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HomeMy WebLinkAbout04-1502 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW Adams County National Bank, Plaintiff VS. Calvin L. Ott and Wendy L. Ott, Defendants No. 2oo4.-/x'o . Action of Mortgage Foreclosure To: Calvin L. Ott and Wendy L. Ott, Defendants 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 at~er this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing w/th 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 HIR1NG A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone Number: 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW Adams County National Bank, Plaintiff VS. Calvin L. Ott and Wendy L. Ott, : Defendants : No. 2004- Action of Mortgage Foreclosure To: Calvin L. Ott and Wendy L. Ott, Defendants AVISO USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes p~iginas, debe romar acci6n dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe antefiormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya pot la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFIC1NA LE PUEDA PROVEER 1NFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone Number: 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Adams County National Bank, Plaintiff VS. Calvin L. Ott and Wendy L. Ott, Defendants No. 2004. Action of Mortgage Foreclosure COMPLAINT IN MORTGAGE FORECLOSURE AND NOW, this ~'~ dayof ~1~'[ ,2004, comes Plaintiff, Adams County National Bank, by its attorneys, Puhl, Eastman & Thrasher, who brings this action in mortgage foreclosure against Calvin L. Ott and Wendy L. Ott, Defendants, whereof the following is a statement: 1. Plaintiff, Adams County National Bank, is a national banking corporation organized and existing under the laws of Congress relating to national banks, with its main office at 16 Lincoln Square, Borough of Gettysburg, Adams County, Pennsylvania 17325. 2. Defendant, Calvin L. Ott, is an adult individual whose last known address is 386 Springfield Road, Shippensburg, Cumberland County, Permsylvarfia 17257. 3. Defendant, Wendy L. Ott, is an adult individual whose last known address is 12 Oakville Road, Carlisle, Cumberland County, Pennsylvania 17257. 4. Defendants are not in the military or naval service of the United States or its allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940, as amended. 5. On May 13, 2002, Defendants made, executed, and delivered a mortgage upon real estate hereinafter described to Plaintiff as Mortgagee, which mortgage is recorded in the office of the Recorder of Deeds of Cumberland County, Pennsylvania in Record Book 1758 at page 4536. A copy of said mortgage is attached hereto and marked as Exhibit "A". Said mortgage is incorporated herein by reference. 6. There has been no assignment of said mortgage. 7. The real estate subject to the mortgage is described as follows: Tract No. 1: ALL that certain tract of mountain land now or formerly of R.G. Himes; thence by the same, South 74 degrees East 61 perches to a stone; thence by land now or formerly of Goerge Clever, South 19 degrees West 136 perches to stones; thence by land now or formerly of John Stamey, North 45 degrees West 86 perches to a stone; thence by land now or formerly of Benjamin Helm, deceased, North 29 degrees East 58 perches to stones; thence by land now or formerly of C. Long, deceased, North 35 degrees East 44 perches to the place of BEGINNING. CONTAINING 51 acres 70 perches, more or less. BEING the same premises which Alice L. Monar, widow, by her deed dated January 28, 2000, and recorded in the Recorder of Deeds in and for Cumberland County in Record Book 216, Page 99, granted and conveyed to Calvin L. Ott and Wendy L. Ott, husband and wife, mortgagors herein. Tract No. 2: ALL that certain lot of land situate in Southampton Township, Cumberland County, Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a spike in the centerline of Legislative Route 21006 at the intersection of Legislative Route 21050; thence along Legislative Route 21006 South eighty-seven (87) degrees, seven (7) minutes West, one hundred fifty mad seventy-nine hundredths (150.79) feet to another spike in the centerline of Legislative Route 21006; thence along lands now or formerly of Lloyd Mowery, North eighty-four (84) degrees forty-five (45) minutes East, one hundred fifty and zero hundredths (150.00) feet to a spike in the centerline of Legislative Route 21050; thence along the centerline of said road, South eleven (11) degrees twenty-three (23) minutes East, one hundred eighty-three and seventy hundredths (183.70) feet, the point and place of BEGINNING. CONTAINING .618 acre more or less. The above description being taken from a survey entitled "Subdivision for Elder R. Whitmer" dated June 27, 1994, by Thomas A. Neff, R.S. 8. The present owners of the real estate subject to the mortgage are Defendants. 9. Said mortgage is in default because the payments of principal and interest, which have become due and payable on January 13, 2004, and on the thirteenth day of each month, thereafter, remain due and unpaid. By the terms of said mortgage and at the option of Plaintiff, the whole of the said mortgage debt and interest is immediately due and payable. 10. By reason of the aforesaid default, the following amounts are due in accordance with the terms of the mortgage: (a) Balance o f unpaid principal $110,549.61 (b) Interest from 1/14/04 to 3/23/04 $ 2,169.62 (Plus $21.96 per diem thereafter) (c) Late charges to 3/23/04 $ 109.12 (Plus $27,28 per month thereafter) (d) Attorney's commissions $ 8,453.95 TOTAL $121,282,30 11. The attorney's commissions set forth above are in conformity with the mortgage documents and Pennsylvania law and will be collected in the event ora third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the Sheriff's Sale, reasonable attorney's fees will be charged based upon on legal work actually performed. 12. The Combined Notice of Delinquency, which satisfies the requirements of the Notice of Intention to Foreclose pursuant to Act 6 of 1974 (41 P.S. §403) and the Notice of Homeowners' Emergency Mortgage Assistance pursuant to Act 91 of 1983 (35 P.S. §1680.401c), as amended, has been sent to Defendants by first-class mail, postage prepaid, and by certified mail, remm receipt requested. Copy of the Combined Notices of Delinquency sent to Defendants are attached hereto and marked as Exhibits "B" and "C". Said Notices are incorporated herein by reference. The Certified Mail Receipt (PS Form 3800) and Domestic Return Receipt (PS Form 3811) from the mailing of said Notices to Defendants are attached hereto and marked as Exhibits "D" through "G". Said Receipts are incorporated herein by reference. 13. The temporary stay provided by said Combined Notices of Delinquency has terminated. Defendants have failed to cure the aforesaid default. WItEREFORE, Plaintiff demands IN REM judgment in mortgage foreclosure for the sum of $121,282.30, plus interest from March 24, 2004, at a per diem of $21.96, additional late charges, costs of suit, and other charges collectible under the terms of the mortgage; for the foreclosure and sale of the mortgaged property; and for other relief as the Court deems appropriate. Respectfully submitted: PUHL, EASTMAN & THRASHER Attorney ID Number 77071 Attorney for Plaintiff 220 Baltimore Street Gettysburg, PA 17325 (717) 334-2159 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Adams County National Bank, Plaintiff VS, Calvin L. Ott and Wendy L. Ott, : Defendants : No. 2004-SU- Action of Mortgage Foreclosure VERIFICATION TO COMPLAINT IN MORTGAGE FORECLOSURE I, Susan M. Saylor, do hereby state that I am Assistant Vice President, Collections, of Adams County National Bank, that I am authorized to make this verification, and that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are tree and correct to the best of my knowledge, information and belief. I understand that this statement is being made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. /~usan m. Saylor / / ~ Assistant Vice President, Collections Adams County National Bank -- Commonwealth of P~n~j4v-nl- Space Above This l.,h:le For Recording Data -- OPEN-END MORTGAGE This Mortgage sect=es futute advances DATE AND PAR'fU~q. The date of this ~ottgage (Secudty ~n.qm~me~t) tS .., .M~...Y. ....... ...o...1.3...~....2.0..O..2. a~d the pan~e~, the~ ~ and tax Menfi~ca~on o.ml~ts, if tequhed, a~e a~ follows: MORTGAGOR: CALVIN L OTT WENDY L OTT 2588 SHIPPENSBURG ROAD BIGLERVILLE PA 17307 I-Jif checked, refer to the attached Addendum incorporated herein, for additional Mortgagors, their signatures and acknowledgments. LENDER: ADAMS COUNTY NATIONAL BANK PO BOX 3129 GETTYSBURG PA 173~5 2. CONVEYANCE. For good and valuable consideration, the receiPt and sufficiency of which is acknowledged, and to secure the Secured Debt (defined below) and Mortgagor's performance under this Security Inatr.meut, Mortgagor grants, barg.m% conveys and mortgages to Len~ler the following described property: SEE ATTACHED LEGAL DESCRIPTION 3 '~Tl~q'S ROAD 2 NElL ROAD SHIPPENSBURG Pemmylv~ni~ 17257 (Addr~s) (cie,) (zip Code) Together with all rights, easements, appurtenances, royalti~, mineral rig~.ts, oil ~ gas rights, .crops, timber, all diversion payments or third party payments ,.mad.e t.o crop pro~uc .e?s, all water a~l riparian rights, wells, ditches, reservoirs, and water stock ami all existing ancO. future maprovements, s.Uuct~s.., fixtures, and replacements that may now, or at any time in the future, be part of the real estate ae$cnoea above (all referred to as "Property"). MAAIMUM OBLIGATION LIMIT. The total principal amount secured by this Security Instrumem at ally Olle time ~hal! not exceed $ ...,~.%.5.~..0.0..0...,.0..0 ............... This limitation of amount does not include interest and other fees and ebnrge8 validly made pursuant to thl. Security lustmm~t. Also, this limitation does not apply to advances ~.de under the terms of this Security I~trument to protect Lender's security ltllCl tO perform ally of the COVenants contained ii1 this SeClll'ity [n.~tr~tmetlto PEII~ISYLYAIIIA - AamClIL?UBALr:0MIdEIICIAt Id0RTOA;~ mT ~O~ ~ F~Ur. ~ OS VA U~. ~ ~T ml~ ~m ~u~o~.~ ~^ /pa~e ~ of ~0; ~ Ol~/~4Elarlk~'lS¥]st~lll,~PO~.,~t.~lou~JM,N FO~I~(~O.MT~i~PA 7/1~/2000 .~L~.-~ ~ __ % O~:~:'L :~r.'r, gftt O0'O00'S!l: ~ :,T,.hZt).OIAI~ bI'trorl .T.~O G ~(~ (~ .T..T-O ~ bIIArl~rD :E~btOEHO~ ~L,t~) 'sxtogm.~sqns ~o s'~og~g~pom 'sl~t,s,~ 'suo!s~olxo ,~!.~ ll~ ptm .~oloq p~q.uo~p lq~p ~.o o'Juop.t~ .m~po ~o (s),C.mmimg '(s)~m~oo '(Oo~ou ,bo~ .qmo~a fie ~o stm~ m:p ~ poJumo~. ~qoCI '¥ 9. DUE ON SALE OR ENCUMBRANCE. Lender may, at its option, declare the entire balance of the Secured Debt to be immediately due and payable upon tho creation of, or contract for the creation of, any lien, eno~mhrance, transfer or sale of the Property. This right is subject to the restrictions imposed by f~deral law (12 C:F.R. 591), as applicable. This covenant shall nm with the Property and ~ha11 remain ill effect until the Secured Debt is paid in full and this Security Insw!meut is released. 10. TRtN~Iq~R OF AN INTEREST IN '1'1~ MORTGAGOR. ff Mo~gagor ~ ~ mfi~ o~ ~ a ~ ~on (s~ ~ a ~omfion or o&er organization), ~n~ my d~d i~ate pa~t if: A. A b~fidfl ~te~ ~ MoKgagor is ~ld or ~. C. ~ is a ~e ~ o~p of ~ than 25 ~t of ~e vo~ stock of a ~fion or How~, ~ ~y not d~and pa~ ~ ~e ~ve ~fiom ff R is p~bit~ by ~w ~ of ~e da~ of ~s S~ ~t, I1. ElVI1T~' WARRANTIES AND REP~ATIONS; If Mortgagor is an rarity other than a natural person (such as a corporation or other organization), Mortgagor ~ to Leoder the following warranties and representations which shall continue as long as the Secured Debt r~maln~ outStslading: A. Mortgagor is duly organized and validly existing in Mortgagor's state of incorporation or organi7ation. Mortgagor is in good standing in all states in which Mortgagor transacts business. Mortgagor has the power and authority to own the Property and to carry on its business as now being conducted and, as applicable, is qualified to do so in each state in which Mortgagor operates, B. The execution, delivery and performance of this Security Instrument by Mortgagor and the obligations evidenced by the Secured Debt are within the power of Mortgagor, have beon duly authorized, have received all necessary governmental approval, and will not violate any provision of law, or order of court or governmc-utal agency. C. Other than previomly disclosed in writing to Lender, Mortgagor has not changed its name within the last ten years and has not used: any other trade or fictitions name. Without Lender's prior written consent, Mortgagor does not:and will not use any other name and will pre,rye its existing name, trade names and franchises until the Secured Debt is satisfied. 12. PROPERTY CONDITION, ALTERATIONS AND INSPECTION. Mortgagor will ~ the Property in good condition and make all ~l~aim that are reasonably necessary. Mortgagor ~ha!! not commit or allow any waste, impairment, or deterioration of the Property. Mortgagor will ~ the Property free of noxions weeds and grasses. Mortgagor agrees that the nature of the occupam-y and use will not substantially change without Lender's prior written consent. Mortgagor will not permit any change in any license, restrictive covenant or easement without Lender's prior written consent. Mortgagor will notify I.lmder of all d~'nanrks, procoed~s, clailns; alld actions against Mortgagor, and of any loss or damagO to NO portion of the Property will be removed, demolished or materially altered without Lender's prior written consent except that Mortgagor has the right to remove items of personal property comprising a part of the Property that become worn or obsolete, provided that such personal property is replaced with other personal property at least equal in value to the replaced personal property, free from any rifle retention device, security agreement or other encumbrance. Such zeplacem~t of personal property will be deemed subject to the security interest created by this Security Instrument. Mortgagor shall not partition or subdivide the Property without Lender's prior written consent. Lender or I.~nder's agents may, at Lender's option, enter the Property at any reasonable time for the purpose of iz?..cc?rig the Property. Lender shall .give M.ortgagor notice .at the time_of or before an inspection specifying a reasonable purpose for the mspecUon. Any mspectton of the Property slml be entirely for Lender's benefit and Mortgagor wili in no way rely on Iamder's i~s~Pecti°n' tt~a~e3ot~OJ 13. AIOTliORITY TO PERFORM. If Mortgagor fails to perform any duty or any of the covenants contained in this Security hstrummt, Lender may, without notice, p~form or cause them to be performed. Mortgagor appoints Lender as attorney in fact to sign Mortgagor's p~m~ or pay any amount necessary for perform,~ce. Lender's right to pedorm for Mortgagor ~h~ll not create an obligation to rP~srm' and Lender's failure to perform will not preclude Lender from exercising any of Lender's other under the law or this Security [ns~meut. If any construction on the Property is discontinued or not carried on in a reasonable manner, Lender may take all steps necessary to protect Lender's security interest in the Property, incl-a!~g completion of the consU-uaiou. 14. ASSIGNMENT OF LEASES AND RENTS. Mortgagor grants, bargains, and conveys to Lander as additional security all the right, title and interest in and to any and all: A. Existing or future leases, subleases, licanses, gua~nfies and any other va'ittan or verbal a~a~tts for the use and occupancy of any portion of the Property, including any extemions, renewals, modifications or substitutions of such agreements (all referred to as "I.eases"). B. Rants, issues and profits (all refen'ed to as "Rants"), including but not limited to security deposits, mlnlr~lm rant, pe~antage re/it, add/tional rent, common area m~i~,m~ce charges, parking charges, real estate taxes, other applicable taxes, insurance pz~Emm contributions, liquidated d~m~ges following default, cancellation premiums, "loss of rents" insurance, guest receipts, revanuas, royalties, proceeds, bonuses, accounts, contract fights, general intangibles, and all fights and c]~im~ which Mortgagor may have that in any way pertsin to or am on account of the use or occupancy of the whole or any part of the Property. In the evant any item listed as Leases or Rants is determined to be personal property, this Secur/ty Mortgagor will promptly provide Lender with U'ue and correct copies of all existing and future I.~ases. Mortgagor may collect, receive, anjoy and use the Rents so long as Mortgagor is not in default. Except for one lease period's rent, Mortgagor will not collect in advance any future Rents without Lender's prior writtan consent. Upon default, Mortgagor will receive Rems in lrust for Lender and Mortgagor will not commi~Sle the Rants with any other funds. Amollnts collected ~h~!! be applied at Lan~r's discretion to payments on the Secured Debt as therein provided, to costs of rnsn~ging, protecting and preserving the Property and to any other necessary rela~d expenses inc!-di~_g Lender's attorneys' fees and court costs. Mortgagor agrees that this assig~rru~.et is immediately effective between the parries to this Security Insu'umant and effective as to third parties on the recording of this Security Instrument, and this assi~man~ will r~m~in effective until the Obligations are setisfiad. Mortgagor agrees that Lender is mtitled to notify Mortgagor or Mortgagor's tanants to make payments of Rants due or to become due directly to Lender after such recording. However, Lender agrees not to notify Mortgagor's umants until Mortgagor defaults and Dmder notifies Mortgagor of the default and dem~ that M6rtgag0r and Mortgagor's tenants pay all Rants due or to be/oma due directly to Lender. On receiving the notice of default, Mortgagor will andorse and deliver to Lender any payments of Rents. Mortgagor warrants that no default exists under the Leases or any applicable landlord law. Mortgagor also agrees to mslntain, and to require the tenants to comply with, the Leases and any applicable law. Mortgagor will promptly notify Lender of any noncompliance. If Mortgagor neglects or refuses w anforce complim~ce with the terms of the Leases, than Lender may, at Lender's option, enforce compliance. Mortgagor will obtain L~nder's writmn authorization before Mortgagor consants to sublet, modify, cancel, or otherwise alter the Leases, to accept the surrender of the Property covered by such Leases (unless the Leases so require), or to assign, compromise or enc~mher the Leases or any future Ren~s. If Lender acts to m~sge, protect and preserve the Property, Land~r does not assume or become liable for its m~i~tanance, depreciation, or other losses or d~m~!es, except those due to Lender's gross negligence or imantional torts. Otherwise, Mortgagor will hold Lender harmless and indemnify Lender for any and all liability, loss or ~m~ge tha~ Lender may incur as a consequence of the assi~mant under this section. IS.LEASEHOLDS; CONDOMINIUMS; PLANNED UNIT DEVELOPMENTS. Mortgagor agrees to comply with the provisions of any lease ff this Security hsWamant is on a leasebuld. If the Property (page 4 of I0] includes a unit in a condominium or a planned unit developmeot, Mortgagor will perform all of Mortgager's duties under the covenants, by-laws, or regulatious of the condominiilm or planned unit development. 16. DEFAULT, Mortgagor will be in default if any of the following occur: A. Any party obligated on the Secured Debt fails to mske payment when due; B. A breach of any term or covenant in this Security Instrument or any other decument executed for the purpose of creating, securing or guarantying the Secured Debt; C. The ~ or furnlshln~ of any verbal or wriReo representation, statement or wan'anty to Lender that is false or incorrect m any material respect by Mortgagor or any person or entity obligated on the Secured Debt; D. The death, diasolution, or insolvency of, appointment of a receiver for, or application of any debtor relief faw to, Mortgagor or any other ]~rson or entity obligated on the Secured Debt; E. A ~ood faith belief by Lender at any ~ tiaa. t Lender is ~nseenre with ~ t.o .any ..person. or entity obligated on the Secured Debt or that the prospect ur any payment is unpmrea or me value of the Property is impaired; , F. A material adverse change in Mortgager's business lncl.udi~ ownership, m,n~gement, and f~n~r~elal conditions, which Lender in its opinion believes impau's the value of the Property or repayment of the Secured Debt; or G. Any loan proceeds are used fo.r a purpose that will con/ribute .to excessive em.sion of highly erodible land or to the conversion of wetlands to D _r~i_uce an agricultural commomty, as further explained in 7 C.F.R. Part 1940, Subpart G, Exhibit ivl. 17. REMEDIES ON DEFAULT. In some instances, federal and state law will require Lender to provide Mortgagor with notice of the right to cure or .o~ther notices and may establish time schedules for foreclosure actions. Subject to these limitations, if any, Lender may accel .er?e the Secured Debt and foreclose this Security Instrument in a m~nner provided by law if Mortgagor is .m default. . . .At the o tiun o.f ? any p? of..the c tes , interest, and prm pal eecome ~mmediar~ly olle anapayeDle, al~er giving notice 1~ requlreo oy law, upon me ooxurence ur a default or anytime thereafter. In addition, Lender shall be entitled th al/the remedies provided by law, the terms of the Secured Debt, this Security ~ and any related d~.. ~ts. All remedies are distinct, cumulative and not exclusive, and the Lender is entitled to all remedies provided at law or equity, whether or not expressly set forth, The. acceptance by Lender of any sum in payment or p..a.rtial payment on the Secured Debt after the balance .,m. due or is accelerated or after foreclosure proceedings are filed .~h~]l not constitute a waiver of Lender s right to require comPlete cure of _~,_y existing default. By not exercising any remedy on Mortgager's default, Lender does not waive Lender s right to later consider the event a default if it continues or happens again 18. EXPI~SES; ADVANCES ON COVENANTS; ATTORNEYS' ~; COLLECTION COSTS. Except when prohibited by law, Mortgagor agrees to pal( all of Lender s expenses if Mortgagor breaches any covenant in this Sec~it~ Instrument. Mortgagor w/ii also pa~, o..n de~m,nd any .a~_ unt. ~ by Lender for insuring, inspecting, preserving or otherwise prote~ting me Pro.~Ct~. and Lentler s security interest. These expenses will bear interest from the date of the payment until paid in full at the highest interest rate in effect as provided in the terms of .the Secured .De§t: Mort~a§.or. agrees w pay. all costs expenses incurred by Lender il~ coliectmg., enforcing o.r prot ..e.c.tm.~..Lenaer s rights ~ remedies under this. Security lnstrmnent. This amount may include, but is not lnmted to, .a~t. omeys xees, court costs, an~ other legal expenses. This See.uti. 'ty, Ius.miment sh~]] remain in effect until released. Mortgagor agrees to pay for any recordation costs o/c suc/l release. 19. E~WIRONMENTAL LAWS AND HAZARDOUS SUBSTANCES. As used in this section, (1) Environmental Law means, without limitation, the ComPrehensive Environmental Response, Co sation and Li.a?ity Act (C C. LA, 42 U.S.C. ?ther f er , and laws, re{~ul, atious, ordinances, court o.roers, attorney general opnuons or interpretive letters concerning the pubhc health, safety, welfare, enVLronmen~ ~,~ ~ substance; and (2) Hazardous Substance means any xoxic, radioactive or h~,~rdeus material, waste, pollutant or colltnminnnt WhiCh has characteristics which render the substance d~n~erons or potentially dangerous to the public health, safety, welfare or envirorrmeut. The term includes, without limitation, any substances defined as ~hazardous material," "toxic substances," "hazardous waste" or "hazardous substance" und~ any FAlvironmental Law. Mortgagor represents, warrants and agrees that: A. Except as previously disclosed and acknowledged in writing to Lender, no Hazardous Substance has been, is, or will be located, transported, m~m.~actured, Ur. areal, refined, or h~ndled by any person un, under or about the Property, except in the orclln~ry course of business and in strict compliance with ail applicable Environmental Law. B. Except as previously disclosed and acknowledged in writing to Lender, Mortgagor has not and will not cause, contribute to, or permit the release of any Hazardous Substance un the Property. C. Mortgagor will immediately notify Lender ff (1) a release or threateoed release of Sub~ance occurs on, under or about the Property or migrates or threatens to migrate from nearby propo~; or (2) there is a violation of any Environmental Law concerning the Property. Iu such an event, Mortgagor will take all necessary remedial action in accordance with Environmemal Law. D. Except as previously disclosed and acknowiedged in writing to Lender, Mortgagor has no knowledge of or reason to believe there is any pending or threatened investigatiou, claim, or proceeding of any kind relating to (1) any Hazardous Substance located on, under or about the P~...p.erty; o.r (2) any .violation by Mo~agor or any tenant of any Environrtmutal Law. Mortgagor wili ~mmed~ately no,fy Lender in writing as soon as Mortgagor has reason to believe there is any such peudin~ or threatened investigation, claim, or proceeding. In such an eve~, Lender has the fight, but not the obligation, to participate in any such proceedin~ including the right to receive copies of any documents relating to such proceedings. Except as previously disclosed and acknowledged in writing to Lender, Mortgagor and every tenant have been, are and shall mmpi, in full compliance with any applicable Environmeotal Law. Except as previously disclosed and acknowledged in writing to Lender, there are no underground storage rsn~ private dumps or opeo wells located on or under the Property and no such ts~, dump or well will be added u~less Lender first consants in writing. Mortgagor will regularly inspect the Property, monitor the activities and operatious on the Property, and confirm that ail permits, licenses or approvals required by any applicable Environmental Law are obtained and complied with. Mortgagor will permit, or cause any tanant to permit, Lender or Lender's agent to enmr and Lnspect the Property and review all records at any ressouable ~m~ to determine (1) the existence, location and nature of any Hazardous Substance on, under or about the Proper~y; (2) the existance, locatinn, naCare, and magnitude of any H~r~ous Substauce that has been released on, under or about the Property; or (3) whether or not Mortgagor and any te~nt are in compliance with applicable Environmental Law. I. Upon Lender's request and at any time, Mortgagor agrees, at Mortgagor's expose, to engage a qualified environmental engineer to prepare an environmeutal audit of the Property and to submit the results of such audit to Lender. The choice of the environmental engineer who will pe~orm such audit is subject to Lender's approval. J. Le~ler has the right, but not the obligation, to porform any of Mortgagor's obligations under this sacdun at Mortgagor's expense. K. As a consequence of any breach of any representation, warranty or promise m~,te in th/s section, (1) Mortgagor will indemnify and hold Lender and Lender's successors or assigns hacmless from and against all losses, claims, demand, ~iabilities, d~m~ges, cleanup, reaponso and mmediation costs, penalties and expense, including without limitation all cos~:s of litigation and at~orueys' fees, which Lender and Lender's successors or assigns may susta/u; and (2) at Lender's discretion, Lender may rales~¢ this Security Instrument and in return Mortgagor will provide LeAder with collateral of at lesst equal value to the Property secured by this Security kmrument without prejudice to any of Lender's rights under this Security instrument. __ fP~g~ ~ of F. G, H, regardless of any -~E~- -~ ...... y ~.oreclosure .or sat~..f~.on .of this Security Inatriml~m ~r~,~,.,~, A.., ~'~i~'.~ang~°~u,u~e .r_o.~ or sny .mSl~. sit, on' ,y Lender of any or all of the ~,,-~%~. ,~.~ ~ : mau ~x~am~ to tile collffary ~ ller~Dy walve~. 20. C.ONI)EMN.A..TION: .Mortgagor. will give ~ prompt.ho, flee of any pending or threataned action, by ~p_n_v?.._ o_r_r~uc.,~uries ~o q.uro~e or ~.a~ ~y ? allo~ the Prorer~ through ~unde~-~Son, ??,_,:~,.~2r_?~y_?m~. ra~er~. ~. ortg~ag, or aumorges Lender to intervene m Mortgagor's n~me in any of the m~uVe UV.~,TI~ aotlOl~S Or cla~m~ Mortgagor assi~,~ to Lender ,k~ ...~.~..~a~ ~ ....... · *.,~,~. ~,~o wuu~.~:~.r w~m a ~on~mn~llon or otller ~g OI all or any o of the Pmno~q'v shall oe consid · · . . ,art._ ...... docnm~nt ~ ,- ~ ~ , u~:~ vi aunt, soclLrlty agreemerg or otller lien 21. INSURANCE. Mortgagor agrees to m~intain insurance as follows. A. M..ortgagor ~h.~.!l ~ .the Property ' _insured agsln~t loss by 'fire, flood, theft and other hn,~ls nnd .... m. me arno ·ana ror the periods that Lender requires. The insurance carrier ptOVlalilg tile ms~ai~ shnl] be chosen bY Mortgagor subieet to I-~nder's annroval ,a~hloh shM1 not be..u~...~ly withheld. If Mortgagor fails to mnintai~ the cov~a~e descri=~h~ ..may, at Le~a~ s opU.on, obtain coverage ro protect Leveler s rights m tim Pror~q-tv ~e terms of this S..ec~unty inst~m~llt. -- All insurance policies and reoewals .~hM! be acceptable to Lender and shall include a stn~d~rd .~mo,rtgag9 clause.; ..a~d, wh~'e applicable: 'loss payee clause. ~ Mortgagor ~ha]l immodiatel¥ notify Lenaer oF cancenauon or ~ermmatton ot the insurance. Lender shall have the riaht m :~r, ia th',, p.olici.~ and r.~ewals. If Lender requires, Mortgagor ~h~ll ~m~ediately give to-~'~ll-r~i~s .oi pma prenm~m~ and renewal 'notices. Upon loss, Mortga£or shall ~ive imm~liato. ance carrier and Lender. Lender may mnke proo~ of loss if" not made immodiately by Mortgagor. . oi .me .rroperty or w me ? .e~u~. L~e~t, w'netller or not then due at Lenr~r's appli,catlon of proceeds to prmctpal shall not exteald or postpone the ~ date of sche~u~x~)-a'v~t nor change the amount of any payment Any excess will be raid to the Mort~n~ar B. Mortgagor a~e~ to ~ntain compmh~usive general 1.iabil!ty insurance na~g Lander as an additional insured in an amount acceptable to Lender, msunng against ch~m~ arising from any accident or occurrence in or on the Property. C..Mortgagor agrees ~ ~main rentsl loss or business interruption insurance, as required by L~nder, m an amount equa~ to at least coverage of one year's debt service and ~-uir~l posits 0f agreed to seperat~ly m writing), under a form of pohcy acceptable to L~nder. 22. ESCROW FOR TAXES AND INSURANCE. Unless otherwise provided in a separate a~t, Mortgagor will not be required to pay to L~nder funds for taxes and iusurance in escrow. ~ ~_u~_.~ ms ~ee~.m. ty lus .~. ~t a?.Lomt.and indiwd.~al. If Mortgagor signs this Security ~ ~oes no~ s~gn an evil,ce o~ ae~t, Mortgagor aoes so only to mortgage Mortgagor's , ,:, . ,./~_ (page?oliO) interest in the Property to ~cure paymen~ of the Secured I~bt and Mortgagor does not agree to be personally liable on the Secured Debt. If this .~. ~_ty Insw~ment _secures a gt)~an~y between Lend~ and Mortgagor, Mortgagor agrees to waive any fights that may prevent Lender-from bringing any action or claim against Mortlagor or any pa~7 indebted.undor.t~, e obligation. ~ rights, may '.mcltide, but are .no.t limited to, any anU-doficiency or on, action laws. mortgagor agre~ mat J-enaer ano ~ny party to ttns Security Instrument may extend, modify or m~ke any change in the terms of this Security Instrument or any evidence of debt without Mortgagor's consent. Such a change will not release Mortgagor from the terms of this Security Insmm~at. The duties and benefits of this Security Instrument shall bind and benefit the successors and assigns of Mortgagor and Lender. 2$. APPLICABLE LAW; SEVERABIL1TY; INTERPRETATION. This Security Instrument is governed by the laws of the jurisdiction in which I.~nder is located, except to the extem otherwis.e required by the laws of the jurisdiction where the Pr_open~ is located. Any provision that appg_ints Lender as an agent is not st~bject to the provisions of 20 Pa.C.S.A. Section 5601 et seq. (Chapter 56; Decedents, F.~tates and Fiduciakies Code). Lender, by exerci~ng any of its rights ~,od~ this Security lnsmtment, does so for benefit of Le~er. This Seco~ity ImU'umem is complete and fully integrated. This Security Iustnuneat may not be amended or modified by oral agreement. Any section in this Security Instrument, atl~hments, or any agreement related to the Secured Debt that conflicts with applicable law will not be effective, unless that law expressly or impliedly pem~its the variations by written agreement, ff any section of this Security Instrument cannot be ~fforced according to its terms, that section will be severed and will not affect ~ enforceability of ~e re-~,aer ?f thiA_ Security lnsw~. Whe~v.. er used, the s'.mgu~.as shall include me plural and the plural the singular, lne c~tions and headings of ma sections of this Security ~t ~ for con.~enience onl}, ~ ~ not to_be used to interpret or dcu~me the terms of this Security Instrument. Time is or me ess~ce m this 5ecurity Inset. .?,6, NOTICE. Unless otherwise required by law, any notice shsli be given by deliverin~ it or by mailing it by first class rn~il to the at~ropfi_ate ,party's address on page 1 of this Seci~rity ~t, or to any other address designated in writing. Not~ce to one mortgagor will be deemed to be notice to all mortgagors. 27. WAIVERS. Except to the extent prohibited by law, Mortgagor waives any right to apprais~nom relating 28. WAIVER OF JURY TRIAL. To the extent not prohibited by law, Mortgagor and Lende~ knowingly and imontionally waive the _right, which the party may have, to a trlai by j~ury with respect to any litigation ~ from the Se~n'ed Debt, or any oth~ agreement execut~ in enajunetinn .with the E.~dance of Debt and this Mort~ge. Mortgagor and Leader each acknowledge that *hi~ section has ~ther bean brought to the att~atian of ~ac.~ party's legal counsel or that each party had the opportunity to do so. 29. U,C.C. PROVISIONS. If checked, the following are applicable to, but do not limit, this Security Instrument: [] Construction Loan. This Security Instmmeut secures an obligation incurred for the construction of an im2rovement on the Property. [] Fixture Filing. Mortgagor grants to Le~er a security interest in all goods that Mortgagor owns now or in the future and that are or will become f~xtures related to the Property. [] Crops; Timber; Minerals; Rents, Isles, and Profits. Mortgagor grants to Lendor a security interest in all cro~)s, timber, and minerals located on the Property as well as ail rents, issues,' and profits of them including, but not limited to, all Conservation Reserve Program (CRP) and Payment in Kind (P,BC~) paym~ts and similar govm programs (ail of which shall also be included in the te~m Property'). [] Personal Property. Mortgagor grants to Leader a security interest in all personal property located on or connected with the Property, including all farm products, inventory, equipment, accounts, documents, instruments, chattel paper, general intangibles, and all other items of personal property :1758P§l 5k3' Mortgagor owns now or in the f~mre ~l tl~ 'are used or useful in the con,~ruction, o.~_ .~p, operation, msnngemen~, or m~in't.g~,al~ of the Pwperty (~ of w~ ~hn~ ~ ~ ~ ~ ~e t~ '~'). ~e te~ "p~ p~ ~y ~cl~!~ pwp~ d~ ~ ~ho~old g~' s~ h ~on ~ a '~" lo~ ~ ~o~ te~ ~ de~ ~ ~p~le ~end ~o~ gong ~ ~ d~five ~t p~. ~ ~lln~ ~ ~n~n~ ~t. Moagagor ages ~ ~wl~ ~t ~s ~ ~t &~ ~ ~ a ~g ~t ~ ~y ~n, photo~c or o~ ~u~on ~y be ~ of ~ for p~ of ~cle 9 of ~ U~fo~ ~i~ ~. 30. ~ ~. If ch~, ~e fo~o~ ~ ~plic~le to ~ S~ ~: [] Line of Credit. The Secured Debt inc!n~ a revolving line of credit provision: Although the ._ Secured Debt may be reduced to a zero balance, this Security Iusm~ment will ~rnain in effect until [] Agricultural Property. Mortgagor covenants and warrants that the Property will be used principally for agricultural or farmi,g purposes and that Mortgagor is an individual or antity allowed to own agricultural land as specified by law. [] Purchase Money. This Security Inztn~m~nt secures advances by lender used in whole or in part to acquire the Property. Accordingly, this Security Iusmmaen*, and the lien hereunder, is and shall be construed as a purchase money mortgage with all of the rights, priorities and benefits thereof under the laws of the Commonwealth of Pem~ylvania_ [] Additional Terms. SIGNATURES: By signing below, Mortgagor, intending to be legally bound hexeby, agre~ to the terms and covenants contained in this Security Inslrument and in any attaclmaents. Mortgagor also acknowledges receipt of a copy of this Security instrument on the date stated on page 1. ....................................................................................... .(W~mess) ' ~ ' 0Vit~ss) ~ o5 ~.3/2002 (Sig..Aw/,e) (D~te) (S~gmm~e) (Da) (Wimess) (Wimess) [page 9 of lOJ COMMO~ OF ...~ ......... ~., ~ OF .~~.... } ss. ~, ~ ~, ~....~..... a~ o~.. ~.~ ~ ~., ~o~ ~ .................................. · e ~i~ offi~, p~ly ~-.~...~,...~..~ ..................... ......... ~...~.._ ex~ ~e ~ for ~e p~ ~ ~s w~f, I h~m (s~) Notarial Seal Sally J. W1rtder, Notary Public Shippem~burg Twp., Cumberland County My Commission Expires Feb, 13, 2003 Titlo of Officer COMMONWEALTH OF .............................. , COUNTY OF ....................... ;~v.,.'.. } ss. On this, the ................. day of .............................. before me .................................. the undersigned officer, personally appeared ................................................................ ................................................................ who acknowledged hlm~olf/herself to be the .......................... and that he/she as such ................................................................ being authorized to do so, executed the foregoing instrument for the purposes therein contained by signing the name of the ................................... by ........................................... as In witness whereof, I hereunto set my barut and official seal. My commission expires: (Scat) ......... ~'7;'~';'77"';7/'~ ........................... Title of Officer It is hereby certified that the address of the Lender within nsm~d is: .................................................. .~..~. ,e..o....~........~.. ~.~..o....m~.... ~.. ~.o.. ~.o.,x.. ~ .z..2..~...o.~ ...~3%..s. ~ .?,..e,... ~..~ 2 .~..2.s. .............................. lpage 10 of 10) Tract No. 1: ALL that certain Iract of mountain land now or formerly of tLG. I-llmes; thence by the same, South 74 degrees East 61 perches to a stone; thence by land now or formerly of Goerge Clever, South 19 degrees West 136 perches to stones; thence by land now or formerly of John Stamey, North 45 degrees West 86 perches to a stone; thence by land now or formerly of Benjamln Helm; deceased,. North 29 degrees East 58 perches to stones; thence by land now or formerly of C. Long, deceased, North 35 degrees East 44 perches to the place of BEGINNING. CONTA/NING 51 acres 70 perches, more or less. BEING the same premises which Alice L. Mortar? widow, by her deed dated Jnauary 28, 2000, and recorded in the Recorder of Deeds in and for Cumberland County in Record Book 216, Page 99, granted and conveyed to Calvin L. Ott and Wendy L. Ott, husband and wife, mortgagors herein. Tract No. 2: ALL that certain lot of land situate in Southampton Township, Cumberland County, Pennsylvania more particularly bounded and described as follows, to wit: BEGINNING at a spike in the centerline of Legislative Route 21006 at the intersection of Legislative Route 21050; thence along Legislative Route 21006 South eighty-seven (87) degrees, seven (7) minutes West, one hundred fifty and seventy-nine hundredths (150.79) feet to another spike inlthe centerline of Legislative Route 21006; thence along lands now or formerly of Llo3)~l Mowery, North eighty-four (84) degrees forty-five (45) minutes East, one hundred fifty and zero hunclredths (150.00) feet to a spike in the centerline of Legislative Route 21050; thence along the centerline of said road, South eleven (11) degrees twenty-three (23) minutes East, one hundred eighty-three and seventy hundredths (183.70) feet, the point and place of BEGINNING. CONTAINE~G .618 acre more or less. The above description being taken from a survey entitled "Subdivision for Elder R. Whitmer dated June 27, 1994, by Thomas A. Neff, ILS. SCF/EDULE'A' this to be recorded c '.m berland County PA Kccor c of Deecls Date: Jenuarv 15, 2004 ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort~mte on your home is in default, and the lender intends to foreclose. Sueeifie information about the nature of the d~fault/s orovided in the a~aehed pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM fI-IEMAP) may be able to help to save your home. This Notice explains how the program works. To see ffHE/VIAP can helv, you must MEET Wl'l'l-f A CONSLrMt~ CREDIT COUNSEJ_IIqG AGENCY W2rTItIb130 DAYS OF THE DATE OF Tills NOTICE. Take this Notice with you whon you meet with the Coun~elixtg Agency. The ,amc, address and ohone number of Consumer Credit Counsel/ng A~ncios servin~ your Count*' are 1/sted at the end of this Notice. If you have any anasfions, you may call the Penmvlvenia Hous/a~ Fi-~nce A~tencv toll free at 1-800-342-2397. (Persons with imm~ired hearing ca~ 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 exphin it. You may also want to contact an attorney in your urea. The local bur association may be able to help you fred a lawyer LA NOTi]tlCACION FaN Al)JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A COi~'£1NUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOI'J~'iCACION OBTENGA lUNA TRADUCCION IMMEDIATAMEI~TE LLAMANDA ESTA AGENCIA ('PENNSYLVANIA HOUSI2~G FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. ?UEDES 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 HII'OTECA. HOMEOWNER'S NAME(S): Calvin L. Oft PROPTERY ADDRESS: 2 Nell Road. Shioneasburg, PA 17257 LOAN ACCOUNT NO.: 600126293 ORIGINAL LENDER: Adams CounW NaflonalBank CURRENT LENDER/SERVICER: Adams County National Bank HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANC/AL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSU1LE AND I~ELP YOU MAWE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (TH.E "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASS/STANCE: · 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, · IF YOU MEET OTWI~,R ELIGIBILITY REQUIREMENTS ESTABLISHED BY TH_E PENNSYLVANIA HOUSING ]FINANCE AGENCY, ,, XHIBIT B TEMPoRARy STAY O1~ FORECLOSURE - Under the Ach you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from tiao el~,~ of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counsel/ng agencies listed at the end of this Notice. THIS MEETING MUST OCCUR V~tI'I'HI-N' THE NEXT (30/DAYS. 11~ YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. Tt~ PART OF THIS NOTICE CALLED "HOW TO CUP~ YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take aotlen against you for thirty (30) days after the date of this meeting. The names. addresses and teloohone numbers of desimmted consumer credit counseling a~eneios for the cotmtv in which the provortv 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 immediatslv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth hter in this Notice (see following pages for specific information about the nature of your default) If you have Ned and ere m,~ble to resolve this problem with the lender, you have the right to apply for/~n~ncial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sig~ and file a completed Homeowner's Emergency Assismuce Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling ageaeias have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Houshg Finunee Agency. Your application MUST be filed or postmurked v~tbln 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 'rm~ LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOiV[E IMIVfEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASS/STANCE W]I,L BE DENIED, AGENCY ACTION - Avaihble funds for emergency mortgage assistance arc very limited. They will be disbursed by the Agency under the eligibility trim-ia established by the AM. The Pennsylvania Housing Finance Agency has six~ (60) days to make a decision a.fax it receives your application. During that time. no foreclosure pro~eediugs will be pursued against you/f you bare met the time requirements set forth above. You will be notified d/reedy by the Penusylvania Housing Finance Agency of its decision on your application, NOTE: IF YOU ARE CURRENTLY PROTECTED BY TI~ FILING OF A PETITION IN BANKRIYFFCY, FOLLOWING PART OF TI~I,~ NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have ~ed bankruptcy you can still apply for Emergency Mort~gage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it uo to date). NATURE OF THE DEFAULT- The MORTGAGE debt held by the above lender on your propor~ located at: 2 Neli React Shiooensbur~, South Hampton Townshiv, Cumberland CounW, ?A AND 3 Tums Road, Shivpeasburg, South Hamvton Townshio, Ctmabm'land County, PA IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly naments of $909.39 due for November, December 2003 and January 2004, vlus vast due charges of $54.56 Other charges (explain/itemize): TOTAL AMOUNT PAST DUE: $2,782.73 B. YOU HAVE FArLKD TO TAKE THE FOLLOWING ACTION(Do not use if not atrolicable): HOW TO ~ THiE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO TH~ LF_i~ER, WHICH IS $ 2.782.73 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DLrE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash. cushier's check certified check or money order made navable and sent to: ADAMS COUNTn~ NATIONAL BANK P.O. Box 3129 GetWsbm~. PA 17325 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use ff not aovlicable.) IF YOU DO NOT CURE 'IHE DEFAULT - If you do not cure the default within Tt{IRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ri~his to accelerate the mort~a2e debt. Tiffs means that the entire outstanthng balance of tiffs debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly instzllments. If full payment of the total amount past due is not made within THII~TY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose uoon vour mortgaged vrooertv. IF Tu ~; 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 st/il be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegai proceedings are started agai~t you, you will have to pay all reasoashle attoruey's fees a~tually iucurred by the lender even ffthey exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also iuchde other reasonable costs. If you cure the default wlthi~ the 'rI~R'I'Y (30) DAY oeriod, yen will not be reauired to cay atiarnev's fees, OTHER LENDER REMEDIES - The lender may also sue yon personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE TKE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THRITY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and orevent the sal~ at any t/me uo to one hour before the Sheriff's Sale. You may do so bY navin~ the total amount then vast due, vlus any late or other charges then due, reasonable attorney's fee~and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as snecified in wrifin~ by the lender and by verformln~ any other remfirements under the mortgage. Curing your default in the manner set forth ia this notice will restore your mortgage to the same position as ffyou had never defaulted. EARLIEST POSSIBLE SHERII~'S SALE DATE - h is es~ms~ed that the earliest date that such a Sheri~s Sale of the mortgaged property could be held would be approximately 3 months from the date of this Notice. A notice of the actual date of the Sher//~s Sale wil/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 centering the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Fax Number: Contact Person: Adams County National Bank 16 Liaeoia Sauare, P.O. Box 3129 Gettysburg. PA 17325 (717) 359-1922 (717) 3598809 David W, Deaner EFFECT OF SHERIFF'S SALE - You should realize &at 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 O17 MORTGAGE - You may not sell or transfer your home to a buyer or/rausferee who will assume the mortgage debt, provided &at all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and &at ~ae other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: · TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF TH]5 MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTI rLrrION TO PAY OFF THIS DEBT. · TO HAVE THIS DEFAULT CULLED BY ANY THIRD PARTY ACTING ON YOUR BEHALF · TO HAVE ~ MORTGAGE RESTOKED TO THE SAME POSITION AS IF NO DEFAULT ~ OCCURRED, IF YOU CLrRE THE DEFAULT. (I-IOW'EVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAtL) · TO ASSF. RT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR A.NY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY TI-IE LENDER. · TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENC]]gS SERVING YOUR COUNTY PENNSYLVAbIIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES American Red Cross - Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 FAX (717) 637-3294 Financial Counseling Services of Franklln 31 West 3nt SWeet Waynesboro, PA 17268 (717) 762-3285 ADAMS COUNTY Consumer Credit Coumeling Service of Western PA 2000 Linglestowa Road Haxrisburg, PA 17102 (717) 541-1757 (717) 5414670 Adam~ County Homing Authority 139-143 Carlisle Street Gettysburg, PA 17325 717) 334-1518 FAX (717) 334-8326 American Red Cross - Hanover Chapter 529 Carhsle Street Hanover, PA 17331 (717) 637~3768 FAX (717) 637-3294 YORK COUNTY Consumer Credit Counseling Service of Western PA 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 (717) 5414670 Homing Council of York 116 North George Street York, PA 17401 (717) 854-1541 FAX (717) 845-7934 Consumer Credit Counseling Sm'vice of Western PA 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Consumer Credit Counseling Service of Western PA 970 South George Street York, PA 17403 (717) 8464176 Financial Counseling Services of Franldin 31 West 3'~ Street Wayaesboro, PA 17268 (717) 762-3285 Y'vVCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 243-3948 *Copies also ma/led to 3 Tums Road, Shippensburg, PA 17257 Ufoan League of Metropolitan Harrisburg 25 North Front Slreet Harr/sburg, PA 17101 (717) 234-5925 FAX (717) 232-4985 Date: Sanuarv 15, 2004 ACT 91/6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. S~eeific kfformafion about the nature of the default is vrovided in the attached ~ages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEM_AP) may be able to hel~ to save your home. This Notice exolaias how the ~rom'am works. To see if HEMAP can helo, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITH~ 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 Couuselin~ Agencies serving your Count~ are listed at the end oft, his Notice. If you have any auestions, you mav call the Penusvlwnis Housin~ Finance A~enc¥ toll free at 1-800-342-2397. (Persons with impaired hearin~ 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 aa attorney in your area. The local bar association may be able to help you fred a lawyer LA NOTIFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CO~TENIDO DE ESTA NOI'H0'ICACION OBTENGA UNA TRADUCCION IMMF~DIATAMENTE LLAMANDA 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 A~SISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERI)IDA DEL DER.ECHO A REDIMIR SU H i POTECA. HOMEOWNER'S NAME(S): WandvL. Ott PROPTERY ADDRESS: 2 Neil Road, Slrlooensburg, PA17257 LOAN ACCOUNT NO.: 600126293 ORIGINAL LENDER: Adams County National Balak CURRENT LENDER/SERVICER: Adams County National Bank HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU M~KI~, 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, · IF YOU MEET OTHER ELIGIBH,ITY 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. Durlag that time you must arrange and att~d a 'Tace-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. 1~ YOU DO NOT APPLY FOR F_2VlF_~GENCY MORTGAGE ASSISTANC]E, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PA,KT OF THIS NOTICE CALI.~D 'fi-IOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action aga~ast you for thirty (30) days af~ the date of this meeting. The names, addresse~ and teleohone numbers of desi~mated consumer credit counseling a~encies for the count~ in which the ~ropertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-te-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 tho 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 Progran~ 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 submittin~ a complete application to the Pennsylvania Housing Finance Agency. 'Your application MUST be filed or postraarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. Hr YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW 'l'i~E OTf~ER TIME PERIODS SET FORTH IN 'J'9~ LE'ITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENr~.o. 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 agalnat 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: n7 YOU ARE CURRENTLY PROTECTED BY THE FIlING OF A PET/llON IN BANKRUPTCY, THE FOLLOWING PART OF Tlqlg NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you liave fried bankruptcy you can still apply for Emergency Mortgage Assistance,) HOW TO CURE yOUR MORTGAGE DEFAULT (Brin~, it no to date). NATURE OF THE DEFAULT- The MORTGAGE debt held by the above lender on your property located at: 2 Neff Road. Shinpensburg, South Hampton 'l~ownshin, Cumberland County, PA AND 3 Tums Road, Shipvensbur~. South Hamoto~ Township. Cumberland Counts', PA IS SERIOUSLY IN DEFAULT because: A, YOU Is. AVE NOT MADE MONTI-ILY MORTGAOE PAYMENTS for the following months and the following amounts are now past due: Monthly vavments of $909.39 due for November. December 2003 and January 2004, ~lns oast due char~es of $54.56 Other charges (explain/itemize): TOTAL AMOUNT PAST DUE: $2,782.73 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION(Do not use if not avv~icable): HOW TO CURE 'lTd~ DEFAULT - You may cur~ the default wi'th!~ TI-HRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 2,782.73 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made ~ither by cask cashier's check, certified check or money order made ~avable and sent to: ADAMS COLrNTY NATIONAL BANK P.O. Box 3129 Gcrtvsbur~. PA 17325 You can cure any other default by irking the following action w/thin THIRTY (30) DAYS of the date of th/s letter: (Do not use ff not applicable.) IF YOU DO NOT CURE THE DEFAULT - Ifyun do not cure the default w/thin THIRTY (30) DAYS of the date of this Notice, the lander intends to exercise its ri~,hts to accelerate the morataee debt. This means that the entire outstanding balance of this debt w/Il be considewd 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 TI-IIRTY (30) DAYS, the lander also intends to iustmct its attorneys to start legal action to foreclose uoon your mort£a~ed orooertv. IF Tile MORTGAGE IS FORECLOSED UPON - The mortgaged property w/il be sold by the Sheriff to pay off thc mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquan~y 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, fflegal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incu_wed by the lender even ffthey exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. I_f yon cure the default within the THRTY (30) DAY oeriod, you will not be reouired to nay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you p~sondly for the unpaid principal balance and all other sun~ due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default w/thin the THPdTY (30) DAY period and foreclosure proceed/rigs have begun, you still have the right to cure the default mad urevant the sale at any time up to one hour before the Sheriff's Sale. You may do so by navin~ the total amount then east due. olus any late or other char~es then due. reasonable attorney's fees and cost~ connected with the foreclosure sale and auv other costs connected with the Sheriff's Sale as specified in writin~ by the lender and bY perform~, any other reaairements under the mort~e. Curing your default in the manner set forth hi this notice will restore your mortgage to the same position as ff you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - h is es6mzted that the earhest date that such a Sheriffs Sale of the mortgaged property could be held would be appro~mstely 3 months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of vourse, the amount needed to cure the default w/Il 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: Nsme of Lender: Address: Phone Number: Fax Number: Contact Person: Adams County National Bank 16 Lhieohi Souure, P.O. Box 3129 Gettysburg, PA 17325 (717} 359-1922 (717} 359-8809 David W. Deaner EFFECT OF SHEKII~'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged propea~y 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 furai.~hlu~s and other belongings could be started by the lender at any time. ASSUM?TION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt~ provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAV~ 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 TI-HS DEFAULT CURED BY ANY '13IIRD PARTY ACTING ON YOUR BEHALF · TO HAVE THE MORTGAGB RESTORED TO ~ SAlVIE POSITION AS IF NO DEFAULT HAD OCCLrRRED, 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 DOCUiVIENTS. · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. · TO SEEK PROTECTION UNDER Tt~ FEDEILAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES American Red Cross - Hanover Chapter 529 Carlisle Sueet Hanover, PA 17331 (717) 637-3768 FAX (717) 63%3294 Finanv, l.al Counseling Services of Framklin 31 West 3ra street Waynesboro, PA 17268 (717) 762-3285 ADAMS COUNTY Consumer Credit Counseling Service of Western PA 2000 Linglestown Road Han'isburg, PA 17102 (717) 541-1757 (717) 5414670 Ad-ms c0nnty Homing Authority 139-143 Carlisle Street Gettysburg, PA 17325 717) 334-1518 FAX (717) 334-8326 American Red Cross - Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 FAX (717) 63%3294 YORK COUNTY Consumer Credit Counsel/rig Service of Western PA 2000 Linglestown Road Harrisburg, PA 17102 (717) .541-1757 (717) 5414670 Homing Council of York 116 North George Street York, PA 17401 (717) 854-1541 FAX (717) 845-7934 Consumer Credit Counseling Service of Western PA 2000 L'mglestown Road Harrisburg, PA 17102 (717) 541-1757 Consumer Credit Counseling Servioe of Weatem PA 970 South George Street York, PA 17403 (717) 8464176 CUMBERLAND COUNTY Financial Counseling Services of Franklin 31 West 3~i Slreet Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 243-3948 *Copies also m211ed to 3 Turns Road, Shippensburg, PA 17257 Urban League of Metropolitan Harrisburg 25 North Front Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 2324985 (+ · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Js desired. · Print your .ams and address on the reverse so that we can return the card to you. II Attach this card to the back of the rnailpiece, or or] the fror]t if space permits. 1. Article Addressed to: Ca~vin L. Ott 2 Nell Road Shippensburg, PA 17257 2. Article Number (Copy from ~ervice label) Ps Fo~n 3811, Ju~ 1999 3. Service Type ~[ Certlt'~d Mail [] Express Mail [] Registered ]r'~Rsturn Receipt for Merctlendl~e r-~ insured Mail [] C.O.D. 4. flest~cted Delivery? (Extra Fee) I'-J y~ 7099 3400 000] 4861 9959 Domestic Return Receipt 102595-00-U-0952 2 Nell Road, Shlppensbur~, PA '=- ce~"~'~' 2.30 /' x/"----",,, ~ 2 Nell Road Shi PA ]7257 · Con'if=~ ~ I, 2, and 5. Also complete item 4 If Restricted Delivery is desired. · Print your name and address on the reverse ~o that we can return the card to you, · Attach this card to the back of the mailpiece, or on the front ff space permits. 11 Article Addressed to: Wendy L Ott 2 Neil Road Shippensburg, PA ]7257 2. Article Number (Copy from service labe0 F~ Form 3811, July 1999 A. Received by (/3lease F C. Sig rum D. Isde~k~yaddm~sdtffe~mimm/~7 r-1 y~ If YES, enter delivery address l~low; ~-I ~ 3. Service Type ]J~ Certified Mail r'l Express Mail I-I Registered J~] Return Receipt for Meecf3endi~e t-1 Insured Mail [] C.O.D. 4. Restricted Deliver,? (Extra Fee) [] Ye~ 7099 3400 000] 486] 9928 x?z.~?/-~,~?o h,,llh,,h,hhhl,h:,lhh,,h,lh,,~! I 3 Tu~ Ro~d, gh~ppo'~h.rg~ PA F .37 2 . 3o ,,//-'!:~,~,, ,., ~.7~ ~1 Potage & F~s ~ 4.42 .___C~lwin._7~ ~...~ t .t. .................................................. Turns Road ShlpDensbl~rg, PA 17257 Turns Road, Shippensbur~, PA Postage $ .37 Certified Fee2.30 $ 4.42 Name (Please Pdnt Clearly) (to be completed by mailer) ....~ .e_.n_._d.y._._L..,....O..t...t. ........................................................... 3 Turns Road "E~,' ~£d,'~Y¢;~ ........................................................................... SHERIFF' S RETURN - REGULAR CASE NO: 2004-01502 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ADAMS COUNTY NATIONAL BANK VS OTT CALVIN L ET AL RONALD HOOVER , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT OTT CALVIN L DEFENDANT at 2 NEIL ROAD SHIPPENSBURG, PA 17257 WENDY L. OTT, WIFE a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according FORE was served upon , at 2047:00 HOURS, on the 29th day of April by handing to to law, the 2004 - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 13.11 Affidavit .00 Surcharge 10.00 .00 41.11 Sworn and Subscribed to before me So Answers: R. Thomas Kline 05/05/2004 ADAMS COUNTY NATIONAL BANK SHERIFF'S RETURN - CASE NO: 2004-01502 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ADAMS COUNTY NATIONAL BANK VS OTT CALVIN L ET AL REGULAR RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon OTT WENDY L DEFENDANT at 2047:00 HOURS, on the 29th day of April at 2 NEIL ROAD SHIPPENSBURG, PA 17257 by handing to WENDY L. OTT a true and attested copy of COMPLAINT - MORT FORE law, the , 2004 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this // ~ day of -7~o.~,~ So Answers: R, Thomas Kline 05/05/2004 A~DAMS COUNTY NATIONAL BANK By: SHERIFF'S RETURN - CASE NO: 2004-01502 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ADAMS COUNTY NATIONAL BANK VS OTT CALVIN L ET AL REGULAR RONALD HOOVER , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE OTT CALVIN L DEFENDANT at 2047:00 HOURS, at THREE TURN ROAD SHIPPENSBURG, PA 17257 by handing to WENDY L. OTT, WIFE a true and attested copy of COMPLAINT - MORT FORE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 29th day of April the , 2004 together with and at the same time directing Her attention to the contents thereof. Additional Comments PROPERTY AT THREE TURN ROAD IS JUST MOUNTAIN GROUND. DEFENDANT WAS SERVED AT 2 NEIL ROAD SHIPPENSBURG. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 Affidavit .00 f Surcharge 10.00 R. Thomas Kline .00 16.00 05/05/2004 ADAMS COUNTY NATIONAL BANK Sworn and Subscribed to before me this ~1T~ day of V (:,~. ~, ~ ~;~ A.D. Prot~onotary~ By: Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2004-01502 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ADAMS COUNTY NATIONAL BANK VS OTT CALVIN L ET AL RONALD HOOVER , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE OTT WENDY L DEFENDANT , at 2047:00 HOURS, at THREE TURN ROAD SHIPPENSBURG, PA 17257 WENDY L. OTT a true and attested copy of COMPLAINT - MORT FORE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 29th day of April , 2004 by handing to together with and at the same time directing Her attention to the contents Additional Comments PROPERTY AT THREE TURN ROAD IS JUST MOUNTAIN GROUND. DEFENDANT WAS SERVED AT 2 NEIL ROAD SHIPPENSBURG, PA. thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this [/ ~ day of ~ ~,-~ 9~ A.D. " ~ Prothonotary -- So Answers: R. Thomas Kline o5/05/2oo4 ADAMS COUNTY NATIONAL BANK Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Adams County National Bank, : Plaintiff : VS. Calvin L. Ott and Wendy L. Ott, Defendants No. 2004-1502 Civil Term Action of Mortgage Foreclosure PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned Action of Mortgage Foreclosure as discontinued. Dated: May / O , 2004 PUHL, EASTMAN & THRASHER By: Attorney ID Number 77071 Attorney for Plaintiff 220 Baltimore Street Gettysburg, PA 17325 (717) 334-2159