HomeMy WebLinkAbout08-4974PENNSYLVANIA STATE IN THE COURT OF COMMON PLEAS
EMPLOYEES CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
:
V. NO. Gs - HQ74 Civil Terr+
STEPHEN M. LONG and CIVIL ACTION - LAW
SUSAN MURPHY LONG, IN MORTGAGE FORECLOSURE
Defendant(s) .
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after the Complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
Court without further notice for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 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 CAN NOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDCE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
1-800-990-9108
Document #: 210017.1
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE
CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE
USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA
DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU
ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE
PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE
PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA
QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR
RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE
SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS),
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
1-800-990-9108
Document #: 210017.1
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE,
BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15
U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE
VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF
DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF
RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL
OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN
VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE
ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF
THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH
YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN
THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS
COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME.
FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT
FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS
AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF
YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY
PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT,
THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH
LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE
MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD
CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR
RIGHTS AND OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUTPCY AND RECEIVED A DISCHARGE,
THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION
TO ENFORCE A LIEN ON REAL ESTATE.
Document #: 210017.1
PENNSYLVANIA STATE
EMPLOYEES CREDIT UNION,
Plaintiff
V.
STEPHEN M. LONG and :
SUSAN MURPHY LONG,
Defendant(s)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
COMPLAINT
The Complaint of Plaintiff, Pennsylvania State Employees Credit Union ("PSECU"), by
and through its attorneys, Van Eck & Van Eck, P.C., seeking mortgage foreclosure in the above
action is as follows:
1. Plaintiff, PSECU, is a financial institution authorized to conduct business in the
Commonwealth of Pennsylvania with a principal place of business located at One Credit Union
Place, Harrisburg, Dauphin County, Pennsylvania, 17110.
2. Defendant, Stephen M. Long, is an adult individual whose last known address is
103 Worcester Avenue, Harrisburg, PA 17111.
3. Co-Defendant, Susan M. Long, is an adult individual whose last known address is
103 Worcester Avenue, Harrisburg, PA 17111.
4. Defendant(s) is/are the mortgagor(s) and real owner(s) of the property hereinafter
described.
5. On or about March 20, 2002, Defendants, Stephen M. Long and Susan M. Long,
executed and delivered a mortgage and note upon the premises hereinafter described to PSECU
(the "Mortgage"). The mortgage is recorded in the Office of the Recorder of Deeds in and for
Document #: 210017.1
Cumberland at mortgage book 1754, Page 720. A copy of the mortgage is attached hereto as
Exhibit "A" and a copy of the note is attached hereto as Exhibit "B".
6. The premises subject to the mortgage referenced above is described in the
mortgage attached as Exhibit "A" and is known as 742 Allenview Drive, Mechanicsburg, Pa
17055.
7. The Mortgage is in default because monthly payments of principal and interest
due January 1, 2006 and each month thereafter are due and unpaid The terms of the Mortgage
provide for the entire principal balance and all interest due thereon to be due upon failure of the
mortgagor to make such payments after written notice to the Mortgagor.
8. The following amounts are due on the Mortgage:
(a) Unpaid principal balance
(b) Interest at $9.46 per day
from 01/01/06 to 07/16/08
(based on contract rate of 6.49%)
(c) Late fees
(d) Escrow
(e) Title Search
(f) Attorney's fees and Costs
(g) Satisfaction Fee
$53,194.43
$6,043.92
$960.60
$50.00
$1,470.00
$27.00
TOTAL $61,745.95
9. 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 purchaser at
Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be
charged.
Document #: 210017.1
10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of
Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998,
and/or Notice of Default as required by the mortgage document, as applicable, have been sent to
the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said
notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an
authorized consumer credit counseling agency, or has/have been denied assistance by the
Pennsylvania Housing Finance Agency. True and correct copies of the above notices, as
relevant, were sent by regular mail and by certified mail, return receipt requested and are
attached hereto as Exhibit "C".
11. This action does not come under Act 6 of 1974 because the original mortgage
amount exceeds $50,000.00.
WHEREFORE, Plaintiff demands an in rem Judgment against the Defendants in the
sum of $61,745.95, together with interest from July 16, 2008 at the per diem rate of $9.46 to the
date of Judgment, and other costs and charges collectible under the Mortgage and for the
foreclosure and sale of the mortgaged property.
VAN ECK & VAN ECK, P.C
Dated: August 18, 2008 By: Oj "
enr-y . Van Eck, Esquire
VAN ECK & VAN ECK, P.C.
Attorney I.D. No. 83087
7810 Allentown Blvd
PO Box 6662
Harrisburg, PA 17112
(717) 540-5406
Attorneys for Plaintiff
Document #: 210017.1
Exhibit "A"
LLD
.; Lti l ? Ct?t1T1TY- F
'02 APR 2 Ail 10 26
Parcel Number:
42-28-2423-303
Loan #: 23324
MORTGAGE
THIS MORTGAGE is made this a? day of /` ofUUot , between the Mortgagor,
Stephen M. Long, Susan Murphy Long , , , (herein "Borrower"), and the Mortgagee, PENNSYLVANIA STATE
EMPLOYEES CREDIT UNION, a corporation organized and existing under the laws of PENNSYLVANIA,
whose address is P.O. Box 67013, Harrisburg, PA 17106-7013 (herein "Lender").
WHEREAS, Borrower is indebted to Lender in the principal sum of U.S. $ 83,050.00 which indebtedness is
evidenced by Borrower's note dated / 1 oI r A o? and extensions and renewals thereof (herein "Note"),
providing for monthly installments of principal and interest, with balance of the indebtedness, if not sooner paid,
due and payable on
TO SECURE to Lender the repayment of the indebtedness evidenced by the Note, with interest thereon; the
payment of all other sums, with the interest thereon, advanced in accordance herewith to protect the security of
this Mortgage; and the performance of the covenants and agreements of Borrower herein contained, Borrower
does hereby mortgage, grant and convey to Lender the following described property located in the County of
Cumberland, State of PA known as: 742 Allenview Drive, Mechanicsburg,PA 17055 which was conveyed to
owner by deed dated January 14, 2002 , and properly recorded in the Office for the Recorder of Deeds in said
county in Deed Book No. 250, Page 171 or Instrument No. as the Property is described therein (the "Property")
and, if this box is checked; Clppo`' Alton T?/0
then see Exhibit "A" which more completely describes the PROPERTY, and which is attached hereto and
made a part thereof.
4
PENNSYLVANIA - SECOND MORTGAGE -1/80 - FNMA/FHLMC UNIFORM INSTRUMENT Initials:
Page I of 8 rm 3839
SK 17 541?0720
TOGETHER with all the improvements now or hereafter erected on the property, and all easements,
rights, appurtenances and rents, all of which shall be deemed to be and remain a part of the property covered by
this Mortgage; and all of the foregoing, together with said property (or the leasehold estate if this Mortgage is on
a leasehold) are herein after referred to as "Property."
Borrower covenants that Borrower is lawfully seized of the estate hereby conveyed and has the right to
mortgage, grant and convey the Property, and the Property is unencumbered, except for encumbrances of the
record. Borrower covenants that Borrower wan-ants and will defend generally the title to the Property against all
claims and demands, subject to encumbrances of record.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment of Principal and Interest. Borrower shall promptly pay when due the principal and interest
indebtedness evidenced by the Note and late charges as provided in the Note.
2. Funds for Taxes and Insurance. Subject to applicable law or a written waiver by Lender, Borrower
shall pay to Lender on the day monthly payments of principal and interest are payable under the Note, until the
Note is paid in full, a sum (herein "Funds") equal to one-twelfth of the yearly taxes and assessments (including
condominium and planned unit development assessments, if any) which may attain priority over this Mortgage
and ground rents on the Property, if any, plus one-twelfth of yearly premium installments for hazard insurance,
plus one-twelfth of yearly premium installments for mortgage insurance, if any, all as reasonably estimated
initially and from time to time by Lender on the basis of assessments and bills and reasonable estimates thereof.
Borrower shall not be obligated to make such payments of Funds to Lender to the extent that the Borrower
makes such payments to the holder of a prior mortgage or deed of trust is such holder, is an institutional lender.
a1v t.
Initials:
Page 2 of 8 Form 3839
BltI754P60721
If Borrower pays Funds to Lender, the Funds shall be held in an institution the deposits or accounts
of which are insured or guaranteed by a federal or state agency (including Lender if Lender is such an
institution). Lender shall apply the Funds to pay said taxes, assessments, insurance premiums and ground
rents. Lender may not charge for so holding and applying the Funds, analyzing said account or verifying
and compiling said assessments and bills, unless Lender pays Borrower interest on the Funds and
applicable law permits Lender to make such a charge. Borrower and Lender may agree in writing at the
time of execution of this Mortgage that interest on the Funds shall be paid to Borrower, and unless such
agreement is made or applicable law requires such interest to be paid, Lender shall not be required to pay
Borrower any interest or earnings on the Funds. Lender shall give to Borrower, without charge, an annual
accounting of the Funds showing credits and debits to the Funds and the purpose for which each debit to
the Funds was made. The Funds are pledged as additional security for the sums secured by this Mortgage.
If the amount of the Funds held by Lender, together with the future monthly installments of Funds
payable prior to the due dates of taxes, assessments, insurance premiums and ground rents, shall exceed the
amount required to pay said taxes, assessments, insurance premiums and ground rents as they fall due,
such excess shall be, at Borrower's option, either promptly repaid to Borrower or credited to Borrower on
monthly installments of Funds. If the amount of the Funds held by Lender shall not be sufficient to pay
taxes, assessments, insurance premiums and ground rents as they fall due, Borrower shall pay to Lender
any amount necessary to make up the deficiency in one or more payments as Lender may require.
Upon payment in full of all sums secured by this Mortgage, Lender shall promptly refund to
Borrower any Funds held by Lender. If under paragraph 17 hereof the Property is sold or the Property is
otherwise acquired by Lender, Lender shall apply, no later than immediately prior to the sale of the
Property or its acquisition by Lender, any Funds held by Lender at the time of application as a credit
against the sums secured by this Mortgage.
3. Application of Payments. Unless applicable law provides otherwise, all payments received by
Lender under the Note and paragraphs 1 and 2 hereof shall be applied by Lender first in payment of
amounts payable to Lender by Borrower under paragraph 2 hereof, then to interest payable on the Note,
and then to the principal of the Note.
4. Prior Mortgages and Deeds of Trust; Charges; Liens. Borrower shall perform all of Borrower's
obligations under any mortgage, deed of trust or other security agreement with a lien which has priority
over this Mortgage, including Borrower's covenants to make payments when due. Borrower shall pay or
cause to be paid all taxes, assessments and other charges, fines and impositions attributable to the Property
which may attain a priority over this Mortgage, and leasehold payments or ground rents, if any.
5. Hazard 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 such
other hazards as Lender may require and in such amounts and for such periods as Lender may require.
The insurance carrier providing the insurance shall be chosen by Borrower subject to approval by
Lender; provided, that such approval. shall not be unreasonably withheld. All insurance policies and
renewals thereof shall be in a form acceptable to Lender and shall include a standard mortgage clause in
favor of and in a form acceptable to Lender. Lender shall have the right to hold the policies and renewals
thereof, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which
has priority over this Mortgage.
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.
Initials: J' kL
(We 76(PA) (ooo» Page 3 of 8 Form 3839
OKI754FG0722
If the Property is abandoned by Borrower, or if Borrower fails to respond to Lender within 30 days
from the date notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for
insurance benefits, Lender is authorized to collect and apply the insurance proceeds at Lender's option
either to restoration or repair of the Property or to the sums secured by this Mortgage.
6. Preservation and Maintenance of Property; Leaseholds; Condominiums; Planned Unit
Developments. Borrower shall keep the Property in good repair and shall not commit waste or permit
impairment or deterioration of the Property and shall comply with the provisions of any lease if this
Mortgage is on a leasehold. If this Mortgage is on a unit in a condominium or a planned unit development,
Borrower shall perform all of Borrower's obligations under the declaration or covenants creating or
governing the condominium or planned unit development, the by-laws and regulations of the condominium
or planned unit development, and constituent documents.
7. Protection of Lender's Security. If Borrower fails to perform the covenants and agreements
contained in this Mortgage, or if any action or proceeding is commenced which materially affects Lender's
interest in the Property, then Lender, at Lender's option, upon notice to Borrower, may make such
appearances, disburse such sums, including reasonable attorneys' fees, and take such action as is necessary
to protect Lender's interest. If Lender required mortgage insurance as a condition of making the loan
secured by this Mortgage, Borrower shall pay the premiums required to maintain such insurance in effect
until such time as the requirement for such insurance terminates in accordance with Borrower's and
Lender's written agreement or applicable law.
Any amounts disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the Note
rate, shall become additional indebtedness of Borrower secured by this Mortgage. Unless Borrower and
Lender agree to other terms of payment, such amounts shall be payable upon notice from Lender to
Borrower requesting payment thereof. Nothing contained in this paragraph 7 shall require Lender to incur
any expense or take any action hereunder.
8. Inspection. Lender may make or cause to be made reasonable entries upon and inspections of the
Property, provided that Lender shall give Borrower notice prior to any such inspection specifying
reasonable cause therefor related to Lender's interest in the Property.
9. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in
connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in
lieu of condemnation, are hereby assigned and shall be paid to Lender, subject to the terms of any
mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage.
10. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for
payment or modification of amortization of the sums secured by this Mortgage granted by Lender to any
successor in interest of Borrower shall not operate to release, in any manner, the liability of the original
Borrower and Borrower's successors in interest. Lender shall not be required to commence proceedings
against such successor or refuse to extend time for payment or otherwise modify amortization of the sums
secured by this Mortgage by reason of any demand made by the original Borrower and Borrower's
successors in interest. Any forbearance by Lender in exercising any right or remedy hereunder, or
otherwise afforded by applicable law, shall not be a waiver of or preclude the exercise of any such right or
remedy.
Initials: 6?14L
4W76(PA) 1000» Pape 4 of 8 Form 3839
BKI754PGO723
11. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and
agreements herein contained shall bind, and the rights hereunder shall inure to, the respective successors
and assigns of Lender and Borrower, subject to the provisions of paragraph 16 hereof. All covenants and
agreements of Borrower shall be joint and several. Any Borrower who co-signs this Mortgage, but does
not execute the Note, (a) is co-signing this Mortgage only to mortgage, grant and convey that Borrower's
interest in the Property to Lender under the terms of this Mortgage, (b) is not personally liable on the Note
or under this Mortgage, and (c) agrees that Lender and any other Borrower hereunder may agree to extend,
modify, forbear, or make any other accommodations with regard to the terms of this Mortgage or the Note
without that Borrower's consent and without releasing that Borrower or modifying this Mortgage as to that
Borrower's interest in the Property.
12. Notice. Except for any notice required under applicable law to be given in another manner, (a)
any notice to Borrower provided for in this Mortgage shall be given by delivering it or by mailing such
notice by certified mail addressed to Borrower at the Property Address or at such other address as
Borrower may designate by notice to Lender as provided herein, and (b) any notice to Lender shall be
given by certified mail to Lender's address stated herein or to such other address as Lender may designate
by notice to Borrower as provided herein. Any notice provided for in this Mortgage shall be deemed to
have been given to Borrower or Lender when given in the manner designated herein.
13. Governing Law; Severability. The state and local laws applicable to this Mortgage shall be the
laws of the jurisdiction in which the Property is located. The foregoing sentence shall not limit the
applicability of federal law to this Mortgage. In the event that any provision or clause of this Mortgage or
the Note conflicts with applicable law, such conflict shall not affect other provisions of this Mortgage or
the Note which can be given effect without the conflicting provision, and to this end the provisions of this
Mortgage and the Note are declared to be severable. As used herein, "costs," "expenses" and "attorneys'
fees" include all sums to the extent not prohibited by applicable law or limited herein.
14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this
Mortgage at the time of execution or after recordation hereof.
15. Rehabilitation Loan Agreement. Borrower shall fulfill all of Borrower's obligations under any
home rehabilitation, improvement, repair, or other loan agreement which Borrower enters into with
Lender. Lender, at Lender's option, may require Borrower to execute and deliver to Lender, in a form
acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against
parties who supply labor, materials or services in connection with improvements made to the Property.
16. Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property
or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and
Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option,
require immediate payment in full of all sums secured by this Mortgage. However, this option shall not be
exercised by Lender if exercise is prohibited by federal law as of the date of this Mortgage.
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 delivered or mailed within which
Borrower must pay all sums secured by this Mortgage. If Borrower fails to pay these sums prior to the
expiration of this period, Lender may invoke any remedies permitted by this Mortgage without further
notice or demand on Borrower.
X-O
Initials:
?781PA) t0007i Page 6 of 8 Form 3839
8KI754PGO724
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
17. Acceleration; Remedies. Upon Borrower's breach of any covenant or agreement of Borrower
in this Mortgage, including the covenants to pay when due any sums secured by this Mortgage,
Lender prior to acceleration shall give notice to Borrower as provided by applicable law specifying,
among other things: (1) the breach; (2) the action required to cure such breach; (3) a date, not less
than 30 days from the date the notice is mailed to Borrower, by which such breach must be cured;
and (4) that failure to cure such breach on or before the date specified in the notice may result in
acceleration of the sums secured by this Mortgage, foreclosure by judicial proceeding, and sale of the
Property. The notice shall further inform Borrower of the right to reinstate after acceleration and the
right to assert in the foreclosure proceeding the nonexistence of a default or any other defense of
Borrower to acceleration and foreclosure. If the breach is not cured on or before the date specified in
the notice, Lender, at Lender's option, may declare all of the sums secured by this Mortgage to be
immediately due and payable without further demand and may foreclose this Mortgage by judicial
proceeding. Lender shall be entitled to collect in such proceeding all expenses of foreclosure,
including, but not limited to, reasonable attorneys' fees, and costs of documentary evidence,
abstracts and title reports.
18. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums secured by
this Mortgage due to Borrower's breach, Borrower shall have the right to have any proceedings begun by
Lender to enforce this Mortgage discontinued at any time prior to at least one hour before the
commencement of bidding at a sheriff s sale or other sale pursuant to this Mortgage if. (a) Borrower pays
Lender all sums which would be then due under this Mortgage and the Note had no acceleration occurred;
(b) Borrower cures all breaches of any other covenants or agreements of Borrower contained in this
Mortgage; (c) Borrower pays all reasonable expenses incurred by Lender in enforcing the covenants and
agreements of Borrower contained in this Mortgage and in enforcing Lender's remedies as provided in
paragraph 17 hereof, including, but not limited to, reasonable attorneys' fees; and (d) Borrower takes such
action as Lender may reasonably require to assure that the lien of this Mortgage, Lender's interest in the
Property and Borrower's obligation to pay the sums secured by this Mortgage shall continue unimpaired.
Upon such payment and cure by Borrower, this Mortgage and the obligations secured hereby shall remain
in full force and effect as if no acceleration had occurred.
19. Assignment of Rents; Appointment of Receiver; Lender in Possession. As additional security
hereunder, Borrower hereby assigns to Lender the rents of the Property, provided that Borrower shall,
prior to acceleration under paragraph 17 hereof or abandonment of the Property, have the right to collect
and retain such rents as they become due and payable.
Upon acceleration under paragraph 17 hereof or abandonment of the Property, Lender, in person, by
agent or by judicially appointed receiver shall be entitled to enter upon, take possession of and manage the
Property and to collect the rents of the Property including those past due. All rents collected by Lender or
the receiver shall be applied first to payment of the costs of management of the Property and collection of
rents, including, but not limited to, receiver's fees, premiums on receiver's bond and reasonable attorneys'
fees, and then to the sums secured by this Mortgage. Lender and the receiver shall be liable to account
only for those rents actually received.
20. Release. Upon payment of all sums secured by this Mortgage, Lender shall discharge this
Mortgage without charge to Borrower. Borrower shall pay all costs of recordation, if any.
21. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judg t is
entered on the Note or in an action of mortgage foreclosure shall be the rate stated in the Note. /
initiaI3.
OW76(PA) I0007) Page 6 or 6 Form 3839
0
J
REQUEST FOR NOTICE OF DEFAULT
AND FORECLOSURE UNDER SUPERIOR
MORTGAGES OR DEEDS OF TRUST
Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a lien
which has priority over this Mortgage to give Notice to Lender, at Lender's address set forth on page one of this
Mortgage, of any default under the superior encumbrance and of any sale or other foreclosure action.
IN !FN ESS WHEREOF, Borrower has executed this Mortgage.
Witnes
?' GZ'I•tl _ ? Z o Z /? Z (Seal)
n -Borrower
- (Seal)
-Borrower
-(Seal)
-Borrower
(Sign Original Only)
COMMONWEALTH OF PENNSYLVANIA, LVM LA tj a- County ss.
On this, the y day of M a &-&A Zooo a , before me,
Q gN .jr.+. / L. the undersigned officer, personally appeared
Hato o ry Pubii
Stephen M: Long , Susan Murphy Long known to me (o?satisfactorily uroven) to be the person(s) whose
name(q 6Av t subscribed to the within instrument and acknowledged that -" executed
the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My Commission Expires: 110 J &Ab TA 1q,.;1003
Notary 'Impression Stamp
y`6..
1&Y i
1. aE
(Seal)
-Borrower
Si ature o to `bHc
Notary Seal
NourN ` Sod
71 IPpbiic
EvywCO&VJifft Y?, ! =F% CWA1v
SXPIM Nov. 17, 200
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Page 7 of 8 Form 3839
BK!754PGO726
Certificate of Residence
I, ode N,01176 , do hereby certify that the correct address of the within-named
Lender is P.O. Boa 67013, Harrisburg, PA 17106-701/,/3,.
Witness my hand this OV day of #JI-C/
Agent of Lender
I Certify this to be recorded
In Cumberland County PA
a C&
°
Recorder of Deeds
Page 8 of 8
Form 3839
OKI754PC4727
Exhibit "B"
NOTE
Wych ?D . ow Me&Rn1,60j m
Date Year city State
742 Allenview_nr+ve_ Mmhanieah rr PA ims-i
Property Address
1. BORROWER'S PROMISE TO PAY
In return for a loan that I received, I promise to pay U.S. $ 83,050.00 (this amount will be called "principal"), plus interest, to the
order of the Lender. The lender is PENNSYLVANIA STATE EMPLOYEES CREDIT UNION. I understand that the Lender may
transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note will
be called the "Note Holder."
2. INTEREST
I will pay interest at a yearly rate of 8.49 %.
Interest will be charged on the part of principal which has not been paid. Interest will be charged beginning on the date of the Note
and continuing until the full amount of principal has been paid.
3. PAYMENTS
I will pay principal and interest by making payments each month of UPS/ $ 1'029.26.
I will make my payments on the 1 st day of each month beginning on Ivl 101, a . I will make these payments every month
until I ye ? 41 of the principal and interest and any other charges, deftrib6d below, that I may owe under this Note. If, on
/ iI still owe amounts under this Note, I will pay those amounts, in full, on that date.
I will make my monthly payments at P.O. Box 67013, Harrisburg, PA 17106-7013 or at a different place if required by the Note
Holder.
4. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any of my monthly payments by the end of FIFTEEN 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 FIVE % of my overdue payment. I will
pay this late charge only once on any late payment.
(B) Default
If I do not pay the full amount of each monthly payment by the date stated in Section 3 above, I will be in default. Even if, at a
time when I am in default, the Note Holder does not require me to pay immediately in full as described below, the Note Holder will
still have the right to do so if I am in default at a later time.
(C) Notice From Note Holder
If I am in default, the Note Holder may send me 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, if it is not
mailed, 30 days after the date on which it is delivered to me.
(D) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back
for its costs and expenses to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorney's
fees.
PENNSYLVANIA - SECOND MORTGAGE - 1/80 - FNMA/FHLMC UNIFORM INSTRUMENT
Form 3939
5. THIS NOTE SECURED BY A MORTGAGE
In addition to the protections given to the Note Holder under this Note, a Mortgage, dated protects the Note Holder
from possible losses which might result if I do not keep the promises which I make in this Note. That Mortgage describes how and
under what conditions I may be required to make immediate payment in full of all amounts that I owe under this Note.
6. BORROWER'S PAYMENTS BEFORE THEY ARE DUE
I have the right to make payments of principal at any time before they are due. A payment of principal only is known as a
"prepayment." When I make a prepayment, I will tell the Note Holder in a letter that I am doing so. A prepayment of all of the
unpaid principal is known as a "full prepayment." A prepayment of only part of the unpaid principal is known as a "partial
prepayment."
I may make a full prepayment or a partial prepayment without paying any penalty. The Note Holder will use all of my
prepayments to reduce the amount of principal that I owe under this Note. If I make a partial prepayment, there will be no delays
in the due dates or changes in the amounts of my monthly payments unless the Note Holder agrees in writing to those delays or
charges. I may make a full prepayment at any time. If I choose to make a partial prepayment, the Note Holder may also require
that the amount of my partial prepayment be equal to the amount of principal that would have been part of my next one or more
monthly payments.
7. BORROWER'S WAIVERS
I waive my rights to require the Note Holder to do certain things. Those things are : (A) to demand payment of amounts due
(known as "presentment"); (B) to give notice that amounts due have.not been paid (known as "notice of dishonor"); (C) to obtain
an official certification of nonpayment (known as a "protest"). Anyone else who agrees to keep the promises made in this Note,
or who agrees to make payments to the Note Holder if I fail to keep my promises under this Note, or who signs this Note to
transfer it to someone else also waives these rights. These persons are known as "guarantors, sureties, and endorsers."
8. GIVING OF NOTICES
Any notice that must be given to me under this Note will be given by delivering it or by mailing it by certified mail addressed to
me at the Property Address above. A notice will be delivered or mailed to me at a different address if I give the Note Holder a
notice of that different address.
Any notice that must be given to the Note Holder under this Note will be given by mailing it by certified mail to the Note Holder
at the address stated in Section 3 above. A notice will be mailed to the Note Holder at a different address if I am given a notice of
that different address.
9. RESPONSIBILITY OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each of us is fully and personally obligated to pay the full amount owed and to keep all of
the promises made in this Note. Any guarantor, surety, or endorser of the Note (as described in Section 7 above) is also obligated
to do these things. The Note Holder may enforce its rights under this Note against each of us 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. Any person who takes
over my rights or obligations under this Note will have all of my rights and must keep all of my promises made in this Note. Any
person who takes over the rights or obligations of a guarantor, surety, or endorser of this Note (as described in Section 7 above) is
also obligated to keep all of the promises made in this Note.
t*V
Susan Murphy Long
(Sign Original Only)
Equity Note Modification
This is a Modification to a certain Note executed March 20, 2002, by Stephen M. Long
and Susan Murphy Long (hereinafter called Obligors), payable to Pennsylvania State
Employees Credit Union (hereinafter called Credit Union), dated March 20, 2002, in the amount
of $83,050.00 ($83,050.00) Dollars. This Modification is affixed to and becomes a part of the
said Note.
The Credit Union originally approved the loan based on the following repayment terms:
One Hundred Twenty Monthly payments of $1,029.26 each, which payments shall
include interest at the rate of Eight point Forty Nine (8.490%) percent.
Through a course of conduct, the parties, in fact, have agreed to a repayment schedule
under the terms of which the Obligor will repay principal and interest at a rate of interest
different from that specked by the original Note. There is currently an outstanding principal
balance due of Sixty-eight thousand eight hundred eighty-seven and 92/100 ($68,887.92)
Dollars. The parties have now agreed to amend the amortization of said loan. To that end, the
payment terms of said Note are hereby amended to read as follows:
Ninety One Monthly payments of $960.52 each, beginning October 1, 2004 which
payments shall include interest at the rate of Six point Forty Nine (6.490%) percent.
herein.
All other terms and conditions of the Note shall remain unchanged except as modified
Executed this.5-M- day of l
Susan Murphy lfn
Date: si 04
Date:
Date:
Credit Unio .
174' Z?l
Please deduct the m9dification fee equal to $100.00 from my:
- Share 1 _ Share 4 Other (Please specify: _
- I've enclosed a check or money order payable to PSECU.
Inq?rtunt Nodct
It is important to note
that the modification fee
of $100.00 is not a
prepayment of interest.
The modification fee is
strictly a processing fee.
PSECU does not believe
that there is any
deductibility of this cost
relative to payment .of
taxes. If you have further
questions about this
issue, please discuss it
with your personal tax
advisor
account.
0180542325-50
I
PSECO
the financial linkTM,
Member Number 0180542325
Loan Number 50
August 2, 2004
Stephen M. Long
Susan Murphy Long
Post Office Box 10614
Harrisburg, PA 17105-0614
Dear Members:
Enclosed is the Equity Note Modification we discussed. All obligors listed must sign their name(s)
exactly as they appear. Please return the Modification promptly in the postage paid envelope enclosed.
The total amount due is $100.00. It is important to note that the amount you are paying for this Note
Modification is not prepayment of interest. It is strictly a processing fee. PSECU does not believe- that
there is any deductibility of this cost relative to payment of taxes. If you have further questions about this
issue, please discuss it with your personal tax advisor.
We cannot complete your request for a modification unless we receive the enclosed Equity Note
Modification back from you prior to October 1, 2004. Please note that you are still required to make your
existing scheduled payment on September 1, 2004. Your first new payment will not take effect until
October 1, 2004.
Thank you for allowing us this opportunity to serve you. If you have any questions, please don't hesitate
to call us at one of the main office numbers listed below, our extension is 3885.
Sincerely,
1.-1 2
Lee D. Hunter
Service Advisor
Real Estate Servicing
Enclosures
PENNSYLVANIA STATE EMPLOYEES CREDIT UNION
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • (717) 234-8484 • (800) 237-7328
Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • (717) 777-2100 (TDD) • (800) 472-1967 (TDD)
Web Address: www.psecu.com
Savings federally insured up to $100,000 by the National Credit Union Administration.
Exhibit "C"
PSECO
03/20/2007
STEPHEN M LONG
SUSAN M LONG
742 ALLENVIEW DR
MECHANICSBURG, PA 17055
Dear STEPHEN M AND SUSAN M LONG:
The mortgage held by the Pennsylvania State Employees Credit Union
(hereinafter PSECU, we, us, ours) on your property located at 742
Allenview Drive, Mechanicsburg, PA 17055 is in serious default. The
total amount required to bring your account current as of March 31,
2007 is $14,407.80. Additionally, a regularly scheduled payment of
$960.52 is due April 1, 2007.
You have 30 days from the date of this letter to pay $14,407.80, plus
any additional payments that may fall due during this period. Such
payment must be made either by cash, a cashier's check, a certified
check or a money order and made payable to PSECU.
If the default is not cured within 30 days, PSECU will exercise our
right to accelerate your mortgage payments. This means that whatever
is owed on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original
mortgage by installments.
Additionally, we will instruct our attorneys to start foreclosure
proceedings. If your mortgage is foreclosed, your mortgaged property
will be sold by the Sheriff to pay off the debt.
If your payment is received after we contact our attorneys but before
foreclosure proceedings, you will be required to pay reasonable
attorney fees up to $50. If your payment is received after legal
proceedings begin, all reasonable fees, regardless of the amount, will
be added your loan. Only if payment is made within 30 days will you
avoid any legal fees.
If we foreclose and the sale of your property does not pay off the
total debt, then we may sue you personally for the unpaid balance and
all other sums still due.
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 717.777.2100 (TDD) • 800.472.1967 (TDD)
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender www.psecu.com
PSE(O
If you do not make your payment and foreclosure proceedings have begun,
you still have the right to make payment and prevent the sale at any
time up to one hour before the Sheriff's sale. You may do so by paying
the total amount of the unpaid monthly payments plus any other charges
then due, as well as the reasonable attorney's fees and the costs
connected with the foreclosure sale.
It is estimated that the earliest date of the Sheriff's sale would be
90 days from the date of this letter. A notice of the date of the
Sheriff's sale will be sent to you before the sale. Of course, the
amount due will increase the longer you wait. You may determine your
balance by calling me. Again, payment must be in cash or by a
cashier's check, certified check or money order and payable to PSECU.
You should realize that a Sheriff's sale would end your ownership of
the mortgaged property and the right to remain in it. If you continue
to live in the property after the Sheriff's sale, a lawsuit could be
started to evict you.
You have additional rights to protect your interest in the property:
• You have the right to obtain money to pay off the mortgage debt;
• You have the right to borrow money from another lending institution;
and
• You have the right to have the amount due paid by a third party
acting on your behalf.
You may have the right to sell or transfer the subject.property to a
buyer or transferee who will assume the mortgage debt, provided that
all the outstanding payments, charges and attorney's fees and costs are
paid prior to or at the sale, and that other requirements under the
mortgage are satisfied. Contact us to determine under what
circumstances this right might exist.
If you make full payment of what you owe, the mortgage will be restored
to the same status as if no default had occurred. However, you are not
entitled to this right to cure your default more than three times in
any calendar year.
If you have any questions, call 234-8484 in Harrisburg or call our
toll-free number, (800) 237-7328. At the menu prompt, enter 6 then
extension 3120. We are open from 8 a.m. to 5 p.m. Monday through
Friday and 8 a.m. to noon on Saturday.
Sincerely,
"T0_4?
Roxann Myers
Account Advisor
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD)
• This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender www.psecu.com
PSECO
03/20/2007
STEPHEN M LONG
SUSAN M LONG
742 ALLENVIEW DR
MECHANICSBURG, PA 17055
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS.
Dear STEPHEN M AND SUSAN M LONG:
The Mortgage held by the Pennsylvania State Employees Credit Union on your property
located at 742 Allenview Drive, Mechanicsburg, PA 17055 is in serious default
because you have failed to pay prompt installments of principal and interest, as
required, for a period of at least sixty (60) days. The total amount of the delinquency is
$14,407.80. This sum is good through March 31, 2007.
A regular scheduled monthly payment of $960.52 is required on April 1,2007.
You may be eligible for financial assistance that will prevent foreclosure on your
mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage
Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary
assistance if your default has been caused by circumstances beyond your control, and
if you meet the eligibility requirements of the Act as determined by the Pennsylvania
Housing Finance Agency. Please read all of this Notice. It contains an explanation of
your rights.
Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for
thirty (30) days from the date of this Notice. During that time you must arrange and
attend a face-to-face meeting with a representative of PSECU, or with a designated
consumer credit counseling agency. The purpose of this meeting is to attempt to work
out a repayment plan, or to otherwise settle your delinquency. This meeting must
occur in the next thirty (30) days.
If you attend a face-to-face meeting with a PSECU representative, or with a consumer
credit counseling agency identified in this notice, no further proceeding in mortgage
foreclosure may take place for thirty (30) days after the date of this meeting.
The name of PSECU's representative is the undersigned and may be reached at
PSECU's address or by calling (717) 234-8484 or toll free (800) 237-7328. This
representative's extension is 3120. The name and address of the consumer credit
counseling agency in your area is CCCS of Western PA 970-D South George St, York,
PA 17403, 888-511-2227. It is only necessary to schedule one face-to-face meeting.
You should advise PSECU immediately of your intentions.
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
• Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD)
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender www.psecu.com
PSE(*
If you have tried and are unable to resolve this problem at or after your face-to-face
meeting, you have the right to apply for financial assistance from the Homeowners'
Emergency Assistance Application with one of the designated consumer credit
counseling agencies listed above. An application for assistance may only be obtained
from a consumer credit counseling agency. The consumer credit counseling agency will
assist you in filling out your application and will submit your completed application to
the Pennsylvania Housing Finance Agency. Your application must be filed, or
postmarked, within thirty (30) days of your face-to-face meeting.
It is extremely important that your application is accurate and complete in every
respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a
decision after it receives your application. During that additional 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 that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 211 North Front Street, P. O.
Box 8029, Harrisburg, PA 17105. Telephone No. (717) 780-3800 or 1-800-342-2397
(toll free number).
If you choose to exercise your rights described in this notice, we cannot foreclose upon
you during that time. Also, if you receive financial assistance from the Pennsylvania
Housing Finance Agency, your home cannot be foreclosed upon while you are receiving
that assistance.
rely,
S,
1. 1
7*4--A3
Roxann Myers
Account Advisor
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 - 717.234.8484 - 800.237.7328
• Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 - 717.777.2100 (TDD) - 800.472.1967 (TDD)
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender www.psecu.Com
- PENNSYLVANIA STATE
EMPLOYEES CREDIT UNION
/ P.O. Box 67013
Hai linke Harrisburg, PA 17106-7013
ADDRESS SERVICE REQUESTED
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011.204"_; 02598
STEPHEN M LONG
SUSAN M LONG NIXIE .171 5E i 28 04'114/07
742 ALLENVIEW DR RETURN TO SENDER
UNCLAIMED
MECHANICSBURG, PA 17055 UNABLE TO FORWARD
MC: 171013701313 *1323-0^a.'7.t>S-2fi-2 I
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¦ Complete Items 1, 2, and & Also complete
Item 4 N Restricted Dehwy Is desired.
¦ Prim your regime and address on the reverse
so that we can return the card to you.
¦ Attach this cad to the back of the malipiece,
or onM* front If specs permits.
A. SWmhrre
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B. Recei red by (PA#9d Name) C. Date of
D. Is delivery address different from Item 1? ? Ye
u YES, enter delivery address below. ? Nt
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1. Article Addressed tD:
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STEPHEN N111G
SUSAN (G .
742 Ar LENVBW DR
MECHANICSBURG, PA 17055
a Service Type
? Csrtl/fled Map ? Bpm Map
O Regletered ? Return Receipt for M
? Insured Map ? C.O.D.
4. Restricted Depveyt (Extra Fee) ?
2510 0001 7023 0727
Return Receipt 102595-a
L2L0 E20L '0000 0'[52 b00U.
PSECO
03/20/2007
STEPHEN M LONG
SUSAN M LONG
PO BOX 10614,
HARRISBURG, PA 17105-0614
Dear STEPHEN M AND SUSAN M LONG:
The mortgage held by the Pennsylvania State Employees Credit Union
(hereinafter PSECU, we, us, ours) on your property located at 742
Allenview Drive, Mechanicsburg, PA 17055 is in serious default. The
total amount required to bring your account current as of March 31,
2007 is $14,407.80. Additionally, a regularly scheduled payment of
$960.52 is due April 1, 2007.
You have 30 days from the date of this letter to pay $14,407.80, plus
any additional payments that may fall due during this period. Such
payment must be made either by cash, a cashier's check, a certified
check or a money order and made payable to PSECU.
If the default is not cured within 30 days, PSECU will exercise our
right to accelerate your mortgage payments. This means that whatever
is owed on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original
mortgage by installments.
Additionally, we will instruct our attorneys to start foreclosure
proceedings. If your mortgage is foreclosed, your mortgaged property
will be sold by the Sheriff to pay off the debt.
If your payment is received after we contact our attorneys but before
foreclosure proceedings, you will be required to pay reasonable
attorney fees up to $50. If your payment is received after legal
proceedings begin, all reasonable fees, regardless of the amount, will
be added your loan. Only if payment is made within 30 days will you
avoid any legal fees.
If we foreclose and the sale of your property does not pay off the
total debt, then we may sue you personally for the unpaid balance and
all other sums still due.
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
• Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD)
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender www.psecu.com
PSECO
If you do not make your payment and foreclosure proceedings have begun,
you still have the right to make payment and prevent the sale at any
time up to one hour before the Sheriff's sale. You may do so by paying
the total amount of the unpaid monthly payments plus any other charges
then due, as well as the reasonable attorney's fees and the costs
connected with the foreclosure sale.
It is estimated that the earliest date of the Sheriff's sale would be
90 days from the date of this letter. A notice of the date of the
Sheriff's sale will be sent to you before the sale. Of course, the
amount due will increase the longer you wait. You may determine your
balance by calling me. Again, payment must be in cash or by a
cashier's check, certified check or money order and payable to PSECU.
You should realize that a Sheriff's sale would end your ownership of
the mortgaged property and the right to remain in it. If you continue
to live in the property after the Sheriff's sale, a lawsuit could be
started to evict you.
You have additional rights to protect your interest in the property:
• You have the right to obtain money to pay off the mortgage debt;
• You have the right to borrow money from another lending institution;
and
• You have the right to have the amount due paid by a third party
acting on your behalf.
You may have the right to sell or transfer the subject property to a
buyer or transferee who will assume the mortgage debt, provided that
all the outstanding payments, charges and attorney's fees and costs are
paid prior to or at the sale, and that other requirements under the
mortgage are satisfied. Contact us to determine under what
circumstances this right might exist.
If you make full payment of what you owe, the mortgage will be restored
to the same status as if no default had occurred. However, you are not
entitled to this right to cure your default more than three times in
any calendar year.
If you have any questions, call 234-8484 in Harrisburg or call our
toll-free number, (800) 237-7328. At the menu prompt, enter 6 then
extension 3120. We are open from 8 a.m. to 5 p.m. Monday through
Friday and 8 a.m. to noon on Saturday.
Sincerely,
410,x"'
Roxann Myers
Account Advisor
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
• Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD)
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender www.psecu.com
. ? 4 .
PSECO
03/20/2007
STEPHEN M LONG
SUSAN M LONG
PO BOX 10614,
HARRISBURG, PA 17105-0614
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS.
Dear STEPHEN M AND SUSAN M LONG:
The Mortgage held by the Pennsylvania State Employees Credit Union on your property
located at 742 Allenview Drive, Mechanicsburg, PA 17055 is in serious default
because you have failed to pay prompt installments of principal and interest, as
required, for a period of at least sixty (60) days. The total amount of the delinquency is
$14,407.80. This sum is good through March 31, 2007.
A regular scheduled monthly payment of $960.52 is required on April 1,2007.
You may be eligible for financial assistance that will prevent foreclosure on your
mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage
Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary
assistance if your default has been caused by circumstances beyond your control, and
if you meet the eligibility requirements of the Act as determined by the Pennsylvania
Housing Finance Agency. Please read all of this Notice. It contains an explanation of
your rights.
Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for
thirty (30) days from the date of this Notice. During that time you must arrange and
attend a face-to-face meeting with a representative of PSECU, or with a designated
consumer credit counseling agency. The purpose of this meeting is to attempt to work
out a repayment plan, or to otherwise settle your delinquency. This meeting must
occur in the next thirty (30) days.
If you attend a face-to-face meeting with a PSECU representative, or with a consumer
credit counseling agency identified in this notice, no further proceeding in mortgage
foreclosure may take place for thirty (30) days after the date of this meeting.
The name of PSECU's representative is the undersigned and may be reached at
PSECU's address or by calling (717) 234-8484 or toll free (800) 237-7328. This
representative's extension is 3120. The name and address of the consumer credit
counseling agency in your area is CCCS of Western PA 970-D South George St, York,
PA 17403, 888-511-2227. It is only necessary to schedule one face-to-face meeting.
You should advise PSECU immediately of your intentions.
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328
• Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (fDD) • 800.472.1967 (TDD)
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender WWW.psecu.com
PSECO
If you have tried and are unable to resolve this problem at or after your face-to-face
meeting, you have the right to apply for financial assistance from the Homeowners'
Emergency Assistance Application with one of the designated consumer credit
counseling agencies listed above. An application for assistance may only be obtained
from a consumer credit counseling agency. The consumer credit counseling agency will
assist you in filling out your application and will submit your completed application to
the Pennsylvania Housing Finance Agency. Your application must be filed, or
postmarked, within thirty (30) days of your face-to-face meeting.
It is extremely important that your application is accurate and complete in every
respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a
decision after it receives your application. During that additional 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 that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 211 North Front Street, P. O.
Box 8029, Harrisburg, PA 17105. Telephone No. (717) 780-3800 or 1-800-342-2397
(toll free number).
If you choose to exercise your rights described in this notice, we cannot foreclose upon
you during that time. Also, if you receive financial assistance from the Pennsylvania
Housing Finance Agency, your home cannot be foreclosed upon while you are receiving
that assistance.
S' erely,
Roxann Myers
Account Advisor
Pennsylvania State Employees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 - 717.234.8484 - 800.237.7328
• Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 - 717.777.2100 (TDD) - 800.472.1967 (TDD)
This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender www.psecu.com
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or on the front If space permits.
1. Article Addressed to:
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STEPHEN M LONG
SUSAN M LONG
PO BOX 10614
HARRISBURG, PA 17105-0614
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B. Received by (Pnfnfed NarA I C.
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If YES, enter delkwy address below: 13 No
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4. Restricted Dellvay? (Fria Fee) p Yes
2. Article Number
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PS Form 3811, February 2004 Domestic Retum Receipt 102595-MM-1540
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to -<
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-04974 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PENNSYLVANIA EMPLOYEES CREDIT
VS
LONG STEPHEN M ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
LONG STEPHEN M but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
the within named DEFENDANT , LONG STEPHEN M
742 ALLENVIEW DRIVE
MECHANICSBURG, PA 17055
, NOT FOUND , as to
PER NEIGHBOR, DEFENDANT WORKS REALLY ODD HOURS AND LIVES
BY HIMSELF. NUMEROUS ATTEMPTS - UNABLE TO SERVE.
Sheriff's Costs:
Docketing 18.00
Service 36.00
Not Found 5.00
Surcharge 10.00
.00
f6/ca/b?- 69.00
So answers:
R. Thomas K7, one
Sheriff of Cumberland County
VAN ECK & VAN ECK
09/19/2008
Sworn and Subscribed to before
me this day of
A.D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-04974 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
PENNSYLVANIA EMPLOYEES CREDIT
VS
LONG STEPHEN M ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
LONG SUSAN M but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
the within named DEFENDANT
742 ALLENVIEW DRIVE
LONG SUSAN M
NOT FOUND , as to
MECHANICSBURG, PA 17055
PER NEIGHBOR, DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
So answers-
6.00
.00
5.00 R.JThomas line
10.00 Sheriff of Cumberland County
.00
?21.00 VAN ECK & VAN ECK
09/19/2008
Sworn and Subscribed to before
me this day of
A.D.
David D. Bueff
Prothonotary
KirkS. Sohonage, ESQQ
Solicitor
knee X Simpson
1" Deputy Prothonotary
Irene E. Morrow
2'd Deputy Prothonotary
Office of Me Prothonotary
Cum6erland County, Tennsy(vania
n8- q7 n CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R.C.P 230.2
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square 0 Suite 100 • Carfsfe, M 17013 • (717 240-6195 9 Tax (717) 240-6573