@ORY a???-tri G? M^aI%
known to me (or
satisfactorily proven) to be the person(s) whose name(s) is/are subscribed to the within instrument and
acknowledged that he/she/they executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My Commission Expires:
NOTARIAL SEAL
JAMES A. MILLER, Notary Public
Boro of Camp Hill, Cumberland County, PA
My Commission Expires April 30, 2005
0049256902
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wnagzee
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Form 3039 1101
Schedule C Legal Description IA 2004-233-C
ALL THAT- CERTAIN lot situate in the Borough of Wormleysburg, Cumberland
County, Pennsylvania, on the Plan of Lots of Riverview, as recorded in the office of
the Recorder of Deeds in and for the County of Cumberland in Plan Book No. 11,
page 9 and being subject to utility easements and building and use conditions and
restrictions of record, described as follows:
Lot 28 Section "D" BEGINNING at a point where the division line between lots
twenty-seven (27) and twenty-eight (28) intersects with the westerly side of Old
Orchard Circle; thence zero degrees (00% thirty-eight (38) minutes fifty-eight (58)
seconds east, along the westerly side of Old Orchard Circle, twenty-two and three-
hundredth (22.03) feet to a point of curvature; thence continuing along the curving
westerly side of Old Orchard Circle, in an arc created by a fifty (50) foot radius, a
distance of twenty-six and eighty-seven (26.8'1) feet to a point; thence south fifty-
eight (S8) degrees, thirty-three (33) minutes and thirty-six seconds west, along the
division line between lots twenty-eight (28) and twenty-nine (29), a distance of one-
hundred and ninety-nine hundredth (100.99) East to a point; thence north thirty-six
(36) degrees thirty (30) minutes west, thence along the division line of lots eighteen
(18).and nineteen (19) and lot twenty-eight (28), a distance of ninety-seven and
eighty-eight hundredths (97.88) feet to a point; thence north twenty-five (25) degrees
forty-nine (49) minutes three (03) seconds east, along the division line between lots
twenty-six (26) and lot twenty-eight (28), a distance thirty-nine and forty-eight
hundredths (39.48) feet to a point; thence north eighty-nine (89) degrees twenty-one
(21) minutes two (02) seconds east, along the division line between lots twenty-seven
(27) and twenty-eight (28), a distance of one hundred forty-five and twenty-one
hundredths (145.21) feet to a point the place of BEGINNING.
Parcel M #: 47-18-1302-113
OK ! 873PG273 I
ADJUSTABLE RATE RIDER
(6-Month LIBOR Index - Rate Caps)
(Assumable during Life of Loan) (T<irst Business Day of Preceding Month Lookback)
THIS ADJUSTABLE RATE RIDER is made this 9th day of July, 2004 ,
and is incorporated into and shall be deemed to amend and supplement the Mortgage,
Deed of Trust, or Security Deed (the "Security Instrument') of the same date given by the
undersigned (the "Borrower") to secure the Borrower's Adjustable Rate Note (the "Note") to
FIRST HORIZON HOME LOAN CORPORATION
(the 'Lender") of the same date and covering the property described in the Security
Instrument and located at:
50 OLD ORCHARD CIRCLE
CAMP HILL, Pennsylvania 17011
[Property Address]
THE NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN THE
INTEREST RATE AND THE MONTHLY PAYMENT. THE NOTE LIMITS THE
AMOUNT THE BORROWER'S INTEREST RATE CAN CHANGE AT ANY
ONE TIME AND THE MAXIMUM RATE THE BORROWER MUST PAY.
ADDITIONAL COVENANTS. In addition to the covenants and agreements made in the
Security Instrument, Borrower and Lender further covenant and agree as follows:
A. INTEREST RATE AND MONTHLY PAYMENT CHANGES
The Note provides for an initial interest rate of 7.900 °?. The Note
provides for changes in the interest rate and the monthly payments, as follows:
4. INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Dates
The interest rate I will pay may change on the first day of August, 2006 ,
and may change on that day every sixth month thereafter. Each date on which my interest
rate could change is called a "Change Date."
0049256902
MULTISTATE ADJUSTABLE RATE RIDER 6-Month LIBOR Index (Assumable during
Life of Loan) (First Business Day Lookback) - Single Family - Freddie Mac UNIFORM
INSTRUMENT
-815R (0404) Form 51M-
Page 1 of 4 Initials: 6 "Mill
VMP Mortgage Solutions
(800)521-7291 loin
BK 1873PG2732
(B) The Index
Beginning with the first Change Date, my interest rate will be based on an Index. The
"Index" is the six month London Interbank Offered Rate ("LIBOR") which is the average of
interbank offered rates for six-month U.S. dollar-denominated deposits in the London
market, as published in The Wall Street Journal . The most recent Index figure available as
of the first business day of the month immediately preceding the month in which the Change
Date occurs is called the `Current Index."
If the Index is no longer available, the Note Holder will choose a new index which is
based upon comparable information. The Note Holder will give me notice of this choice.
(C) Calculation of Changes
Before each Change Date, the Note Holder will calculate my new interest rate by
adding
percentage point(s) ( 5.300 %) to the Current Index. The Note Holder will then
round the result of this addition to the nearest one-eighth of one percentage point (0.1251/0).
Subject to the limits stated in Section 4(D) below, this rounded amount will be my new
interest rate until the next Change Date.
The Note Holder will then determine the amount of the monthly payment that would be
sufficient to repay the unpaid principal that 1 am expected to owe at the Change Date in full
on the maturity date at my new interest rate in substantially equal payments. The result of
this calculation will be the new amount of my monthly payment.
(D) Limits on Interest Rate Changes
The interest rate I am required to pay at the first Change Date will not be greater than
10.900 % or less than 7.900 %. Thereafter, my interest rate will
never be increased or decreased on any single Change Date by more than
ONE & 00/100 percentage point(s) ( 1.00 (/16) from the rate of
interest I have been paying for the preceding six months. My interest rate will never be
greater than 14.900 %•
(E) Effective Date of Changes
My new interest rate will become effective on each Change Date. I will pay the amount
of my new monthly payment beginning on the first monthly payment date after the Change
Date until the amount of my monthly payment changes again.
(F) Notice of Changes
The Note Holder will deliver or mail to me a notice of any changes in my interest rate
and the amount of my monthly payment before the effective date of any change. The notice
will include information required by law to be given to me and also the title and telephone
number of a person who will answer any question I may have regarding the notice.
0049256902
at-815R (0404)
Initials
Page 2 of 4 Form 5120 3104
ov I S73PG2733
I
B. TRANSFER OF THE PROPERTY OR A BENEFICIAL INTEREST IN BORROWER
Section 18 of the Security Instrument is amended to read as follows:
Transfer of the Property or a Beneficial Interest In Borrower. As used in
this Section 18, 'Interest in the Property" means any legal or beneficial interest in
the Property, including, but not limited to, those beneficial interests transferred in a
bond for deed, contract for deed, installment sales contract or escrow agreement,
the intent of which is the transfer of title by Borrower at a future date to a
purchaser.
If all or any part of the Property or any Interest in the Property is sold or
transferred (or it Borrower is not a natural person and a beneficial interest in
Borrower is sold or transferred) without Lender's prior written consent, Lender may
require immediate payment in full of all sums secured by this Security Instrument.
However, this option shag not be exercised by Lender if such exercise is prohibited
by Applicable Law. Lender also shag not exercise this option d: (a) Borrower
causes to be submitted to Lender information required by Lender to evaluate the
intended transferee as if a new loan were being made to the transferee; and (b)
Lender reasonably determines that Lender's security will not be impaired by the
loan assumption and that the risk of a breach of any covenant or agreement in this
Security Instrument is acceptable to Lender.
To the-extent permitted by Applicable Law, Lender may charge a reasonable
fee as a condition to Lender's consent to the loan assumption. Lender may also
require the transferee to sign an assumption agreement that is acceptable to
Lender and that obligates the transferee to keep all the promises and agreements
made in the Note and in this Security Instrument. Borrower will continue to be
obligated under the Note and this Security Instrument unless Lender releases
Borrower in writing.
If Lender exercises the option to require immediate payment in fug, Lender
shall give Borrower notice of acceleration. The notice shall provide a period of not
less than 30 days from the date the notice is given in accordance with Section 15
within which Borrower must pay all sums secured by this Security Instrument. If
Borrower fails to pay these sums prior to the expiration of this period, Lender may
invoke any remedies permitted by this Security Instrument without further notice or
demand on Borrower.
0049256902
at-815R (0404) Page 3 of 4
Initials:4 r-
Form 5120 3104
6R 1873PG2734
BY SH
contained in
G =WRY
0049256902
Ct-815R (0404)
Page 4of4
____ (Seal)
-Borrower
- (Seal)
-Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
Form 5120 3104
I Certify this to be i-cu >rdec;
In Cumberland County PA
i?, sib ? j' i.•.: ?_ - - °. r.,-.
n • r_•, i? d y;J
G
Recorder of Deeds
ON, t 873PG2735
accepts and agrees to the terms and covenants
(Seal)
-Borrower
_ (Seal)
-Borrower
(Seal)
-Borrower
(Seal)
-Borrower
EXHIBIT `B'
?pY
0049256902
ADJUSTABLE RATE NOTE
(LIBOR Index - Rate Caps)
THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE
AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE
CAN CHANGE AT ANY ONE TIME AND THE MAXIMUM RATE 1 MUST PAY.
JuLy 9th, 2004 CAMP HILL PENNSYLVANIA
[Date[ [City] [State]
50 OLD ORCHARD CIRCLE, CAMP HILL, Pennsylvania 17011
IProleny Addteal
1. BORROWER'S PROMISE TO PAY
In return for a loan that I have received, I promise to pay U.S. $ 135, 900.00 (this amount is called
"Principal"), plus interest, to the order of the Lender. The Lender is
FEItST HORIZON HOME LOAN CORPORATION
I will make all payments under this Note in the form of cash, check or money order.
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled
to receive payments under this Note is called the "Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly
rate of 7.900 %. The interest rate I will pay may change in accordance with Section 4 of this Note.
The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both before and after any default
described in Section 7(B) of this Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making a payment every month.
I will make my monthly payments on the fist day of each month beginning on SRPTMWER 1st, 2 004
I will make these payments every month until I have paid all of the principal and interest and any other charges
described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be
applied to interest before Principal. If, on AUGUST 1, 2034 , I still owe amounts under this Note, I
will pay those amounts in full on that date, which is called the "Maturity Date."
I will make my monthly payments at P.O. BOX 146
KDWHIS, TN 38101
or at a different place if required by the Note Holder.
(B) Amount of My Initial Monthly Payments
Each of my initial monthly payments will be in the amount of U.S. $
987.73 .This amount may change.
(C) Monthly Payment Changes
Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate that I must pay.
The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance with Section
4 of this Note.
MULTISTATE ADJUSTABLE RATE NOTE - LIBOR INDEX - Single Family - Freddie Mae UNIFORM INSTRUMENT Fort. 85901101
100-815N toztW
Pap91 p(4 VAAP MORTGAGE FORMS - (800)621-729 /`=? ? I I lime ? Will
4. INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Dates
The interest rate I will pay may change on the first day of AUGUST, 2006 , and on that day every sixth
ninth thereafter. Each date on which my interest rate could change is called a "Change Date."
(B) The Index
Beginning with the first Change Date, my interest rate will be based on an Index. The "Index* is the average of interbank
offered rates for six-month U.S. dollar-denominated deposits in the London market ("LIBOR"), as published in The Wall Street
Journal. The most recent Index figure available as of the first business day of the month immediately preceding the month in which
the Change Date occurs is called the "Current Index."
If the Index is no longer available, the Note Holder will choose a new index that is based upon comparable information. The
Note Holder will give me notice of this choice.
(C) Calculation of Changes
Before each Change Date, the Note Holder will calculate my new interest rate by adding
percentage points ( 5.300 %) to the Current Index. The Note Holder will
them round the result of this addition to the wrest one-eighth of one percentage point (0.125%). Subject to the limits stated in
Section 4(D) below, this rounded amount will be my new interest rate until the next Change Date.
The Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpaid principal
that I am expected to owe at the Change Date in full on the Maturity Date at my new interest rate in substantially equal payments.
The result of this calculation will be the new amount of my monthly payment.
(D) Limits on Interest Rate Changes
The interest rate I am required to pay at the first Change Date will not be greater than 10.900 % or less
than 7.900 %. Thereafter, my interest rate will never be increased or decreased on any single Change Date by
more than one percentage point (1 %) from the rate of interest I have been paying for the preceding six months. My interest rate
will never be greater than 14.900 %.
Q Effective Date of Changes
My new interest rate will become effective on each Change Date. I will pay the amount of my new monthly payment beginning
on the first monthly payment date after the Change Date until the amount of my monthly payment changes again.
(F) Notice of Changes
The Note Holder will deliver or mail to me a notice of any changes in my interest rate and the amount of my monthly payment
before the effective date of any change. The notice will include information required by law to be given to me and also the title and
telephone number of a person who will answer any question I may have regarding the notice.
5. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of Principal at any time before they are duce. A payment of Principal only is known as a
"Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment
as a Prepayment if I have not made all the monthly payments due under the Note.
I may make a full Prepayment or partial Prepayments without paying any Prepayment charge. The Note Holder will use my
Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to
the accrued and unpaid interest on the Prepayment amount before applying my Prepayment to reduce the Principal amount of the
Note. If I make a partial Prepayment, there will be no changes in the due dates of my monthly payments unless the Note Holder
agrees in wry to those changes. My partial Prepayment may reduce the amount of my monthly payments after the first Change
Date following my partial Prepayment. However, any reduction due to my partial Prepayment may be offset by an interest rate
increase.
6. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan
charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be
reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which
exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe
under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial
Prepayment.
0049256902
4D.-815N (wie)
Page 2d4
Form /Oi
7. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charges for Overdue Payments
If the Note Holder has trot received the full amount of any monthly payment by the end of 15 calendar days after
the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.00 %
of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.
(C) Notice of Default
If I am in default, the Note Holder may send the a written notice telling me that if I do not pay the overdue amount by a certain
date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest
that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by
other means.
(D) No Waiver By Note Holder
Even if, at a time I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note
Holder will still have the right to do so if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay in full as described above, the Note Holder will have the right to be paid back by me
for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for
example, reasonable attorneys' fees.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note
Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class
[nail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different
address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this
Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also
obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or
endorser of this Note, is also obligated to keep all of the promises trade in this Note. The Note Holder may enforce its rights under
this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of
the amounts owed under this Note.
10. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor.
"Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the
right to require the Note Holder to give notice to other persons that amounts due have not been paid.
11. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note
Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"), dated the same date as this Note,
protects the Note Holder from possible losses which might result if I do not keep the promises that I make in this Note. That
Security Instrument describes how and under what conditions I may be required to [Hake immediate payment in full of all amounts
I owe under this Note. Some of those conditions are described as follows:
fj?
0049256902 ?uiitlals:
®,816N (pm) Pape 3 d 4
Transfer of the Property or a Beneficial Interest In Borrower. If all or any part of the Property or any Interest in
the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or
transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured
by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by
Applicable Law. Lender also shall not exercise this option if. (a) Borrower causes to be submitted to Lender information
required by Lender to evaluate the intended transferee as if a new loan were being made to the transferee; and (b) Lender
reasonably determines that Lender's security will not be impaired by the loan assumption and that the risk of a breach of
any covenant or agreement in this Security Instrument is acceptable to Lender.
To the extent permitted by Applicable Law, Lender may charge a reasonable fee as a condition to Lender's consent
to the loan assumption. Lender may also require the transferee to sign an assumption agreement that is acceptable to
Lender and that obligates the transferee to keep all the promises and agreements made in the Note and in this Security
Instrument. Borrower will continue to be obligated under the Note and this Security Instrument unless Lender releases
Borrower in writing.
If Lender exercises the option to require immediate payment in full, Lender shall give Borrower notice of
acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance
with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay
these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument
without further notice or demand on Borrower.
WITNESS THE
SNARY
THE UNDERSIGNED.
(Seal)
-Borrower
(Seal)
-Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
(Seal)
-Borrower
-(Seal)
-Borrower
(Seal)
-Borrower
(Seal)
-Borrower
[Sign Original Only]
0049256902
-315N (0210) Pape 4 of 4 Form 35901101
0049256902
PREPAYMENT PENALTY ADDENDUM TO NOTE
THIS PREPAYMENT PENALTY ADDENDUM TO NOTE is made this 9th day of July ,
2004 and is incorporated into and shall be deemed to amend and supplement the Note made by the undersigned
(the "Borrower"), in favor of FIRST HORIZON HOME LOAN CORPORATION
(the "Lender") and dated the same date as
this Addendum (the "Note"). The Note is secured by a security instrument, as modified or amended in
favor of Lender dated the 9th day of July , 2004 (the "Security Instrument").
ADDITIONAL COVENANTS. In addition to the covenants and agreements made in the Note, Borrower
and Lender further covenant and agree as follows:
Any provisions of said Note, or other such instruments executed in connection with said indebtedness
which are inconsistent with the provisions of this Addendum, including, but not limited to, monthly
payments of principal and interest, maturity date and notice to the Borrower are hereby amended or
negated to the extent necessary to conform such instruments to the provisions of this Addendum.
The final Note payment shall be due and payable on August lot, 2034
The following notice is given to the Borrower as part of this loan contract pursuant to Federal regulations:
S. BORROWER'S RIGHT TO PREPAY
PROVISIONS FOR PREPAYMENT PENALTY
Consecutive monthly principal and interest installments are due with a first due date on the lot day
of September , 2004 . Such payments to continue until maturity when the remaining principal
balance and any unpaid interest thereon shall be due and payable. In the event full or partial prepayment
is made within two (2) years of the date of the first monthly payment, a prepayment penalty
in the amount of 2.00 % of the remaining principal balance will be assessed if allowable by applicable
state or federal law.
BY SIGNING BELOW, Borrower accepts
Prepayment Penalty A_40tndum to Note.
reel to the terms and provisions contained in this
RICHARD Q EMORY
Borrower
Borrower
Borrower
Borrower
Borrower
Borrower
Borrower
Mu ff-prpayment petty Page I of I F116D837
Addendum to ARM Note (Single Family)
1 1
# 0049256902
Al(onge to Note
For valuable consideration, without recourse, the undersigned hereby endores
to:
All of his/her rights, title and interest in and to the attached Note dated 7/9/2004
In the amount of $135,900.00
Executed by RICHARD G EMORY
Said Note is secured by a Mortgage/Deed of Trust of the same date on real
property located at:
50 OLD ORCHARD CIRCLE
CAMP HILL PA 17011
First Horizon Home Loan Corporation d/b/a First Horizon Lending Center
Susan Long
Divisional Vice President
EXHIBIT ` 5
EMC Mortgage Corporation
PO Box 141358
Irving, TX 75014-1358
NMI
I III III III
,.o, 5400 zoo .=,a 6503
January 29, 2008
IRichard Emory
50 Old Orchard Cir
Camp Hill, PA 17011-1826
EMC Re: Loan No: 0008456162
Mortgage Property Address: 50 Old Orchard Cir
Corporation Camp Hill, PA 17011-1826
ACT 91 N TICE
TAKE ACTI N T SAVE YOUR
HOME FRO 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.
IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR
The Homeowners' Emergency 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, 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.
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling
Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able
to help you find a lawyer.
La Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el
contenido de esta notificion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency)
sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowners' Emergency
Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCOUNT NUMBER:
CURRENT SERVICER
Richard Emory
50 Old Orchard Cir
Camp Hill, PA 17011-1826
0008456162
EMC Mortgage Corporation
Page two 0008456162
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 provision of the Homeowners' 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 the 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 thirty (30)
days. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE
UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW
TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the
end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names,
addresses and telephone numbers of designated consumer credit counselingaQencies for the county in which your property is located
are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise this 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 Homeowners' Emergency Mortgage Assistance Program.
To do so, you must fill out, sign and file a completed Homeowners' Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have
applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE
OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision
after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistance)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date):
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 50 Old Orchard Cir
Camp Hill, PA 17011-1826 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due:
(a) Monthly payments from 06/01/2007: $11,607.90
(b) Late charge(s): $98.78
(c) Other charge(s): NSF and Advances $1,233.59
(d) Less: Credit Balance $0.00
(e) Total amount required as of 01/28/2008: $12,940.27
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable):
HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY
PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $12,940.27, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES (and other 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 to EMC Mortgage Corporation at Po Box
660530 Dallas, TX 75266-0530.
.Page three 0008456162
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the
lender intends to exercise its right 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, EMC Mortgage Corporation also intends to instruct their attorneys to start
a 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 you cure the delinquency before they begin 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 are over $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 attorneys' 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, charges then
due, reasonable attorneys' 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 Sheriffs Sale of the mortgaged
proprty could be held would be approximately five (5) months from the date of this Notice. A notice of the actual date of the
Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER
Name of Lender: EMC Mortgage Corporation
Address: Po Box 660530 Dallas, TX 75266-0530
Telephone Number: 1-888-609-2379
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 furniture and
other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage
debt, provided that all the outstanding payments, charges and attorneys' 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. (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.
Page four 0008456162
EMC Mortgage Corporation is attempting to collect a debt, and any information obtained will be used for that purpose.
Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you
dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address below
within the thirty day period that the debt, or any portion thereof, is disputed, we will:
1) Provide to you verification of the debt or a copy of any judgment entered against you.
2) Provide to you the name and address of your original creditor, if the original creditor is different from the current
creditor.
Sincerely,
EMC Mortgage Corporation
EMC Mortgage Corporation Po Box 660530 Dallas, TX 75266-0530, 1-888-609-2379
Appendix B
Consumer Credit Counseling Agency
Notification To:
Name of Mortgagee:
Address:
In accordance with the Pennslyvania Homeowner's Emergency Mortgage Assistance Program (Act 91 of 1983), we have been
approached for mortgage counseling assistance by:
Name of Applicant
Address
Telephone Number
Mortgage Loan Number
Address of property on which mortgage is in default,
If different from above.
The counseling agency met with the above named applicant on
Date
Who have indicated that they are more than sixty (60) days delinquent on their mortgage payments and have received notification to
foreclosure from:
Name and Address of Mortgage
In accordance with the Homeowner's Emergency Mortgage Assistance Program, this is to inform you that:
1. If the delinquency cannot be resolved with in the 30 day forbearance period as provided by the Servicer, the applicant
listed above may apply to the Pennsylvania Housing Finance Agency for Homeowner's Emergency Mortgage Assistance.
2. By a copy of this Notice, we are notifying all other mortgagees, if any, which the applicant has indicated as also having a
mortgage on the property identified above.
3. It is our understanding that the 30 day forbearance period in which we are now in ends on
4. No legal action to enforce the mortgage may occur during this forbearance period, unless procedural time limits were not
met by the homeowner.
' Indicates Counties Serviced
Acorn Housing Corporation
846 North Broad Street
Philadelphia, PA 19130
(215) 765-1221
*Bucks, Chester, Delaware, Montgomery,
Philadelphia
Americon Financial Counseling Services
1 Abington Plaza, Suite 403
Old York Road and Township Line
Jenkintown, PA 19046
(800) 490-3039
`Delaware, Montgomery
Action Housing Inc American Financial Counseling Services
425 6th Avenue, Suite 950 175 Strafford Avenue, Suite One
Pittsburgh, PA 15219 Wayne, PA 19087
(412) 281-2102 800) 490-3039
*Allegheny, Beaver, Butler, Fayette, Greene, *Bucks, Chester, Delaware, Mongomery,
Washington, Westmoreland Philadelphia
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
(717) 334-1518
*Adams, Cumberland, Franklin, York
American Financial Counseling Services
906 Penn Avenue
Wyomissing, PA 19610
(610) 780-0680
*Berks
Advocates for Financial Independence
1806 S Broad Street, Suite 1 B
Philadelphia, PA 19145
(215) 389-2810
*Philadelphia
Allegheny County Acorn
5907 Penn Avenue, Suite 300
Pittsburgh, PA 15206
(412) 441-6551
*Allegheny
American Credit Counseling Institute
21 S Church Street
West Chester, PA 19380
(888) 212-6741
*Chester
American Credit Counseling Institute
300 North Pottstown Pike, Suite 210
Exton, PA 19341
(888) 212-6741
*Berks, Bucks, Montgomery
American Credit Couseling Institute
528 Dekalb Street
Norristown, PA 19401
(610) 971-2210
*Montgomery
American Credit Counseling Institute
530 W Street Road, Suite 201
Warminster, PA 18974
(215) 444-9429
*Bucks, Montgomery, Philadelphia
American Credit Counseling Institute
1345 Coates Street
Coatesville, PA 19320
(888) 212-6741
*Bucks, Chester, Montgomery, Philadelphia
American Credit Counseling Institute
937 North Hanover Street
Pottstown, PA 19460
(888) 212-6741
*Berks, Bucks, Montgomery
American Red Cross - Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
(717) 637-3768
*Adams, Franklin, York
American Red Cross of Chester
1729 Edgemont Avenue
Chester, PA 19013
(610) 874-1484
*Chester, Delaware
APM
2147 Norht Sixth Street
Philadelphia, PA 19122
(215) 235-6788
*Chester, Delaware, Philadelphia
Armstrong CO Community Action Agency
124 Armsdale Road, Suite 211
Kittanning, PA 16201
(724) 548-3405
`Armstrong
Blair County Community Action Agency
2100 6th Avenue, Suite 102
P.O. Box 1833
Altoona, PA 16602
(814) 946-3651
*Blairl
Booker T. Washington Center
1720 Holland Street
Erie, PA 16503
(814) 453-5744
*Crawford, Erie, Warren
Bucks County Housing Group
200 West Bridge Street
Morrisville, PA 19067
(866) 866-0280
*Bucks
Bucks County Housing Group
2324 Second Street Pike, Suite 17
Wrightstown, PA 18940
(866) 866-0280
*Bucks
Bucks County Housing Group
349 Durham Road
Penndel, PA 19047
(866) 866-0280
*Bucks
Bucks County Housing Group
470 Old Dublin Pike
Doylestown, PA 18901
(866) 866-0280
*Bucks
Bucks County Housing Group
515 West End Blvd
Quakertown, PA 18951
(866) 866-0280
*Bucks
Budget Counseling Center
247 North Fifth Street
Reading, PA 19601
(610) 375-7866
*Berks, Chester, Schuylkill
Carroll Park Community Council, Inc.
5218 Master Street
Philadelphia, PA 19131
(215) 877-1157
*Chester, Delaware, Philadelphia
CCCS of Delaware Valley
1230 New Rodgers Road, Suite F1
Bristol, PA 19007
(215) 563-5665
*Bucks
CCCS of Delaware Valley
1515 Market Street, Suite 1325
Philadelphia, PA 19107
(215) 563-5665
*Bucks, Delaware, Montgomery, Philadelphia
CCCS of Delaware Valley
1777 Sentry Parkway W, Suite 200
Blue Bell, PA 19422
(215) 563-5665
*Montgomery
CCCS of Delaware Valley
280 North Providence Road
Media, PA 19063
(215) 563-5665
`Delaware
CCCS of Delaware Valley
Marshal Building
790 E Market St, Suite 170
West Chester, PA 19382
(215) 563-5665
*Chester, Delaware
CCCS of Delaware Valley
Catholic Social Services Building
7340 Jackson Street
Philadelphia, PA 19136
(215) 563-5665
*Bucks, Philadelphia
CCCS of Delaware Valley
One Cherry Hill, Suite 215
Cherry Hill, PA 08002
(215) 563-5665
*Philadelphia
CCCS of Lehigh Valley
3671 Crescent Court East
Whitehall, PA 18052
(610) 821-4011
*Berks, Bucks, Carbon, Lancaster, Lehigh,
Northhampton, Schuylkill
* Indicates Counties Serviced
CCCS of Northeastern PA
1400 Abington Exec. Park, Suite 1
Clarks Summitt, PA 18411
(570) 587-9163
*Carbon, Columbia, Lackawanna Lycoming,
Monroe, Montour, Northumberland, Pike,
Sullivan, Tioga, Union, Wayne, Wyoming
CCCS of Northeastern PA
201 Basin Street, Suite 6
Williamsport, PA 17701
(570) 323-6627
*Centre, Clinton, Lycoming, Northumberland,
Union
CCCS of Northeastern PA
202 W Hamilton Avenue
State College, PA 16801
(814) 238-3668
*Blair, Centre, Clearfield, Clinton, Huntingdon,
Juniata, Mifflin
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
(570) 602-2227
*Bradford, Carbon, Columbia, Lackawanna,
Lycoming, Monroe, Montour, Northumberland,
Pike, Sullivan, Tioga, Union, Wayne, Wyoming
CCCS of Northeastern PA
411 Main Street, Suite 104
Stroudsburg, PA 18360
(570) 420-8980
*Bradford, Carbon, Monroe, Pike, Wayne
CCCS of Western PA
1 North Gate Square #2
Garden Center or
Greensburg, PA 15601
(888) 511-2227
*Fayette, Greene, Indiana, Somerset,
Washington, Westmoreland
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
(888) 511-2227
*Adams, Cumberland, Dauphin, Franklin, Perry,
Synder, York
CCCS of Western PA
219-A College Park Plaza
Johnstown, PA 15904
(888) 511-2227
*Cambria, Clearfield, Indiana, Somerset
CCCS of Western PA
312 Chestnut Street, Suite 227
Meadville, PA 16335
(888) 511-2227
`Lawrence
CCCS of Western PA
41 East Chestnut Street
Washington, PA 15301
(888) 511-2227
`Washington
CCCS of Western PA
4402 Peach Street
Erie, PA 16509
(888) 511-2227
*Crawford, Erie, Warren
CCCS of Western PA
524 Franklin Avenue
Aliquippa, PA 15001
(888) 511-2227
*Cameron
CCCS of Western PA
917 A Logan Boulevard
Altoona, PA 16602
(888) 511-2227
*Armstrong, Bedford, Blair, Cambria, Centre,
Clearfield, Huntingdon, Juniata, Mifflin, Union
CCCS of Western PA
971 Third Street
Beaver, PA 15009
(888) 511-2227
*Beaver
CCCS of Western PA
Colonial Shopping Center
970 S George Street
York, PA 17403
(888) 511-2227
*Franklin, Fulton, Lancaster, York
CCCS of Western PA
Pullman Commerce Center
112 Hollywood Dr
Butler, PA 16001
(888) 511-2227
*Butler, Clarion, Jefferson, Mercer, Venango
CCCS of Western PA
River Park Commons
2403 Sidney Street
Pittsburgh, PA 15203
(888) 511-2227
*Allegheny
Chester Community Improvement Project
412 Avenue of the States
P.O. Box 541
Chester, PA 19016
(610) 876-8663
*Chester, Delaware, Montgomery, Philadelphia
Comm. On Ecen Opportunity of Luzeme Co.
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 826-0510
*Carbon, Luzeme, Schuylkill, Wyoming
Community Action Commission of Capital
Region
1514 Derry Street
Harrisburg, PA 17094
*Cumberland, Dauphin, Franklin, Perry, Synder
Community Action Committee of the Lehigh
Valley
1337 East Fifth Street
Bethlehem, PA 18015
(610) 691-5620
*Berks, Carbon, Lehigh, Monroe, Northhampton
Community Action Development Comm -
CADCOM
113 E Main Street
Norristown, PA 19401
(610) 277-6363
*Montgomery
Community Action Southwest
150 W Beau Street, Suite 304
Washington, PA 15301
(724) 225-9550
*Washington
Community Action Southwest
58 E Greene Street
Waynesburg, PA 15370
(724) 852-2893
*Allegheny, Fayette, Greene, Washington,
Westmoreland
Congreso
216 West Somerset Street
Philadelphia, PA 19133
(215) 763-8870
*Philadelphia
Council of Spanish Speaking Organization
705-09 North Franklin St
Philadelphia, PA 19123
(215) 627-3100
*Philadelphia
Diversified Community Service
Dixon House
1920 South 20th Street
Philadelphia, PA 19145
(215) 336-3511
*Bucks, Chester, Delaware, Philadelphia
Fair Housing Partnership of Greater Pittsburgh,
Inc.
2840 Liberity Ave., Suite 205
Pittsburgh, PA 15222
(412) 391-2535
*Allegheny
Fayette Co. Community Action Agency Inc
137 North Beeson Avenue
Uniontown, PA 15401
(724) 437-6050
*Fayette, Somerset
FOB CDC
1201 West Only Avenue
Philadelphia, PA 19141
(215) 549-8755
*Bucks, Chester, Delaware, Philadelphia
Frankford CDC
4625 Frankford Avenue, 2nd Floor
Philadelphia, PA 19124
(215) 743-9201
*Philadelphia
Garfield Jubilee Associates
5138 Penn Avenue
Pittsburgh, PA 15224
(412) 665-5200
*Allegheny
Germandtown Settlement
5538 Wayne Avenue Bldg C
Philadelphia, PA 19144
(215) 849-3104
*Bucks, Chester, Delaware, Montgomery,
Philadelphia
* Indicates Counties Serviced
Greater Erie Commun. Action Committee
18 West 9th Street
Erie, PA 16501
(814) 459-4581
'Crawford, Erie, Venango, Warren
HACE
167 W Allegheny Ave., 2nd Floor
Philadelphia, PA 19140
(215) 426-8025
'Bucks, Chester, Delaware, Philadelphia
Koren Comm. Develop. Services Center
6055 Norht 5th Street
Philadelphia, PA 19120
(215) 276-8830
'Philadelphia
Lawrence County Social Services, Inc.
241 West Grant Street
P.O. Box 189
New Castle, PA 16103
(724) 658-7258
'Lawrence
New Life Comm. Housing Devel Corp.
712 Hawkins Avenue
Braddock, PA 15104
(412) 351-4077
'Allegheny, Washington, Westmoreland
Northern Tier Community Action Corp.
135 West 4th Street
P.O. Box 389
Emporium, PA 15834
(814) 4861161
'Cameron, Elk, Mckean, Potter
}lousing Alliance of York
35 South Duke Street
llork, PA 17401
(717)854-1541
'York
Housing Assoc. of Delaware Valley
1500 Walnut Street, Suite 601
Philadelphia, PA 19102
(215) 545-6010
'Philadelphia
Housing Assoc. of Delawre Valley
658 North Watts Street
Philadelphia, PA 19123
(215) 978-0224
'Philadelphia
Housing Opportunities of Beaver Co.
320 College Avenue, Unit 1
Beaver, PA 15009
(724) 728-7511
'Beaver, Lawrence
Housing Partnership of Chester County
41 West Lancaster Avenue
Downingtown, PA 19335
(610) 518-1522
`Chester, Delaware, Montgomery
Huntingdon County Housing Servicing
Weatherization, Inc.
917 Mifflin Street
Huntingdon, PA 16652
(814) 643-2342
'Bedford, Blair, Fulton, Huntingdon, Juniata,
Mifflin, Perry
Indiana Co. Community Action Prog.
827 Water Street Box 187
Indiana, PA 15701
(724) 465-2657
'Armstrong, Cambria, Clearfield, Indiana,
Jefferson, Westmoreland
Intercultural Family Services Inc.
4225 Chestnut Street
Philadelphia, PA 19104
(215) 386-1298
'Philadelphia
Keystone Economic Develop. Corp.
1954 Mary Grace Lane
Johnstown, PA 15901
(814) 535-6556
'Bedford, Blair, Cambria, Clearfield, Indiana,
Somerset, Westmoreland
Liberty Resources
714 Market Street, Suite 100
Philadelphia, PA 19106
(215) 634-2000
'Philadelphia
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 1711
(717) 232-2207
'Cumberland, Dauphin, Perry
Lycom-Clntn Co Comm fo Comm Action
2138 Lincoln Street
P.O. Box 3568
Williamsport, PA 17703
(570) 326-0587
'Centre, Clinton, Lycoming, Union
Northwest Counseling Service
5001 North Broad Street
Philadelphia, PA 19141
(215) 324-7500
`Bucks, Chester, Delaware, Montgomery,
Philadelphia
Nueva Esperanza
4261 North 5th Street
Philadelphia, PA 19140
(215) 324-0746
'Philadelphia
Pennsylvania Housing Finance Agency
2275 Swallow Hill Rd., Bldg 200
Pittsburgh, PA 15220
(412) 429-2842
`Allegheny
Maranatha PHFA
43 Philadelphia Avenue 211 North Front Street
Waynesboro, PA 17268 Harrisburg, PA 17110
(717) 762-3285 (800-) 342-2397
'Adams, Cumberland, Franklin, Fulton, Perry 'Cumberland, Dauphin
Media Fellowship House
302 South Jackson Street
Media, PA 19063
(610) 565-0434
'Chester, Delaware
Philadelphia Council for Comm. Advmnt.
100 N 17th St, Suite 600
Philadelphia, PA 19103
(215) 567-7803
'Chester, Delaware, Montgomery, Philadelphia
Mon Valley Unemployment Committee
1800 West St., 3rd Floor
Homestead, PA 15120
(412) 462-9962
'Allegheny, Washington, Westmoreland
Mt. Airy, USA
6703 Germantown Ave., Suite 200
Philadelphia, PA 19119
(215) 844-6021
`Philadelphia
Nazareth Housing Services
285 Bellevue Road
Pittsburgh, PA 15229
(412) 931-3510
'Allegheny
Neighborhood Housing Services Inc.
213 N 5th St., Suite 1030
Reading, PA 19601
(610) 372-8433
'Berks
Neighborhood Housing Services
710 5th Avenue, Suite 1000
Pittsburgh, PA 15219
(412) 281-9773
"Allegheny
Philadelphia Senior Center
509 South Broad Street
Philadelphia, PA 19147
(215) 546-5879
`Philadelphia
Schuylkill Community Action
225 N. Centre Street
Pottsville, PA 17901
(570) 622-1995
`Becks, Carbon, Lebanon, Lehigh, Luzeme,
Northumberland, Schuylkill
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(724) 981-5310
'Crawford, Lawrence, Mercer
South Philadelphia H.O.M.E.S.
1444 Point Breeze Avenue
Philadelphia, PA 19146
(215) 334-4430
'Philadelphia
Southwest Community Development Corp.
6368 Paschall Avenue
Philadelphia, PA 19142
(215) 729-0800
'Philadelphia
16 , , 4
St. Martin Center
1701 Parade Street
Erie, PA 16503
(814) 452-6113
'Crawford, Erie, Venango, Warren
Indicates Counties Serviced
The Trehab Center of Northeastern PA
115 SR 92S
Tuckhannock, PA 18657
(570) 836-6840
'Wyoming
Tableland Services Inc. The Trehab Center of of Northeastern PA
535 East Main Street 1225 Main Street
Somerset, PA 15501 Honesdale, PA 18431
(814) 445-9628
`Cambria, Fayette, Somerset, Westmoreland (570) 253-8941
'Bradford, Sullivan, Susquehanna, Tioga,
Wayne, Wyoming
Tabor Community Services
308 E King Street, Suite 1
Lancaster, PA 17602
(717) 397-5182
`Chester, Lancaster, Lebanon
The NORCAM Group
4200 Crawford Avenue, Suite 200
Northern Cambria, PA 15714
(814)948-4444
'Cambria, Clearfield
the Trehab Center of Northeastern PA
10 Public Avenue
P.O. Box 366
Montrose, PA 18801
(570) 278-3338
'Susquehanna
The Trehab Center of Northeastern PA
144 E East Avenue
Wellsboro, PA 16901
(570) 724-5252
`Tioga
The Trehab Center of Northeastern PA
German Street
P.O. Box 389
Dushore, PA 18614
(570) 928-9667
`Sullivan
The Trehab Center of Northeastern PA
The Enterprise Center
703 S. Elmer Ave., Suite M-6
Sayre, PA 18840
(570) 888-0412
'Bradford
United Communties Southeast Philadelphia
2029 South 8th Street
Philadelphia, PA 19148
(215) 467-8700
'Philadelphia
Urban League of Philadelphia
1818 Market Street
Philadelphia, PA 19103
(215) 561-6070
"Bucks, Delaware, Philadelphia
Urban League of Pittsburgh
Building for Equal Opportunity
One Smithfield St.
Pttsburgh, PA 15222
(412) 227-4802
`Allegheny
Voices for Independence
3711 West 12th Street
Erie, PA 16505
(800) 838-9890
`Erie
Warren-Forest Counties Economic Opportunity
Council
1209 Pennsylvania Ave W.
P.O. Box 547
Warren, PA 16365
(814) 726-2400
'Forest, Waren
r 4 '
VERIFICATION
The undersigned hereby states that the statements made in the foregoing pleading are true and correct
to the best of'his/her knowledge, information and belief. The undersigned understands that the statements
therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to
authorities.
Scott alter 00
EMC Mortgage Corporation, Attorney-in-fact
for JPMorgan Chase Bank, N.A., as Trustee for
certificateholders of Bear Stearns Asset Backed
Securities Trust 2005-SD4, Mortgage Pass-
Through Certificates, Series 2005-SD4
Loan #0008456162
{ f r.1
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-03220 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
EMC MORTGAGE CORPORATION
VS
EMORY RICHARD G
SHAWN HARRISON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
EMORY RICHARD G A/K/A EMORY RICHARD EMORY the
DEFENDANT , at 1020:00 HOURS, on the 31st day of May 2008
at 50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
RICHARD EMORY
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
t,/0 f y
18.00
15.00
.00
10.00
.00
? 43.00
Sworn and Subscibed to
before me this
of
So Answers:
R. Thomas Kline
06/02/2008
GREGORY JAV "D
By.
day
A. D.
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR
STEARNS ASSET BACKED
SECURITIES TRUST 2005-SD4,
MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
800 STATE HIGHWAY 121 BYPASS
LEWISVILLE, TX 75067-4180
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-3220 CIVIL TERM
Vs.
RICHARD G. EMORY A/K/A
RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against RICHARD G. EMORY A/K/A
RICHARD GLEN EMORY, Defendant(s) for failure to file an Answer to Plaintiffs Complaint
within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and
assess Plaintiffs damages as follows:
As Set forth in Complaint
Interest 5/17/08 to 7/7/08
TOTAL
$150,725.31
1,833.96
$152,559.27
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown
above, and (2) that notice has been given in accordance with Rule 237.1, copy attached.
GREGORY A ARDIAN, ESQUIRE
Attorney for Plaintiff
Damages are hereby assessed as indicated.
DATE: L/!a? • -
,-7 7 PRO PROTHY/AR-L
EMC. MORTGAGE CORPORATION,
ATTORNEY-[N-FACT FOR JPMORGAN CHASE
BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR STEARNS
ASSET BACKED SECURITIES TRUST 2005-
S134, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
PLAINTIFF
V.
RICHARD G. EMORY
AWA RICHARD GLEN EMORY
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 08-3220 CIVIL TERM
TO: RICHARD G. EMORY
A/K/A RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
DATE OF NOTICE: JUNE 24, 2008
NOTICE, RULE 237.1
IMPORTANT NOTICE
You are in default because you have failed to enter a written appearance personally or by attorney and file
in writing with the court your defenses or objections to the claims se forth against you. Unless you act
within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing
and you may lose your property or other important rights. You should take this notice to a lawyer at once.
If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where
you can get legal help.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800) 990-9108
(717) 249-3
Gregory Javardian, Esquire
1310 Industrial Boulevard
I" Floor, Suite 101
Southampton, PA 18966
(215) 942-9690
Attorney for Plaintiff
Usted se encuentra en estado de rebeldia por no haber tornado la accion requiida de su parte en este caso.
Al no tomar la accion debida dentro de un termino de diez (10) dial de esta notification, el tribunal podra,
sin necesidad de compararecer usted en torte o escuchar prueba alguna, dictar sentencia en su contra, usted
puede perder bienes y otros derechos importantes. Debe llevar esta notification a un abogado
immediatemente si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona
o llame por telpfono a la oficina, cuya direction se encuentra escrita abajo para averiguar donde se puede
conseguir assistencia legal.
"NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE"
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LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR
STEARNS ASSET BACKED
SECURITIES TRUST 2005-SD4,
MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-3220 CIVIL TERM
VS.
RICHARD G. EMORY A/K/A
RICHARD GLEN EMORY
VERIFICATION OF NON-MILITARY SERVICE
GREGORY JAVARDIAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) Defendant(s), RICHARD G. EMORY A/K/A RICHARD GLEN EMORY, is/are
not in the Military or Naval Service of the United States or its Allies, or otherwise within the
provisions of the Servicemembers' Civil Relief Act of Congress of 1940, as amended.
(b) Defendant, RICHARD G. EMORY A/K/A RICHARD GLEN EMORY, is over
18 years of age, and resides at 50 OLD ORCHARD CIRCLE, CAMP HILL, PA 17011.
(c) Plaintiff, EMC MORTGAGE CORPORATION, ATTORNEY-IN-FACT FOR
JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES TRUST 2005-SD4, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4, is an institution conducing business under the Laws of the
Commonwealth of Pennsylvania with an address of 800 STATE HIGHWAY 121 BYPASS ,
LEWISVILLE, TX 75067-4180.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unworn falsification to authorities.
- 4'1 L? -
GREG Y J VARDIAN, ESQUIRE
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APA
O
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR STEARNS
ASSET BACKED SECURITIES TRUST 2005-
SD4, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
800 STATE HIGHWAY 121 BYPASS
LEWISVILLE, TX 75067-4180
VS.
RICHARD G. EMORY, A/K/A
RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-3220 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly issue Writ of Execution in the above matter.
Amount Due
Interest from 7/7/08 to Date of Sale
@ $25.07 per diem
Subtotal
(Costs to be added)
$152,559.27
114--
GREGO J VARDIAN, ESQUIRE
Attome for t1aintiff
I.D. #55669
1310 Industrial Boulevard
1 st Floor, Suite 101
Southampton, PA 18966
(215) 942-9690
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ALL THAT CERTAIN lot situate in the Borough of Wormleysburg, Cumberland County,
Pennsylvania, on the Plan of Lots of Riverview, as recorded in the Office of the Recorder of Deeds
in and for the County of Cumberland in Plan Book No. 11, Page 9 and being subject to utility
easements and building and use conditions and restrictions of record, described as follows:
Lot 28 Section "D" BEGINNING at a point where the dividing line between lots twenty-seven (27)
and twenty-eight (28) intersects with the westerly side of Old Orchard Circle; thence zero degrees
(00) thirty-eight (38) minutes fifty-eight (58) seconds east, along the westerly side of Old Orchard
Circle, twenty-two and three hundredths (22.03) feet to a point of curvature; thence continuing along
the curving westerly side of Old Orchard Circle, in an arc created by fifty (50) foot radius, a distance
of twenty-six and eighty-seven (26.87) feet to a point; thence south fifty-eight (58) degrees, thirty-
three (33) minutes and thirty-six (36) seconds west, along the division line between lots twenty-eight
(28) and twenty-nine (29), a distance of one hundred and ninety-nine hundredths (100.99) feet to a
point; thence north thirty-six (36) degrees thirty (30) minutes west, thence along the division line of
lots eighteen (18) and nineteen (19) and lot twenty-eight (28), a distance of ninety-seven and eighty-
eight hundredths (97.88) feet to a point; thence north twenty-five (25) degrees forty-nine (49)
minutes three (03) seconds east, along the division line between lots twenty-six (26) and lot twenty-
eight (28), a distance of thirty-nine and forty-eight hundredths (39.48) feet to a point; thence north
eighty-nine (89) degrees twenty-one (21) minutes two (02) seconds east, along the division line
between lots twenty-seven (27) and twenty-eight (28), a distance of one hundred forty-five and
twenty-one hundredths (145.21) feet to a point the place of beginning.
BEING known as 50 OLD ORCHARD CIRCLE, CAMP HILL, PA 17011
BEING THE SAME PREMISES which Joseph Laporta and Kimberly Laporta, husband and wife,
by Deed dated July 9, 2004 and recorded July 14, 2004 in the Office of the Recorder of Deeds in and
for Cumberland County in Deed Book 264, Page 689, granted and conveyed unto Richard G. Emory,
a married man.
PARCEL No. 47-18-1302-113
AEMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR STEARNS
ASSET BACKED SECURITIES TRUST 2005-
SD4, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
vs.
RICHARD G. EMORY, A/K/A
RICHARD GLEN EMORY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-3220 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129.1
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 50 OLD ORCHARD
CIRCLE. CAMP HILL, PA 17011:
1. Name and address of Owner(s) or reputed Owner(s):
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
RICHARD G. EMORY, A/K/A 50 OLD ORCHARD CIRCLE
RICHARD GLEN EMORY CAMP HILL, PA 17011
2. Name and address of Defendant(s) in the judgment:
RICHARD G. EMORY, A/K/A
RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
4. Name and address of last recorded holder of every mortgage of record:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Plaintiff.
Joseph Laporta 932 River Road
Kimberly Laporta Maurysville, PA 17053
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
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.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Cumberland County Domestic Relations
Cumberland County Tax Claim Bureau
PA Department of Public Welfare
Bureau of Child Support Enforcement
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
7. Name and address of every other person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenants/Occupants
SPOUSE OF RICHARD G. EMORY,
A/K/A RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are subject to the
penalties of 18 Pa. C.S.A. 4904 relating to unworn falsification to authorities.
GRE JAVARDIAN, ESQUIRE
Atto ey or Plaintiff
August 27, 2008
ID,
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LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR
STEARNS ASSET BACKED
SECURITIES TRUST 2005-SD4,
MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-3220 CIVIL TERM
Vs.
RICHARD G. EMORY, A/K/A
RICHARD GLEN EMORY
CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY
AS TO THE SALE OF REAL ESTATE
I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action
and further certify this Property is:
() FHA
() Tenant Occupied
() Vacant
O Commercial
() As a result of Complaint in Assumpsit
(X) Act 91 complied with
/U\1? -
GREjefo VARDIAN, ESQUIRE
AttoPlaintiff
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LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR STEARNS
ASSET BACKED SECURITIES TRUST 2005-
SD4, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-3220 CIVIL TERM
vs.
RICHARD G. EMORY, A/K/A
RICHARD GLEN EMORY
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: RICHARD G. EMORY, A/K/A
RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
Your house (real estate) at 50 OLD ORCHARD CIRCLE, CAMP HILL, PA 170119 is
scheduled to be sold at Sheriffs Sale on DECEMBER 10. 2008 at 10:00 A.M., in the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of
$152,559.27, obtained by EMC MORTGAGE CORPORATION, ATTORNEY-IN-FACT FOR
JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR CERTIFICATEHOLDERS OF
BEAR STEARNS ASSET BACKED SECURITIES TRUST 2005-SD4, MORTGAGE PASS-
THROUGH CERTIFICATES, SERIES 2005-SD4, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 2? 15)
942-9690.
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.
C
3. You may also be able to stop the sale through other legal proceedings.
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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (215) 942-9690.
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 fu11 amount due in the sale.
To find out if this has happened, you may call Gregory Javardian, Esquire at (215) 942-9690.
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 that 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 Sheriff. 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.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
(800) 990-9108
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ALL THAT CERTAIN lot situate in the Borough of Wormleysburg, Cumberland County,
Pennsylvania, on the Plan of Lots of Riverview, as recorded in the Office of the Recorder of Deeds
in and for the County of Cumberland in Plan Book No. 11, Page 9 and being subject to utility
easements and building and use conditions and restrictions of record, described as follows:
Lot 28 Section "D" BEGINNING at a point where the dividing line between lots twenty-seven (27)
and twenty-eight (28) intersects with the westerly side of Old Orchard Circle; thence zero degrees
(00) thirty-eight (38) minutes fifty-eight (58) seconds east, along the westerly side of Old Orchard
Circle, twenty-two and three hundredths (22.03) feet to a point of curvature; thence continuing along
the curving westerly side of Old Orchard Circle, in an arc created by fifty (50) foot radius, a distance
of twenty-six and eighty-seven (26.87) feet to a point; thence south fifty-eight (58) degrees, thirty-
three (33) minutes and thirty-six (36) seconds west, along the division line between lots twenty-eight
(28) and twenty-nine (29), a distance of one hundred and ninety-nine hundredths (100.99) feet to a
point; thence north thirty-six (36) degrees thirty (30) minutes west, thence along the division line of
lots eighteen (18) and nineteen (19) and lot twenty-eight (28), a distance of ninety-seven and eighty-
eight hundredths (97.88) feet to a point; thence north twenty-five (25) degrees forty-nine (49)
minutes three (03) seconds east, along the division line between lots twenty-six (26) and lot twenty-
eight (28), a distance of thirty-nine and forty-eight hundredths (39.48) feet to a point; thence north
eighty-nine (89) degrees twenty-one (21) minutes two (02) seconds east, along the division line
between lots twenty-seven (27) and twenty-eight (28), a distance of one hundred forty-five and
twenty-one hundredths (145.21) feet to a point the place of beginning.
BEING known as 50 OLD ORCHARD CIRCLE, CAMP HILL, PA 17011
BEING THE SAME PREMISES which Joseph Laporta and Kimberly Laporta, husband and wife,
by Deed dated July 9, 2004 and recorded July 14, 2004 in the Office of the Recorder of Deeds in and
for Cumberland County in Deed Book 264, Page 689, granted and conveyed unto Richard G. Emory,
a married man.
PARCEL No. 47-18-1302-113
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N008-3220 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EMC Mortgage Corporation, Attorney-in-Fact for
JPMorgan Chase Bank, N.A., as Trustee for Certificateholders of Bear Stearns Asset Backed
Securities Trust 2005-SD4, Mortgage Pass-Through Certificates, Series 2005-SD4 800 State Highway
121 Bypass Lewisville, TX 75067-4180 Plaintiff (s)
From Richard G. Emory, a/k/a Richard Glen Emory
50 Old Orchard Circle
Camp Hill, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell see legal description .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $152,559.27
L.L.$.50
Interest from 7/7/08 to Date of Sale @ $25.07 per diem
Atty's Comm % Due Prothy $2.00
Atty Paid $162.00
Other Costs
Plaintiff Paid
Date: August 29, 2008
(Seal)
REQUESTING PARTY:
Name Gregory Javardian, Esq.
Address: 1310 Industrial Boulevard
1st Floor, Suite 101
Southampton, PA 18966
Attorney for: Plaintiff
Telephone: (215) 942-9690
Supreme Court ID No. 55669
Curtis R. Long, Prothonota
By: ?-- /-
Deputy
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
,IT FLOOR, SUITE 101
SOUTHAMPTON, PA 18966 ATTORNEY FOR
(215) 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR
STEARNS ASSET BACKED
SECURITIES TRUST 2005-SD4,
MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
PLAINTIFF
VS.
RICHARD G. EMORY
A/K/A RICHARD GLEN EMORY
DEFENDANT
COURT OF I COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 08-3220 CIVIL TERM
TO THE PROTHONOTARY:
Kindly VACATE, without prejudice, the default judgment lfiled in the instant action
on July 8, 2008.
Date: 10/13/08
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LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
ATTORNEY FOR PLAINTIFF
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR
STEARNS ASSET BACKED
SECURITIES TRUST 2005-SD4,
MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
PLAINTIFF
VS.
RICHARD G. EMORY
A/K/A RICHARD GLEN EMORY
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO.
CIVIL TERM
D
TO THE PROTHONOTARY:
Kindly DISMISS, without prejudice, the Complaint in Mortgage Foreclosure filed in
the instant action on May 22, 2008.
Date: 10/13/08
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EMC Mortgage Corporation
VS
Richard G. Emory a/k/a Richard Glen Emory
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-3220 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 Gregory Javardian.
Sheriffs Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Levy
Mileage
Surcharge
Share of Bills
SO A e
R. Thomas Kline, Sheriff
BY D J
Real Estate Sergeant
30.00
2,641.20
15.00
.50
2.00
15.00
13.00
20.00
14.92
$2,751.62
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EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR STEARNS
ASSET BACKED SECURITIES TRUST 2005-
SD4, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
VS.
RICHARD G. EMORY, A/K/A
RICHARD GLEN EMORY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-3220 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129.1
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 50 OLD ORCHARD
CIRCLE, CAMP HILL, PA 17011:
1. Name and address of Owner(s) or reputed Owner(s):
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
RICHARD G. EMORY, A/K/A 50 OLD ORCHARD CIRCLE
RICHARD GLEN EMORY CAMP HILL, PA 17011
2. Name and address of Defendant(s) in the judgment:
RICHARD G. EMORY, A/K/A 50 OLD ORCHARD CIRCLE
RICHARD GLEN EMORY CAMP HILL, PA 17011
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
4. Name and address of last recorded holder of every mortgage of record:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Plaintiff.
Joseph Laporta 932 River Road
Kimberly Laporta Maurysville, PA 17053
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5. Name and address of every other person who has any record lien on the property:
Name
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
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.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Cumberland County Domestic Relations
Cumberland County Tax Claim Bureau
PA Department of Public Welfare
Bureau of Child Support Enforcement
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
7. Name and address of every other person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenants/Occupants
SPOUSE OF RICHARD G. EMORY,
A/K/A RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are subject to the
penalties of 18 Pa. C.S.A. 4904 relating to unworn falsification to authorities.
GREffiR V- JAVARDIAN, ESQUIRE
Atto ey or Plaintiff
August 27, 2008
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
'13 10 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18%6
(215 942-9690
EMC MORTGAGE CORPORATION,
ATTORNEY-IN-FACT FOR JPMORGAN
CHASE BANK, N.A., AS TRUSTEE FOR
CERTIFICATEHOLDERS OF BEAR STEARNS
ASSET BACKED SECURITIES TRUST 2005-
SD4, MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2005-SD4
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-3220 CIVIL TERM
vs.
RICHARD G. EMORY, A/K/A
RICHARD GLEN EMORY
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: RICHARD G. EMORY, A/K/A
RICHARD GLEN EMORY
50 OLD ORCHARD CIRCLE
CAMP HILL, PA 17011
Your house (real estate) at 50 OLD ORCHARD CIRCLE CAMP HILL PA 17011, is
scheduled to be sold at Sheriffs Sale on DECEMBER 10, 2008 at 10:00 A.M., in the Cumberland
County Courthouse, I Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of
$152,559.27, obtained by EMC MORTGAGE CORPORATION, ATTORNEY-IN-FACT FOR
JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR CERTIFICATEHOLDERS OF
BEAR STEARNS ASSET BACKED SECURITIES TRUST 2005-SD4, MORTGAGE PASS-
THROUGH CERTIFICATES, SERIES 2005-SD4, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 2211 )
942-9690.
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.
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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (215) 942-9690.
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 Gregory Javardian, Esquire at (215) 942-9690.
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 that 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 Sheriff. 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.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
(800) 990-9108
Y
Real Estate Sale #80
On September 9, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
Wormleysburg Borough, Cumberland County, PA
Known and numbered as 50 Old Orchard Circle, Camp Hill
more fully described on Exhibit "A"
filed with this writ and by this reference
6e
incorporated herein.
Date: September 9, 2008 By:
C' ) v..t}
Real Est to Sergeant
WRIT OF EXECUTION and/or ATTACHMENT
.w- - %,- ,
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N008-3220 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EMC Mortgage Corporation, Attorney-in-Fact for
JPMorgan Chase Bank, N.A., as Trustee for Certificateholders of Bear Stearns Asset Backed
Securities Trust 2005-SD4, Mortgage Pass-Through Certificates, Series 2005-SD4 800 State Highway
121 Bypass Lewisville, TX 75067-4180 Plaintiff (s)
From Richard G. Emory, a/k/a Richard Glen Emory
50 Old Orchard Circle
Camp Hill, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell see legal description .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $152,559.27
L.L.$.50
Interest from 7/7/08 to Date of Sale @ $25.07 per diem
Atty's Comm % Due Prothy $2.00
Atty Paid $162.00
Other Costs
Plaintiff Paid
Date: August 29, 2008
(Seal)
REQUESTING PARTY:
Name Gregory Javardian, Esq.
Address: 1310 Industrial Boulevard
1s` Floor, Suite 101
Southampton, PA 18966
Attorney for: Plaintiff
Telephone: (215) 942-9690
Curtis R. Long, Prothonota
By: g ?
Deputy
Supreme Court ID No. 55669
Brandy Lynn Harrison,
Plaintiff
V.
Justin James Harrison,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009 - 3220 CIVIL TERM - LAW
PROTECTION FROM ABUSE,
PETITION TO VACATE ORDER
AND WITHDRAW ACTION
Plaintiff, Brandy Lynn Harrison, by and through her attorneys, MidPenn Legal Services
requests that the Court vacate the Temporary Protection From Abuse Order in the above-captioned
case and that the action be withdrawn on the grounds that:
1. A Temporary Protection From Abuse Order was entered on May 21, 2009, by Judge
Kevin A. Hess.
2. Plaintiff requests that the Temporary Protection Order be vacated and the action
withdrawn without prejudice to her.
3. A certified copy of this Order will be provided to the Police Department by attorney
for Plaintiff.
WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the
Order, and that the action be withdrawn without prejudice to Plaintiff.
Resi)Wullk s\jb
Jes ' C! D. Holst, Attorney for Plaintiff
MI ENN LEGAL SERVICES
401 East Louther Street
Carlisle PA 17013
I, Brandy Lynn Harrison, hereby direct MidPenn Legal Services to file a Petition to Vacate
Order and Withdraw Action on my behalf (Harrison v. Harrison, No. 2009-3220) . I understand
that upon entry of an Order in this matter that the Court will vacate the Temporary Protection
Order entered on May 21, 2009, and that my Protection From Abuse action will be withdrawn.
In addition, I request that no further litigation be filed on my behalf in this case, and I no longer
desire that MidPenn Legal Services represent me in this matter at this time. I understand that my
Protection From Abuse case will be closed.
I have been advised by MidPenn Legal Services staff that I can contact their offices in the
future if I need legal assistance in this or any other matter handled by their program, and that if I
meet the program's requirements, they may be able to assist me.
Date:
Brandy Lyn?i Harrison, Plaintiff
VERIFICATION
I verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to
unsworn falsification to authorities.
Dated: 11 -Cv , 1t,2 t ,J ?C.
Brandy xtn Harrison, Plaintiff