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HomeMy WebLinkAbout08-6099 Donald L. Kornfield Attorney for Plaintiff Kornfield and Benchoff, LLP 17 North Church Street Waynesboro, PA 17268 (717) 762-8222 FAX 762-6544 don@kornfield.net Atty. I.D. #19242 PATRIOT FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS OF Plaintiff : THE 9TH JUDICIAL DISTRICT, PA. VS. TAMMY S. RUNYON a/k/a TAMMY S. COCHRAN Defendant : CUMBERLAND COUNTY BRANCH : CIVIL ACTION -LAW . # 08 - ?OQQ Civi( term NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claims 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 South Bedford Street Carlisle, PA 17013 Telephone Number: 717-249-3166 or 800-990-9108 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. PATRIOT FEDERAL CREDIT UNION Plaintiff VS. TAMMY S. RUNYON a/k/a TAMMY S. COCHRAN Defendant : IN THE COURT OF COMMON PLEAS OF : THE 9TH JUDICIAL DISTRICT, PA. : CUMBERLAND COUNTY BRANCH CIVIL ACTION -LAW #2008 - L 0 9 q Ct?'4 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, Patriot Federal Credit Union, of 800 Wayne Avenue, Chambersburg, Pennsylvania, brings this action to foreclose a mortgage dated August 21, 2007, between Tammy S. Runyon a/k/a Tammy S. Cochran, Mortgagor, and Patriot Federal Credit Union, Mortgagee, which is recorded in Cumberland County, Pennsylvania, at Instrument 407-34148, a copy of said mortgage executed by Defendant is attached hereto and made a part hereof as Exhibit A. 2. The land subject to the mortgage is situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, conveyed to Defendant Tammy S. Runyon by deed of Christopher L. Sommerville and Tina M. Sommerville, dated October 15, 2002, and recorded in Cumberland County Deed Book Volume 254, Page 317, a copy of which deed is attached hereto and made a part hereof as Exhibit B. 3. The mortgage has not been assigned. 4. Defendant is the real owner of the land subject to the mortgage and her address is 338 East Garfield Street, Shippensburg, PA 17257. 5. The mortgage is in default because Defendant has failed to make payments upon the Mortgage. Notice of default in the form of Act 91 was delivered to Defendant by first class mail with proof of mailing and certified mail dated August 21, 2008, and receipted by Defendant on August 28, 2008. Copies of the Notice and mailing receipts are attached hereto, made a part hereof and marked Exhibit C. 6. The following amounts are due on the mortgage: a. Principal, interest and late charges $48,353.37 b. Attorney's collection fee 7,253.01 Total $55,606.38 WHEREFORE, Plaintiff prays the court to enter judgment in mortgage foreclosure against Defendant in the monetary sum of $55,606.38 together with costs and interest at the contract rate after judgment. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. V PREPARED BY WHEN I7ECORDED, MAIL, M PkTX20Y taba:aM CX=ZT V=ott Boo YlhVIK . JLVZI pa 1.0. sox 770 CRUMERODURG VX 17201 UNIFn M PARCM IDE14TIR6t PFIEMISES: MORTGAGE THIS MORTGAGE Is made on.AmMIt 21. 2007 between the Mortgagor, 2ataaer 8 8U X99, 3X1 T3tMY 8 COCERIN, w$*U%e voAmtA, »e a Q*rft eld St SUPPfafb,ssa', PA 17757 (herein'Rorrower'), and the Mortgagee, R,e2nRar. re?„rr a corporation orgertizad and ex sting under tine laws of aftitEma-aziLtem address Is fee ?x7?,r? fy?.arn' -#*"?ffufra ? fo 17wA? whose r ._. (harem r'}, .. WHOI AS,13orrower le Indebted to !.ender in the pt9nclpal turn of V.& S s? _.,e _ en which Indettedness to evldenped by Borroweea note dated and extensions and ranewate thereof (herein •Notsb? pmvtdinp for monthly In ataaImefd$ principal and Interest, with the balance of the indebtedness, If not sooner paid, due and payabte on, IIa t2tY?zs TO SURE to lender the repayment of the Indebtedness evidenced by the Hole. with Interest thereon; the payment of all other sums, with Internet thereon, advanced In accordance therewith to protect the security of this Mortgage: and the performance of the covenants and agreements of Borrower herein contained. Borrower done hereby mortgage. grant and comrey to Lender the followino described property located In the County of n.zh,mz.,.a State of Pennsylvania! 6T/TT 3!DVd EXHIBIT A no -lV83G3d ) _ I SSITL9ZLTL 8080 800Z/L0/80 S= ATTA== -XZXT A which has the address of _aya m carlie2d gc ?, Pennsyhranla 172'a mP cons tuyl (herein "Property Address'): TOGETHER with all the Improvements now or haraaf ter erected on the property, And at easements, rlpChts, appurtenances and rents, all of which $11811 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 lease hha?lldd estate if this Mortgage 6 on a leasehold) are heretaafter referred to as the . Pro party . torrower wer covenants that Borrower Is lawfully seined of the estate hereby conveyed and has the right to mart 9. grant and convey the Property, and that the Prapmny is unanpmfbered. except for eftumbrences of room. Borrower covenants that Borrower warrants and will defend generally the title to the Property. against all claims and demands, subject.to-encumbrancoe.of. record. LKIPOFIM COVENANTS. Borrower and Lender Covenant and agree as follows: Savrow when Interest I debtednessidaricad bthe eNNote and late charg s as provided In 1F a ?e principal and 2. Funds for Taxes and kwirinee. Subject to applicable law or a writton waiver by Lender, Borrower shall pay to Lander on the day monthly payments of principal and Interest are payable under the Note, until the Note Is paid h full. a sum therein 4Funk1c*1 wh,mr 1n -2-00% .ws h_a?ny') whlah may attain prlorlt`y Overi?iis` Mo page Qrou rreemsian tge" hey rl opernrtl1rr ff sy plt s one-twelfth of yearly premium Installments for hazard Insurance, pies one- weltth of premium Installments for morlg a Insurance. It any, all as reasonably etdimated ill lWy and from time to time by Lander on the?asia of assessments and bills and reasonable estimates thereof. Borrower chap not be obligated to make such payments of Funds Sol Lander to the extent that Borrower makes such payments to the holder of a prior mortgage or deed of trust 0 such holder is An Institutional Lander. 0 Borrower pays Funds to Lander, the Funds shall be held In an kieltutlon the deposits or accounts of which are Insured or guaranteed by a federal or state agency (Including Lender 9 AACE2 MUVERAMq 6Z/ZZ 39Vd no -IVJ=d lOINIVd 89TZL9ZLZL 80:80 800Z/L0/80 Tammy S Runyon aka TA=y S. Cochran Exhibit AM tW=tdn Os Shlppusbsttg, Czanborl Ad g a lot ctgrorazd altnatr oa t Qsr6eld 8ts+eeR, in tlLe BOMS4 as 16Amva:', yenntylvfaia, mote pardieularly boc¢sded and desersbed BOUNDED M=OM On de on tbo North by said sts? on the Eat by lot now or fvs =IY of Albert A. famterty of Hetijarnin Roscc?b y err firm ly of Walter B. ReddIg; an the Rest by lot now or BEW'G that Santa real estate d W Allan 13- On= and Doris Jcan amen, k abead ad wife, by their dctd datod ;me 28,20M ud rotor died is flag office of the Recorder of Deeds is fad for O mberlftd Cow, ppMMylMLI& In Dead Book 226 at .Page 14. conveyed to F L So mmervitle and Tim M Som?ervills, httsbead and wife,. orantora balm , 'nX3>'IF[FaC with All and Aisstaw the bw7dir,Ss and iupovempu5, j ltroete. aileys, ddvewaya, peerages. wsteea, wdaramtrs", tights. llbrs*& V,80,3;, aPPMccUSoes,, wh4ts6ev0v mnti rite hereby Prernscs lmi hes'rd'Uoteata and "rtaidn& and aw ravers aw ad tematrsders, tom, b"M and && Or in Mywise tstate, t? a li ?4 Popery, dam and dtnd wbatwcrer of Win, 4- ? l nc? 1 equity, at 10 and to the same. SrgnE4 4 And tba OU Grcmtasa hereby ooveaamt and spec that they 1 OMW Weby tenveya . will warrant vecMy a I 6T/ET 30Vd no -lVH3Q3d 10I6IVd 89TTL9ZLTL 80:80 800Z/L0/80 Lender is such an Institution). Lander shalt apply the Funds to pay sold taxes, assessments, Insurance premiums and ground rents. Lender may not charge for so holdrng and tr>7piying the Funds ring sold account or verll I and con Nn9 said assessments and bile, unloass Lender pay s Barrows intererx on the Funds an0 ! WabIff law permits Lander to make such a charge. Borrower and Lendar may agree in wilting it, the lime of sxeMlo n of tttla Mortgage that Interest on the Funds shall be paid to Banower. and unless such agreement Is made or applicable !nw requires such interest to be paid. Lander shalt not be regdrad to pelt Borrower any interest at earnings on the Funds. Lander shall give to Borrower without charge, on annual accounting of the lands tthawIng credha and debits to the Funds and the purpose for which each debit to the Runde was made. The Funds are pledged as eddit(rlr44 securty for the sums secured by this Mortgage. a the amount of the Fonda heldby Lender, together wh the tutura monthly in froants of Funds pays prior to the due dates of taxes, assessments. Insurance ppttsmtums and ground tents, shall exceed, the amount roqulred to pay said taxe% assessments, inaursuios premium; and ground rents sla they fail due, such excess shall be at Borrower's option, slther prompthr ropald to Borrower or crydlted to Borrower on monthly Inotallntertts of Funds. If the amount ee[[ the hinds hold by hoarder shalt not be sutficiatt to pay taxes, assessments, Insurance premiums and ground rents as they fart due, Borrower shell pay to Lender any amount necessary to make up the defieieney in one or more payments as Lender may require. Upon payment In full of all sums sgeured by this Mon a s tendot shall prom91% refund to t90rrower any Funds held by Lender. i! under paragraph ?7gherodt tl,o Property oto or the Properly Is otherwise acquired by Lender, t nft shah Opp no later than immediately prim to the sale of the Pr rty or its acquisition by Lender. any nds held by Lender at the time of application as a creda against the sums secured by this Mortilp". s. Application of Poymenu Unless .amicable law provides athetw1se, an payments received by Lender under the Nola and paragrapha 1 and 2 hereof shell be appGad by tender first In payment of amours payable to Lender by Borrower under paragraph 2 tlereef, then to Inteneat payable on the Note, and then to the principal Of the Note. 4. PAw Mortgapsa and Useda of Trust; Cleat. Borrower shall perform all of Sorrower's obl? ions under any mortgage deed of iru or other security agreement with a Men which has peloftly over this Mortgage. lncQln Borrowers covenants. to make payments when due. Borrower shell ppy or cause to be paid all #Aaa. assessments ant other fd*des, fines and Impositions attributable to the Property which may stlahn a priority over this Mortgage, and leasehold paymlmta or ground rents. N any. 5. Heard Irlowlrpos. Borrower shall keep the Improvements now euist1ng or hereafter erected on the Propart'r Insured sgshot loss by lire hazwds Included wn the term 'extended coverage'. flood end such ether hazards a Lender may require and In ouch amounts and for such parldds as Lender may require. the Insurance carrier providing the Insurance shop be chosen by Borrower subject to approval by Lands; provided, that such approval shell not be unreasonably withheld. AN Insurance ppdudes and renewals thereof shall be in a form acceptabte to Lender and shall include a standard merle clause In favor of and in 8 form acceplable to Lender. Lender ahaN have the right to hold the poi?lea and renewals thereof, subject to the tarns of an mortgaA deed o1 trust or other security agreement with a Ilen which has priority over this Mortgage. In the event of loss, Borrower than g1vs prom .pt notice to the Insurance carrier and Lander. Lander matopartly h make proof of Ions d not made prartptl by Borrower. It the abandoned by Borrower or Ifyftrowor falls to respond to Lander within 30 days Irom the date notlrm Is maBsd Lsndsr to Borrower that the Insurance carrier offers to sale a Balm for insurance benefits. -Lender Is authorized to oolkct and apply the Insurance proceeds at Lender's option either to restoration or repair of the Property or to the suns secured y tubs Mortgage. 4. Presarvathm and Makenonee of property; Leasehoktet Cerniominkaner Planned Unit bsvaiaprfrente Borrower shestt keep this property l1 good repair and Inman not commit waste or emit Impalrment or deterioration of the Pr%ody_and inter comply with the provisions of any is it this Motto tie Is an At leseshokL If this ertps?e is on a unit In a condominium or a planned unit dsV meet, Borrower shelf perform ttA of Bdfrawere lots under the dselaralion or covenants creating or governing the condominium or amed unlit development. the by-laws and regutationa of the condominium or planned unit development, and constituent documents, PA090 fs, V M!'a0 I 6Z/bZ 39tid no _1VH3Q3d lOINiVd 89TTL9ZLZL 80180 800Z/L0/80 r• 7. protection of Lenders Security, 8 Borrower falls to pixfonn the covenants and agreements contained in this Mortgage or It any action or procesdina Is commenced which materially affects Lenders intereesstt In tote pro?erty, then Lander, at t.oonngoes option, upon notice to Borrower, may make such appearances, dt urse such sums, Including reasonable attorneys' toes, and take such cation as Is necessary to protect Lenders Interest. R Lender required mortgage insurance as a condition or making the ban secured by this Mortgage, Borrower shall p for such I suraannce terminatesrIn accordance fwsith Borroweea and Lenders tim wrt? forement or appficabie Isw. Any amounts disbursed by Lender pursuant to Note rate, shall become Additional indebtedness c ISO or and Lender agree to other terms of paymi trom tender to Borrower requesting payment there require Lender to Incur any expense or take any act 8.. Impaction. Lander may make or cause y. with interest thereon. at the ured by thisstryMortgage. Unless laained Votthts paarrograapht7 shall reasonable entries upon and ,ower notice prior to any such Interest In the Property. usages, dlriacl or consequential, opuny. or pars thereof or for r II be paid to Lander, au aament with a lion which has 10. Borrower Not Weaned; Axbearmtea by Lander Not a Wahre:r. Extension of the time for payment or modification of amortLWicn of the sums secured by this Mortgage granted by Lander to any successor in interest of Borrower shall not operate to release, In 82 manner, liability of the original Borrower and Borrower's successors In Interest. Londar aFtall not re required to commence proceedin s againgt ouch successor or refuse to extend tkne for payment at otherwise modify amertiateon of the sums secured by this Mortgage by reason of any demand made by the original BonVWer end 80ri'owees successors in Interest. An forbearance by Lander In exercising any right o remedy hereunder, or otherwise afforded by applicable We. shall riot be a waiver of or 8, Condemnation, The proceeds of any aws'N or claim fc In connection with any condemnation or other taking of thi then lsrnrals of lieu macpage deed Of trust orr ot?Raecuhty prlorit over this lillortgage. p 11 a eSuccewoors and Assigns any right or and egreomenta heroin contained shall xxueceescre and assigns of tender and All covenants and agreements of Borrow this Mortgage, but does not execute ! 'Borrow era Borrower's 12. Nc manner the flow! Wr w und; Johxt end Several Lilablift Co-signers. The covenants bind, and the rights hereunder shall inure to, the respective Borrower, subject to the provisions of paragraph 16 hereof, or shall be feint and several, Any Borrower who c"Igns ha Nola, ((a) In cc-signing this Mortgage only to mortgage, steel In the property to Lander under the terms of this on the Note or ender this Mon?ga and (c) agrees that rider may agree to extend, Mc+dify, forbear, or make any D the terms of this Mors??aa4N or the Note without that sing that Borrower or modityxxg this Mortgage as to that' ' 1. Wcept for any notice required under applicable ktw to be given in another y notleb to Borrower provided for In this Mortgage shall be given by delivering It or h notice by certified mall addressed to Borrower at the proper[ Address or et such m Borrower mayy desiggnate by notice to Lender as provkW heroin, and (b or shall be gluon by cc ifled mall to Lender s address stated herein or to such otheyr ider may designate by notice to Borrower as _provided hero. Any notice provided tga a shall be deemed to have been given to Borrower or Lander when given in the ated herein. ring 4rw• Scvarabigty. The state seta local laws applicsolle to this Mortgage shall be t juWletG In which the Property is located. The torsirohtg sentence shall not limit y of federal law to this Me age, In the event that any provision of clause of this is Note conflicts with appOcebla taw, such conflict shall not affect other provisions go or the Note which can be given effect without the conflicting provision and to Irovlslons of this Mortgage and the Note are dociaroll to be severable. Is used or limited m(r *attornsys' fees' include all sums to the extent not prohluted by ?? ? ExMrxEe? 61/91 39dd no -IVN3Q3d lOINIVd 89TTL9ZLTL 80:80 800Z/L0/80 i .. S 14. owmWera Borrower shall be fumished a conformed copy at the Note and of this M0112-611111 u the time a execution or after t+eeordation hereof. 1151• Ibhabllltetlon Matt Agreement. Borrower stall fulf0l all of Bxrower's obinjudans tinder envy home rehabilitation improvement, repair, or other loan agreement which Borrow sr enters into with Lander. Lander, at Lend&ea option. may requiro ftorrower to execeite and deriver to Lander, In a form ac. "table to Lander. an asalgrhmant of any rigMa. claims Or defenses which Bormwer may ha mad vvee toainstRparties who supply labor, materials or services in cornhection with Improvements 16, trahderaythe PrOpwsY Or a Bsnefktal httethwt In Bortvwer. If all or any pain of the Property or an Interest In it Is add ce transferred (or It a beneficial irdwest in Borrower is sold or transferred andy Borramer Is not a natural person) without Lender's prior written consent, Lender ,M. at its option, require lmmodats payment In full of an Gums secured by this Mortgage. fbweyer, Ms 0ppt?lon shall not be exercW by Lander 0 exorcise Is proaiblted by federal law. as of the date of this Mortgage. q Lender exerciste this option. Lender shall give Borrower notice of acceleration. The notice shall proylde a period of not loss than $9 days from the date the ncc,tice Is delivered or malted within which Borrower must all sums secured by this Mortgage. 0 Mower falls to pay these sums prior to the expiration this period, Lender may Inv a any remedies permitted n!? this Mort . whheut further notice or demand an Borrower. 4T-UNIrom RNAANfS. Borrower and tender further covenant and agree as follows; 17. Acceleration; ftetrtediee. upon Barnower's breach at env covenant or agreement of Mad rower In this MoK0age, InckWing the covenants to pay when due any stehhs aeourad this ffinnyorMtkins prior to aecelerMW salad give nothe to Borrower as provia law amtxlp a7Rher tlhl tic (11 !hs beetlatk 2) the action ro% red to sp• than a 0 dave from t date the r lea N matted to Ham er. by whkh such kflbIts) &h me t:urhrck and (qat More to cure such breach on or before ) Th the date spee]Hed In the notice may M&M In aacceleraltIon of the sums secured ?y this Yorlye9% toNalOata!e by cal Proo6wrig. and Gab of the Props . ' notice altgg fixtther inform Borrower at the r q to rew"te after acceleration and the r M tO "asst fn the fermbt EM th. w,.,...,,d..,..? we a h MMM or any ctfher defense of e feared an or befOta the data Specified In the the satins rrpound this Mon to be w and fns'I toradose flits M?ap?losJuldidal Procomi g all ettpens"O! fOMWk im 111 t? and tact of doctit, ntary ovlderhoe, aura mcte 15, Barrowees Malit to Rahnstate. Notwl by this Mortgage due to Borrower's breach, it bspun by Lo ndor to enforce this Mortgage befvro the commencement of bidding at a sh a) Borrower ppays tender all sums which w, ad no acceleration ocourre& fbl I;am, Y rsquim to eaeure that the I e 01;%olion to pay the sump chant and Caro by Borrower full force and offffebtt as If no a adonn"M anru t artowar herAeby a shah. prior to acceleration ur iaht to collect and retain sad acceleration folder f?aarregraA y agent or • by )udl0lSK m of and me'?g9 the Proper) All rents co acted by Len ft a ement of the Proport nPootttMARW to, reasonable, -aft- Lender's acoeteratlon of the sums hail have the right to have any pro Id at any time prior to at bast c Or other sate pursuert to this Ma on due under this ?Myortggage and I ,broaches of aA otheraaso!uh? ae •) ) Borrower pays Dr"Mente cf 8e er centsinec •tx ... moot Of Racefvor; Lender In Possession. As additional igns to Under the revue of the Property, provided that w paragratph 17 hereof or abandonment of the Property, ants as they become due and payable. 17 hereof or abandonment of the Property, tender, H oinlod receiver shah be entitled to enter upon, larks and to coffee the rents of the property lnolutl those eiver at d copectbh ors aril ts. Itkpoi nnclludi [Vat unt no mN nmtedd to.. PAGE a ORMta pts<rhl 62/91 39Vd no 1VN3Q33 lOINiVd 89TTL9ZLTL 80:80 800Z/LO/80 A premiums on recoWr's bond and reasonable attorneys' fees, and then to the sums secured by . this Mortgage. Lender and the receiver shall be Noble to account only for those rents actually received. 20. Release. Upon payment of all sums secured rby this Mortgage, Lender shall discharge this forrrelcasing irttg gise sl?p I'mittemeridt. of ap baglraw ihat L he Interest eapayable alter a zt. Wettest Hate After 8byori'oplw Judgment Is entered an the Notis or In an action of mortgage foreclosure shall be the rate stated In FECIUE T FOR NOTICE CW DEFAULT AND FOFMLDWIW UNDER SUPMOR MORTGAGES OR OEl DS OF TIRI T Borrower and Lender request the holder of arty mortgage, deed of trust or other encumbrance with a lion which has priorhy over this Mortgae to of" Notice to Lender, at Lender's address sot forth on page one o this Mortgage, default under the superior encumbrance and of arty gale or other foreclosure action. IN WITNESS WHEFCCOF. Borrower has executed this Mortgage.. Witness: `e WHOM" X w11r... X wq„? X aOftOrrN ? •??- x_ Pon at" NOW GT/LT 39Vd no -lVH3G3d 10INiVd 89TTL9ZLTL 80:80 8002/L0/80 wnv..w -- (Sal) 4 4 I hereby certify that the precise address of the Lender (Mortgagee) is, mz&r E>tlkv -Almir , OOMMONW64LrH OF PEMSYLVANIA, .-County on: On mis, the 22.4• . day of 71npt=-* -? lee7 ., before rne, officer. personally appowed the undersigned 9t - i known to me (or satisfactorily proven) to be the person(s) whose name(s) ,?? $ubsCrlbed to kmnm the within heroin contained. ned. eat and acknowledged that X13e_ executed the same for the purposes , IN WITNESS WHE3Edt. I hereunto set my hand and of I icial seal My Oommieefon expire9: flwl=x thiH14, _ T41e et mew PAO!7 smIgMOLT 6T/8T 30Vd no -lVN3Q3A 1OIaiVd BSTTL93LTL 80:80 80031L0180 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURMOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number. 200734149 Recorded On WI/2007 At 11310:53 ANT * lnetrument Type - MORTOAGE ImvoieeNumber -3556 User JI)-1AV Morlp pr - RUNYON, TAbIAiV S A fortpapee • PATRIOT FEDERAL CR UN • Customer-PATRIOT FEDERAL CR UN *FEES MTZ WRIT TAX $0.50 STATE =a/ACCESS TO $10.00 JUSTXCE RECORDING FEES $19.50 R£CORDZR OV DEEDS AYM74ZABLE hWaxrtc $11.50 COUNTY ARCSSVES FEE $2.00 ROD ARCRIV'ES SEE $3.00 TOTAL FA= 446.0 *Totsl Nps.. 9 Cerfifiestion Page DO NOT DETACH This J=ge is now part of this legal document. X Cerdry this to be recorded in Cumberland {County PA RECORDER O ' D - iaforma lso dm%W by an softrtsk may ebaap durooe the verif esdos preees, end may vivo be nowted an this Patt. 1I1IIII11:IIl1H 61/61 39Vd no IV7 GQ3d lOIdlbd 89ZZL9ZLZL 8080 800Z/L0/80 . Oct,01 2008 4:29PM HP LRSERJET 3330 p.3 L)16, go Tax Parcel I.D. No. 3a -,3? - 0???3- X 91 THIS I)FD MADE THIS day of October in the year of our Lord two thousand and two (2002 BETWEEN CNAISTOPHER L S'OKWRVILLE and TINA M. S0MMERVH-4E, husband and wife, of 338 E. Garfield Street, Shippensburg, Pennsylvania, hereinafter referred to as Grantors AND TAPJW S. RI3NYON, single woman, of 250 Pennsylvania Avenue, Carlisle, Pennsylvania, hereinafter referred to as Grantee WITNESSETH, that for and in consideration of the sum of Seventy Seven Thousand Five Hundred Dollars ($77,500.00), in hand paid, the receipt whereof is hereby acknowledged, the said Grantors do hereby grant and convey, in fee simple to the said Grantee, her heirs and assigns, ALL that certain lot, being a lot of ground situate on East Garfield Street, in the Borough of Shippensburg, Cumberland County, Pennsylvania, more particularly bounded and described 83 follows; BOUNDED on the North by said street; on the East by lot now or formerly of Albert A. Mason; on the South by land now or formerly of Walter B. Reddig; on the West by lot now or formerly of Benjamin Rosenberry. BEING that some real estate that Allan D. Green and Doris Jean Green, husband and wife, by their deed dated June 28, 2000 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 226 at Page 14, conveyed to Christopher L. Sommerville and Tina M. Sommerville, husband and wife, Grantors herein. . TOGETHER with all and singular the buildings and improvements, ways, streets, alleys, driveways, passages, waters, water-courses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging, or in anywise appertaining, and the reversions and remainders, rents, issues, and profits thereof; and all estate, right, title, internest, property, claim and demand whatsoever of them, the said , as ;,.= ..... well as law as in equity, of, in and to the same. ° >= ?- And the said Grantors hereby covenant and agree that they will warrant speciy t4 m =i property hereby conveyed. 3 O - N a rn C.0 2: rn r ..? o m -r 666K "'54 PAV U7 WEIGLE & ASS0CL4TEs. AC. - gTTORN ZTRCET - 3MIPPENSSUKO. PA 17237-1397 ff_ EXHIBIT 10/0112000 10:45:33 AM ' ' fnst# 20024169o. Page 1 of 3 0 Oct,01 2008 4:29PM HP LR9ERJET 3330 p.4 IN WMESS WHEREOF, Grantors have hereurrto set their hands and seals the day and year first above written. Sighed, Scaled and Delivered in the Presence of OA l? ?t Christopher. Somerville A 1 ? I Ate. ?? Tina M. So ' le Ali- , 9 4, ? P4 ? 0?0 M tooK 4 FAcf 318 WOOLK & " KSI9.6¦gr""LAW - 726 JfAST KING STREET - SHIPPENSBURG. PA 17257-139-7 10!01/2008 10.45.33 AM CUMBERLAND COUNTY Inat.# 200241860 - Page 2 of 3 Oct.01 2008 4:29PM HP LRSERJET 3330 COMMONWEALTH OF PENNSYLVANIA SS, COUNTY OF CUMBERLAND On this, the LS' day of October, 2002, before me, a Notary Public in and for said County and State, the undersigned officer, personally appeared Christopher L. Sommerville and Tina M. Sommerville, known to me (or satisfactorily proven) to be, the persons whose names are subscribed to the within instrument, and acknowledged that they executed the some for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARIAL SEAL LIENISEPINAMONTI,NO Public CarGele 8oro., Cumbertandovntll p.5 Re00rdCr I do hereby certify that complete post office address of the within named Grantee is: 338 S'hYCf- Z1.4Per%-b , 17x6-7. Date l? - F5-Ooh .r-- °,? Agen r Crrantee COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND SS. RECORDED on this day of , A.D. 2002, in the Recorder's Office of said County, in Deed Book , at Page 66ax .254 PACe 31s WE16LE A ASSOC[ATE6, RC. - ATTORNEYS AT LAW - 126 W.AST KING STACPT H rm p,(A IT4; Al 10109/2008 10:45:33 AM CUMBERLAND COUNTY Inat.# 200241690 -Page 3 of 3 Kornfield and Benchoff, LLP Attorneys At Law 17 North Church Street Waynesboro, PA 17268 www.kornfieldandbenchoff.com Donald L. Kornfield, Esq. Andrew J. Benchoff, Esq. Kimberly S. Runshaw Paralegal August 21, 2008 ACT 91 NOTICE Phone: 717-762-8222 Fax: 717-762-6544 don@komfield.net an drewnk orn fi el d .net TA-1'12%'-Ir'.-'JACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. EXHIBIT LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Tammy S. Runyon a/k/a Tammy S. Cochran PROPERTY ADDRESS: 338 East Garfield Street, Shippensburg, PA LOAN ACCT.. NO.: 5000061354 ORIGINAL LENDER: Patriot Federal Credit Union CURRENT LENDER/SERVICER: Patriot Federal Credit Union HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCY--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 counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your Lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the Lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date)NATURE OF THE DEFAULT--The MORTGAGE debt held by the above Lender on your property located at: 338 East Garfield Street, Shippensburg, PA, IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE THE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Months due: June, July and August 2008 Payments of Principal and Interest: $1,439.69 Escrow charges: Late charges: 25.13 Attorney Fees/costs: 50.00 Other charges (explain): TOTAL AMOUNT PAST DUE: $1,514.82 ' j B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): n/a. HOW TO CURE THE DEFAULT--You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,514.82, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Patriot Federal Credit Union P.O. Box 778 Chambersburg, PA 17201 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable ) n/a. IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the Lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire, outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the Lender also intends to instruct its attorneys to start legal action to 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 the Lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the Lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the Lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to Day attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by paving the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the Lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately three 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: Patriot Federal Credit Union Address: P.O. Box 778, Chambersburg, PA 17201 Phone Number: 717/263-4444 X4161 Fax Number: 717/263-8684 Contact Person: Lisa Chapman EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the Lender at any time. ASSUMPTION OF MORTGAGE--You may or x may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid to or at the sale and that the other requirements of the mortgage as satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY CCCS of Western PA, Inc. 2000 Linglestown Road Harrisburg, PA 17102 888-511-2227 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717-762-3285 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717-232-2207 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 717-232-9757 PHFA 2101 North Front Street Harrisburg, PA 17110 800-342-2397 PHFA 211 North Front Street Harrisburg, PA 17110 717-780-3940 800-342-2397 Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717-334-1518 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. KORNFIELD AND BENCHOFF, LLP Donald L. Kornfield DLK/ksr cc: Patriot FCU 4- ' n ,. U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: DONALD L KORNFIFI0 17 NORTH CHURCH STREET WAYNESBORO, PA 17268 One piece of ordinary mail addressed to: 3 c f- 72- PS Form 3tY11, January 2001 0 s O Dr in RNR,O O CT m '^ S O D D C L?y C r- s a179 g - mr N Zip 0? 5 N y© c. O -i iv M m -B (Domestic Mail Only; No Insurance Cover age Provided) f]" Information For deliver m y tr M ... t3d m Postage $ s /j 0 flJ Certified Fee ' -4 C3 C3 Return Receipt Fee t R i d d E 1 tmad P str Here ) ( orsemen equ re n Restricted Delivery Fee Ala .I)U ," r3 (Endorsement Required) Ln d,51. 49 t _ r 7 r9i Total Postage & Fees 0 CD Sent To C3 Street. Apt. 3 3 - -- - ------- - ?-f ----- - ? or PO Box No. o. ?rry State, Z, % 72 PS Form 3800. AL190st 2006 fCl W;I'LlChWl; ¦ Complete Items 1, 2, and 3. Also complete A. Signature item 4 if Restricted, Delivery Is desired. ? Agent ¦ Print your name and address on the reverse X 13 Addressee so that we can return the card to you. B. ived by rinted Name) C. Date qDAIvery ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: t?3 ?f / 57 D. Is delivery address different from Item 17 Yet If YES, enter delivery address below: ? No 3. Certified mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mall ? C.O.D. 4. Restricted Delivery? (Exba Fee) ? yes 2. Article Number 7008 0150 0002 0339 3096 (Transfer from service la s PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 r ? to ? CD u a SHERIFF'S RETURN - REGULAR CASE NO: 2008-06099 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PATRIOT FEDERAL CREDIT UNION VS RUNYON TAMMY S ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RUNYON TAMMY S A/K/A TAMMY S COCHRAN the DEFENDANT , at 0018:43 HOURS, on the 13th day of October , 2008 at 338 GARFIELD STREET SHIPPENSBURG, PA 17257 by handing to TAMMY RUNYON DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Posta e So Answers: 18.00 ?J 20.00 // 00 10.00 R. Thomas Kline /el1L?Op ?., 48.42 Sworn and Subscibed to before me this day 10/14/2008 KORNFIELD & BENCHOFF By: Deputy Sheriff of A. D. Donald L. Kornfield Attorney for Plaintiff Kornfield and Benchoff, LLP 17 North Church Street Waynesboro, PA 17268 (717) 762-8222 FAX 762-6544 don@kornfield.net Atty. I.D. #19242 PATRIOT FEDERAL CREDIT UNION Plaintiff VS. TAMMY S. RUNYON a/k/a TAMMY S. COCHRAN Defendant IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT, PA. CUMBERLAND COUNTY BRANCH CIVIL ACTION - LAW 08-6099 Civil Term PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT To the Prothonotary: Enter judgment in mortgage foreclosure in the monetary sum of $55,606.38 together with costs and interest at the contract rate after judgment in the above-captioned matter in favor of Plaintiff and against Defendant by default for failing to plead within the required time to the complaint which was endorsed with the proper notice to plead. K( By Date: January 29, 2009 PATRIOT FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS OF Plaintiff : THE 9TH JUDICIAL DISTRICT, PA. VS. : CUMBERLAND COUNTY BRANCH : CIVIL ACTION -LAW TAMMY S. RUNYON a/k/a TAMMY S. COCHRAN Defendant 08-6099 Civil Term AFFIDAVIT OF SERVICE I hereby certify that pursuant to Rule 237.1 of Pennsylvania R.C.P., I have given the requisite notice of entry of default judgment of ten days and that the filing of a praecipe for a default judgment is offered to the Prothonotary more than ten days after the mailing of the aforesaid notice to Defendant in the above-captioned matter. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. KC By Jan.30. 2009 1:52PM No. 8438 P. 2 Donald L. Kornfield Attorney for Plaintiff Kcrnfieid and Senchoff, LLP 17 North Church Street Waynesboro, PA 17268 (717) 762-8222 SAX 762-6544 don®kornfield.net Atty, I,Q. #10242 PATRIOT FEDERAL CREDIT UNION Plaintiff vs. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT, PA. CUMBERLAND COUNTY BRANCH CIVIL ACTION -LAW TAMMY S. RUNYON a/k/a TAMMY S. COCHRAN Defendant 08-6099 Civil Term TO: Tammy S. Runyon a/k/a Tammy S. Cochran DATE: November 4, 2008 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 SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 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. PA Bar Association Lawyer Referral Service P.O. Box 186,100 South Street Harrisburg, PA 17108 Telephone Number: 1.800-692-7375 Jail. 30. 2009 1: 1d2PM No. 8438 P. 3 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. KORNFIELD AND BENCHOFF, LLP By Donald L. Kornfield Attorney for Plaintiff `'?., ? ?? ? (? _: -t c? -? '' ?'_? "? C,J - o ? S?_ ?.. ,.? ?. . - ?? ?. _- .?. 4= _? ?;M .< Donald L. Kornfield Attorney for Plaintiff Kornfield and Benchoff, LLP 17 North Church Street Waynesboro, PA 17268 (717) 762-8222 FAX 762-6544 don@kornfield.net Atty. I.D. #19242 PATRIOT FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS OF Plaintiff : THE 9TH JUDICIAL DISTRICT, PA. VS. : CUMBERLAND COUNTY BRANCH : CIVIL ACTION -LAW TAMMY S. RUNYON a/k/a TAMMY S. COCHRAN Defendant 08-6099 Civil Term TRANSCRIPT OF JUDGMENT Judgment in mortgage foreclosure in the monetary sum of $55,606.38 together with costs and interest at the contract rate after judgment was entered in the above-captioned matter in favor of Plaintiff and against Defendant on ,g,&_?,3r , 2009. -A?? PZL;1PrC SATISFACTION OF AUTHORITY Acknowledgment not required when Power of Attorney is filed in Prothonotary's Office. The debt, interest and costs of the within judgment have been paid in full, and the Prothonotary is hereby authorized to enter satisfaction thereof. Witness any hand this day of , 20_ COMMONWEALTH OF PENNSYLVANIA) ) SS COUNTY OF ) (Individual Acknowledgment) On this _ day of , 20 , before me, the undersigned officer, personally appeared known to me (or satisfactorily proven) to be the person whose name(s) is/are subscribed to the above instrument, and acknowledged that he/she/they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. (Corporate Acknowledgment) On this _ day of , 20_, before me, the undersigned officer, personally appeared who acknowledged him/herselfto be the of -.6 corporation, and that he/she as such being authorized so to do, executed the foregoing instrument for the purposes therein contained by signing the name of the corporation by himfherself as ......... IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public Donald L. Kornfield Attorney for Plaintiff Kornfield and Benchoff, LLP 17 North Church Street Waynesboro, PA 17268 (717) 762-8222 FAX 762-6544 don@kornfield.net Atty. I.D. #19242 PATRIOT FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS OF Plaintiff THE 9TH JUDICIAL DISTRICT, PA. VS. CUMBERLAND COUNTY BRANCH : CIVIL ACTION -LAW TAMMY S. RUNYON a/k/a TAMMY S. COCHRAN Defendant 08-6099 Civil Term NOTICE OF FILING DEFA UL T JUDGMENT TO: Tammy S. Runyon a/k/a Tammy S. Cochran ( ) Notice is hereby given that judgment in mortgage foreclosure in the monetary sum of $55,606.38 together with costs and interest at the contract rate after judgment in the above-captioned matter has been entered against you on the gi tay of _'2009. ( ) A copy of all documents filed with the Prothonotary in support of this matter are enclosed. P thonotary By If you have any questions regarding this Notice, please contact the filing party: Donald L. Kornfield, Esq. Kornfield and Benchoff, LLP 17 North Church Street Waynesboro, PA 17268 (717) 762-8222 NOTICE MAILED: Prothonotary