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08-6570
Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS I ST FEDERAL CREDIT UNION PLAINTIFF Vs. MARY A. ALHAJ a/k/a MARY ANN ALHAJ DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA NO.: OB - (0547J) Civil-UM CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE TO DEFEND AND CLAIM RIGHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATTEMPTUNG TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 MEMBERS 1 ST FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. . NO.: MARY A. ALHAJ a/k/a MARY ANN ALHAJ : CIVIL ACTION - LAW DEFENDANT : MORTGAGE FORECLOSURE NOTICIA Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objections a las demandas en contra suya. Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS DERECHOS UsAPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THE THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUESTS US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 MEMBERS 1sT FEDERAL CREDIT UNION PLAINTIFF Vs. MARY A. ALHAJ a/k/a MARY ANN ALHAJ DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: Of- CIVIL ,., ACTION-LAW MORTGAGE FORECLOSURE COMPLAINT AND NOW, comes Members I" Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the following complaint: 1. Plaintiff, Members I" Federal Credit Union ("Members 1 sr), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Mary A. Alhaj a/k/a Mary Ann Alhaj ("Defendant"), is an adult individual IA*ng a last known address of $95-8 Geneva Drive, Mechanicsburg, PA 1'7055. 3. On or about October 30, 2006, Defendant borrowed from and agreed to repay to Members 1s'FORTY-THREE THOUSAND FIVE HUNDRED NINETY- I FOUR AND 97/100 ($43,594.97) dollars (the "Loan"). The Loan is evidenced by a Closed-End Note, Disclosure, Loan and Security Agreement dated October 30, 2006 (the "Note") executed and delivered to Members 1st by Defendant. A copy of the Note is attached hereto as Exhibit "A" and made part hereof. 4. As security for the Loan, Defendant executed and delivered to Members 1 st a mortgage ("Mortgage") on all that certain real estate and improvements erected thereon situate in Upper Allen Township, Cumberland County, Pennsylvania, known and numbered as 595-8 Geneva Drive, Mechanicsburg, PA 17055 (the "Property"). At all times relevant hereto, Defendant has been and continues to be the record and sole owner of the Property. A description of the Property is attached hereto as Exhibit "B" and made part hereof. 5. On or about November 28, 2006, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office at Mortgage Book 1974, Page 1410. A true and correct copy of the Mortgage is attached hereto as Exhibit "C" and made part hereof. 6. The Note and the Mortgage have never been assigned by Members 1st and is still held by it as a valid and subsisting obligation of Defendant. 7. Pursuant to the terms and conditions of the Note, Defendant agreed to pay to Members 1 st monthly installments of principal and interest in the amount of at least $545.30 each, which amount was subsequently adjusted to $544.78 each, beginning on December 1, 2006 and continuing on or before the first (1st) day of each month thereafter. 2 8. Defendant is in default of Defendant's obligations under the Note as a result of Defendant's failure to make the payments due to Plaintiff as set forth in the Note and as more particularly set forth and described in the Act 91 Notice attached hereto as Exhibit "D" and made part hereof. 9. Members 1 st gave written notice of its intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. seg., and in particular section 403 thereof, and of Defendant's rights in accordance with the Homeowners' Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. M by letter dated August 12, 2008, addressed to Defendant via certified mail, return receipt requested. A copy of the said notice is attached hereto as Exhibit "D" and made part hereof. 10. A copy of Postal form 3800 evidencing the mailing of said Notices is attached hereto as Exhibit "E" and made part hereof. 11. Simultaneously, Members 1St forwarded to Defendant the same Notices as set forth in paragraph 9 above addressed to Defendant by United States mail, first class, postage prepaid, bearing the return address of Members 1St. The Notices forwarded to Defendant in said manner have not been returned to the offices of Members 1St as undeliverable or otherwise. 12. As of November 7, 2008, Defendant is indebted to Members 1St in the amount of FORTY-FOUR THOUSAND TWO HUNDRED NINETY-ONE and 74/100 ($44,291.74) dollars itemized as follows: a. Outstanding principal $40,107.05 3 b. Interest to November 7, 2008 1,475.73 c. Late fees d. Attorney fees 108.96 2,600.00 f. Total due to Members 1st as of 11/7/2008 $44,291.74 The above attorney's fees are estimated and are in accordance with Defendant's agreements as set forth in the underlying Mortgage and Note. Defendant will be responsible for actual reasonable legal fees incurred by Members I" in this matter. 14. Defendant also agreed under the terms and conditions of the Mortgage that in the event of default there under Defendant would pay, in addition to the amounts set forth in paragraph 13 above, costs incurred by Members 1" as a result of the institution of these legal proceedings. 15. The obligation owed to Members I 't continues to accrue interest at the rate of $9.5488 per day, through the date of payment and continues to accrue late charges and attorney's fees. 16. As set forth above, Members I" has made demand upon Defendant to cure the default under the Mortgage and the Note. However, as of the date hereof, Defendant continues to fail and refuse to cure the default. WHEREFORE, Plaintiff, Members I" Federal Credit Union, demands judgment against Mary A. Alhaj a/k/a Mary Ann Alhaj in the amount of FORTY-FOUR THOUSAND TWO HUNDRED NINETY-ONE and 74/100 ($44,291.74) DOLLARS plus interest at the rate of $9.5488 per day, through the date of judgment entered on this complaint and at the legal rate thereafter 4 until the date of payment, additional legal fees and costs of suit and for Date foreclosure and sale of the mortgaged property. it ?/01? Respectfully submitted, 'Karl M! LedeUohm, Esq. Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff 5 5000 Louise Drive, P.O. Box 40 f 1st Mechan)csburg, PA 17055 MEMBIERS lw CLOSED-END NOTE, DISCLOSURE, I OAN ANn SFC(JR17Y AaRFFMFNT BORROWERS NAME AND ADDRESS MARY A ALHAJ MECMGENEVA 1RG. PA 17055 ACCOUNT NUMBER COBORROWERS MANE 8.699E PRRICIPALAt10UNr 51197 LDANNWaI R 177713 00•BORROWeRSNM4E 1 L a4A T % FIXED VARIABLE ANNUAL PERCENTAGE FINANCE CHARGE: ad:Thettrnountot Total of Payments: The amount RATE: The cost of your credit as a me dollar amount the credit will to you or on your you Will have paid after you have yearly rate. cost you. F made all payments as scheduled. 8.69 % a S 21,839.15 e e 131.1 S 85,434.42 VarxA7le Rate: a your loan has a variable rata as lMSCateO ubove the Annual Prcon", Rate may inomew duri g the tom, d this "-do. M der (odeA charges. Tho The rain will changlt rwnthly on this list day oT Om month. Thu rate will never la: higher than the misimum rain alkimml by in of to the IMMIX veflal h utbn will kl a mar g . ar oat taw, and it will n evr tar less then . Any interest rate krlexses will MSUN In alone pay-ms of the same amount. For Eawnplo, I your loan "a for S5.000 at 15% for 46 months and Wb Annual Percentage Rate In reasod by 2% alter one year, tub Wrm d your ban would increase by two months 'Preferred Rate: E chocked, the lollowing applies to your loam. © AUI1rMLW NPMUymsM DIacW eta: Bemubeen deor, win se you have agbaya1 W mNYe err nItYI111(I meal paymelWf arOYgh tln auk..Wu drwkilaml eDm 4 C.hefkil 'YY?IM,}f is PER in our AL Acmint xri u in a N n n I ? ca ? . y nt to slilkient tumd n your acco cassil intAi yrmrd Arrangement lre 10 b the euonwc W t yo u the AuMorMc Payownt Discounted Rafe. The nN Witt inverse by ..M%Y ment Disabnteit Rate is 10% our Auometk Pa l n e em It h f F l y your oa . s p e. e trm o or y cover the auWnwtie payments. W such a roue, ft affert ul the asaease twil be to extend t in 1 addiboW I pay"WeL 20% resultin our rate VAN increase Me 10 r emod k if g . , wa g . y pa"n on a S5A00.DD Ian for 60 rttonthe and you claw the 4NNar s Vwimlgo Rate P,efemxl Loans. If your horn is a vadhbw ram kw and you guaBy Itr a pndernd rein, your prefvnal 41scoue is taken at IM Met you take naa Yom loan. This loon's Wtial ANNUAL d i E bl d b a e m n a w a ove). For example. illtill ad ANNUAL PERCENTAGE RATE WIN than vary accmlldrhg W chvnnges M the Mika (Ns disdaa PER ENTAGE RATE is 12% atIh dime you tetra U,o kNRL ywr InaiMMfr preferred ANNUAL PERCENTAGE RATE will be N!A%. Your NWI pNemd ANNUAL PERCENTAGE RATE will then vary accurdnrg b db Min%. as ibcbsd in We'VwWbki RAhi provbkm above. = eared rate ban and you quality or a prelarrend rate, you ANNUAL PERCENTAGE RATE vas be the prelenad ANNUAL g! FIxwi Rate Preferred = = PERCENTAGE RATE I as Ir preferred status remake in erbn. Number of Payments Amount ef Payments Payment Frequency When Payments Are Due Property Insurance: You mag th obtainpropany ,le to insurannc?I from anyone ou want at 5 acceptao Yes We credit union. If"ydu et We insurance from the Paynr,va 119 $545.30 Monthly • Beginning 12101/2006 credit union you wall pay vM ba: e 1 $543.72 Final Due - On 1110112016 $ N/A wN w: Security: Cnllateef securing other bans with the credo union Ole aB IX DOW wile Id50 9eClre "a Mean. TYu wa rig;! seclatt inwrest in be,rgg plrCtwssd. - (Describe): RTGAGE ; F] D MO your yeses andNr deposit in Vie vclklunott and Late Char9u: it a yment k late by 10 days dr mom you will Requin'd Deposit Balance: The, Annual Percentage Rale dOlS Filing Feas: NonFIIW9 Insuranc0: he rrutn,?I a bu Ise oI S' your x.Baduled pnymaM. nnl lake into account you rrpu'rwl deposit Mlancu. s any. S NIA j WA Yy pay y ypu w opmya WW. ar Nry n ae rw areaoa maanspr 'epynwna rdudseuPenapo norlPr -yrW w ' ' es aYtn e I1 rw'IGM r.-Vr AMOUNT FINANCED S 43,594.97 Amount Paddtoothers an your behalf(Describe) AMOUNT GIVEN TO YOU DIRECTLY S 5.000.00 $ ebo To M-4a Ua S To jow To MWVM aua s To AMOUNT PAID ON YOUR ACCOUNTS 38.594.97 S To S To Sb.ue TO rant $ TO PREPAID FINANCE CHARGE $ 0.003 TO ?e°?1O°e S To iWeO 'a°'s OTHER (Describe): 585.8 GENEVA DR S --- I is 'IOU :aFea Uvd tai I,rrnli and condltiro in We disclosure stelomM, am Uie mar alt, ail. "'1";,•? Z ?-•••• 0_; -.. ^r - - -- ----- - pwn one Memo 1"" vre oxen tat at the conditions or the bhn and securitY agraNmess governing olds NMn stvna aptly te bdh},kKly and saverelly. You adunwMaV, that you owe rucdvud a copy of the ken ant at at the agreerMdrrs and disclosure daatrBnwN. C)'Irnnar, a YOU Am ei(F1n9 as co-signs. you acknow ilge racept of the rlwko to msig,w secuAty wrmined on page 2. ROWER'S SIGNATURE DA E CO•MAKER -O HEROWNER "CO-SIGNER DATE ISEAI) (SEAT] JM- CO-MAKER 0 -OTHER OWNER []"CO-SIGNER DATE 0 C6MAKER p'OTHER OWNER O "CO-SIGNER (SEAL) DATE X (SEAL) Q CO-MAKER 0-OTHER UMNER(]"CO-SIGNER DATE 13 CO-MAKER Q'OTHER ONMER0 --CO-SIGNER DATE X (SEAQ X (SEAy "witowca: AntpNS -am•wsPetyi-m Wow uwaa er'Arrn•A.almuw•aawa.rrm9ra amwNS,ya na•. na Nrr own'.wMS Nreaaw•Aw. Nr•AMNp,MmPq w•ax wAtwa'wnnuw ows umm?,wrasaubnaraAem•eesrwNaorNMW n,w a•cwIlYA9'?" ••?I•NGaau Ilse, eswA mAedn~"-A aaa•dN•pbaac0rm ur PerArw Nwry rr?e •A •mRae anon Awn tM eww4o w•a,••aarWnamrde,r,r a eywwm•awwr Iw'+atm{ey kw Aool MCATION FOR Gfi'OUP CREDR INSURANCE _ _ ._ 1. ?IAppaeele teal kWrwce cwvageary) Wlltyw tluds ape 70 m the sai asea midi" dale of you fwd! LJ u Y. (AppNwbab YwtltAyca+waga rnl alyw WUmm? Ape lOw We Sda,OWNnonr?oMad?a¦ben ANO SSyw Ora+antN waNMJ 00 ? O a ASMeyariewrvw+geta ppl V30 hounanwape wLr anti hanaeansdwaarg lu JO tleysamve ad ends ar6! NLY Inaddtdtb. syour Ininn y0MCOMMiS2y3w00a0a0a0nU?pmbcoLlalkDyMpng gibsUOn mustsssobomawap>,1din~otlMaN,e dfMIMI ? a ? O ,. UIa90u. IrAnneQ0m0ibreisY Symdalld OtIDS iAE, RIMMA, plea f?rlGTTalbd evwLlovary Ntsy eswsa, **a' ell (nd?CeM tlkllry c?PappariM ere War?34M'YY lodg,?y? ?ww e?id I le fd km Inca tp sn n?. Ma?Amae"9 S1.q?L NwtlUm WSpanmisna dgUlo la intents wa sal The dtadedate d rtelnu)bsuaca wM beawMadess UprawMlstM Tab Mn°wwpy wdwM NWnb Wmeud arryfrounnca mnpanY a? nmtuo Res I.N Ke ppaGde w sbaament w dakn con0antn9 unY opfw-e-ANY raise Inldm 11an nr -'2-- rtw a 17 M?w wNIaMinlOy. m?0rmatlan adnCRr,,YY?,,pp6y1 Flat miaarl0l bwM Nspacw lava i,alwWan?Cas pletd Ne QCaIOr MSfniW SMipewd 0.7100 da Mp,l a?twhalPPe nYePr W-tbawivAWMft dlds.ppleaUrn wit ra,l be tEndnux„KCSL 11MI, CREDIT INSURANCE APPLIED FOR: aNOOTTE?: ONLY ONE APPLICANT MAY APPLY FOR DISABILITY COVERAGE. C1 Yes Q No Single Credit Life Total Premium ? Yes Q No Credit Disabllty Total Premium ? Yes Q No Joint Credit Life tnlicab whirhapPiands): ? ApplkwX ID Ca.AppEOard SO-00 1nAk:ate which Appli.Ant(s): ID Applk wt ? Ce•Appifaml i S 0.00 MHG 6.4300.37 A MHC.9 r•62w 37 LASER.V!ORD r. 4376914av. vin jerks. bc. AI A001 fesomw. Exhibit "A" 1BORROWERS µyAE LOAN NUMBER Ap:OUNT NUMBER MTE OF LOAN MARY A ALHAJ?rry7g 177713 2510060. 1013012006 NAAAEDSAS BCOR OWER1S1T''E WORDS `CREDIT UNION' MEANS MEMBERS 1sT FEDERAL CREDIT UNION. THE WORDS *YOU: 'YOUR' AND YOURS' MEAN THOSE LOAN AGREEMENT rat tnel eamnue to $alW in GOnoaleni OWWI win-, u fa, to p any inswllmen, by _ e t me it is due. pay Allocation or Payments and Additional Payments: Payments and credits shall be applied in the following order, any amounts past due; any tees or charges owing, including any insurance premiums; accrued Interest or finance charrgges; outstanding principal. Payments made In addition to regdady scheduled payments shall be applied In the same order. Prrfn. d Raw: M you aualdy for a oreforretd rate as disclosed on page 1, of making payiv n and 'meet all obN dons under INS Agreement even if you no bpnger receive I'lo preferred rate. Late Char?gges: If make a late p nt, you ogee to pay a tare charge if one is dlSclos on page 1 of this documerlL Properlyy instrefhOe: If you obtain a loan secured by a motor vehicle or other targN3te popenv. Vou must Wain insurance which protects the credit union frmo^mh fina-nctal W The amount and covera99a? the properly ins,-n- must ppo accepabla to the cmd? mm. 5 a gt provide at least fire. flit ft. trombined add'Nounal coverages anEdtisgn insurance. N nest contain a Loss Payable clause enddrserment namng the t credit uraon as lien holder. You may obtain this insurance from am/ eat ur choice and direct thu agent to sand the credit union a copy W th licy. Debtor Res onsiblllty: You promise to notircredit Union of any change In r rmmP.. address aP employment You promse not to applyY for a ball If ou know Thera is n reesonab a oprraoDbabNhV that yau will be urfable to repay our obligation accordin to the c ms of 0he'crEdit extension. You promise o inform credit union of any new Information which relates W yyoOur ablity to rePa our obligation. You promise not to submit false or inact;urate. inPoihadon or willfuly conceal information regarding your creditworthiness. credit standing, or crt:da capacity. Statute Lien: If you are n defauR, IEeerel' ' gees uic urwn sera (s at tfwh0 ct Oa auh toa"sangt tlhlg rloan OncSy aresM dcatithe'aeit unio n may exercise this ng?ht vrnthout to or DICE to U. nlo ri InE ?undeer thstigroertie ffituv atwe ut losing Uienforcing any of the cradle uu Irregular Payments: The credit union may accept late pa Ls or partial pay en1S, even dtaugh merkeedd' yymme!nt in full, without posing any of rho crttdit union rights u at this agreemariL Cc-makers: N you are Ssqhg Oils agrearnam as a co,•nwker, you agree to be oquallyy rel Sues Wish Oho borrower, but the credit unions yanorury sue ekho or both Of youbee^ The credit Tllec^rad o^ u^bn rhave ee1Dihddffhb terns os agreement. hasrWl paid. Y Pesppo°sibilndy o^ this tgfee?ri y without notifying or rdeasehg you from Cmtmclual Pledtpt of Snares: You Pledge all your shams and depnshs N the Credit union. Including future addaams. as security for this ban. In rase you u yment dufeuht. the r,md t union may apppply these shares amt dWleslts to the pa at all sums due at the fne or elefyua,'irvAuckreg costa t rullertiun hind reasonable attorrey's rues. that the cedit union may Incur, up to 2e% of the unpaid Irkhcyhxl and intxrest. No lien or right to nywess a lion on shares air deposits shall apply to any of shams which may be hold in an "ndivWual Rvdrornara Accou I. or "Kec{ih Plan.` SECURITY AGREEMENT Cpq-lwros Incur bV the credit 1. To seclrn naNnUc or gals "W rid all ox rod union in dNeclipn M= wrlrug on a secuntYlrxnrast,you mrato der enwtk unknw?h this loa ssrunly l I% on p?gaxty tY:lenl:ed rn gDapp1 tithis doClarrtl see[irll interest inic, Wd:s all intrenses. prapiWta7nsaM add It N'iB0 lO1M all not ny. wn{Aerlxyclrom any Insu nce on the socu pwofxrty xml a .a r g$ fcow0l Iron tar ' seared properly. CmssCbNalard itat?ort: wmV ty q?ynrt as }aeurltfor this ban or for any other loan 6ansNer MgwI611tIb T7aINl unWn wllrsncr all amour s B owes the C Mlt union now anel n err t= However,gsgieny Recta another dalx ll not, in that loan I such lrorwn / n B rs pr I ms now (tin as the Iwo rose s7 sWn t7nuces at'o ^Wen a? any or Ierrppl mquafineras am sat lied). or are nca •jxrUwse o ? s n of, rw pander lhu rollxtimlAaWtlansl s you how 2. You rnM rnd? P ior ?"tio ? 3. ow u?axpat that tblhat ye?lhuwlt rfHEfadlI V1YN _us?yp?'l b'?f y Interest Ot ¦ ndllGMan:six ow the coMtaml tNq Ms sgneo rte egtQemonI in the indicated placu. 4. You wiN ow aN taxes. nl Bois Bea or attached n the y dusrrneb trio IrnMr 10 1 CropOnaryWar cvndfkwt in a sueable shi . Y o I1r ase2ue filsnrwavS ins and stw.yMMv rsWsat and we rkbM all PMWY aai?gqOmant a al eta aeeM union's Ilgerel adverse IMO party s. You will maintain irwurarn4 to caw?a OWCW a poperty m ohich the ov& union has a secs atlorest..mrs Inseam Min e l lone amt en amount Ih6 caQI union. You will e Onrte union win Ixnof aatls awl to of such iutenpr Gee on wins ovtgd_Iq _r PEN, seed Dv M1. ?aperty??red DNd Ir 1 s b?ararlo our ^wn rs I ark, Usr.0 In hn stains owirl. Tttlnia Wor in Be Conrad rate u peW liner ?g?prt to tie credit Union the to racaivs rte proceeds Of an rnW an 100P oft rr l R ocr aemry n pay_Nvtsdams unen. Yuu t l{cis i:MM unkM W n a cis m 1rhMe arms tnhw0l m t 1e Pe1a sac w srrance. amt appy rte rrWS union you lurihe aWwrim win the rnacassw iMormaC i?ort no Ik union tq provkle Yar kwanrscove Srageevice Cxnte ry for vrtl¢ation nl 1Wp . . acimywlbe Bxwelsrrnace. r uxensbn Yx. m1, oix;rd pv lM credit Vou v at wMoufMreet to you xdvantaay out s DnawlN lop Ina Orosxtan d ft trade B. u an. n fad al a r sx% etl he$ inf. u aemlr W ssin craral u vra n brio 1 allyy.s eewu Ind seCw h? rxodk Mn n eels is rearssary b prutecl flip 1xerM union rylanrst Prssark: to pay. at 6100 21.19 you arc bong asked bgu tuamae this debt. Think wlreN6Ityv before you do. If Oho btlrtower doesn't pay tine deal, you wiN have w. ell sere you can anoro co pay N you ha3e ro. end Ihal ou hNAM W Aaepl this respoRcidlky. You may have a pay up ro the full ainotlra of the debt Y 0he borrower does not pay. You may also have to pay lore tees or rblladlon costs. vAhich irluease W s amount mm yv r? ? t cTMan beeuxdcaageqinCeNS.I qi'a b?errosucn ? aWmrh?q t first lryinSf. ?SC?oy9otauar r? 5 etc. Ibar f ? •d?i ? eve dire d¢, r'hrtal f? ray bewm?e a p?arst o Your t r record. This no'lice is Ina thr. contract that make ?ouuhga61'e Thor,fie drhl. F. 43769 1/02 APPRO syrans, Inc. Vt 1o7s Page 2 of 2 m °a a°i1Y`nnIRX i 'we Zr A mow= ? : r'?yRl« T; "; 8w seuroy inapost which this agf*@Mrd uaste5 p pem is more than am bormwr. v n eons 4r der this eyeemnnt err: .Pus and sowral rear pefng Musa%rrepen3iNe b Ium the brhe d INS ahgrwanmenrty heh and a "went not only binds you. but W" executors. administrators. is. "co. CLOSED-END NOTE, DISCLOSURE, 5000 LOutse Drive, P.O. BOX 40 BORROWERSNAME AND ADDRESS MARY A ALHAI Mechanicsburg. PA 17055 5.8 G ? VA pR 59 ? C UtEABERS r aASeRlic, P?170.55 AACO E CWW_ iiu 251008-05 CO.aORROwER's NAME PRINCIPAL AMOUNT S41S94.97 LOAN NU B R 177713 Co SORROVIIIA1 NAME YECIP, MAT ? T X FRIED VARIME ANNUALPERCENTAGE FINANCE CHARGE: Amount Financed: The amount or Total or Payments: The aoaure RATE: The cost or yourcredit as a The dollar amount the credit will credit provided to you or on your you will have paid after you have yearly rate. • cost you. behalf. made all payments as scheduled. 8.69% S 21,777.93 $ 43,594.97 f 65,37290 vxieble Rale: N ban has a variable rata as bdlcaled about the Annual Percentage Rate may Increase do" the term of this I action X On pndell) %,v The rata will t5wge morditly on the *9 day of the math. The raft veil nMr lea Ilightx than mere nNUtYtsXowad by h of is the I dox value de tnbn oval MW a msr g . a taw, and a we nsvor De less ten . Any Itenot rate Increasers wil morn In more payments of dime sams amwN• Fm Exsrrple, K your lean was for 55.000 m t 5% fa E6 menhs and the Areptal Percentage Rile bcfeasod by 2% after ofe year. the term or your ban would increase by two months 'nPreferred Rata: II acyhemcaked, the rObwirq?atpaplks ID yOYr bpnhave : afire yeti requited nMy ps _ yet N?yS The ANNUAL PERCEN7AG MTE abtwo in Inc ANNUAL IP£RCENT?GE RATE two. Is 20% PERCENT RATE has Caen discounted nedbpyy ANANNiIAi ? . . . ccowt• your the Automatic Payment Discounted Rate. This reie wll Increase by.20% I cease the autainak Wyman S(rWg ant Of flu to maktain suachn fads b your aaaUM W cover the nuuntRedc ppaaymons. In such a case. t ha alrect of the Increase we be to emend the term of yaw loon. For example 0 ypu Automatic payment discounted Rate is 10% aw rate wa awmase to 10.20%. rasull}ngrkt 1 addaionat payment. emML ammatic ment aRen se th a k e0 h d c g y p y it s an you a e On a SS.000.00 ban mont VeriebleRea Preferred Loam. N your loan Is a vad" rate ban and you quably for a preferred rate. yaw praknad discount is taken n the One you eke O s your ban. This iNtinl pretared ANNUAL PERCENTAGE RATE will than very ac to changes in ft Index In dscbsed above). For example, If a variable fate bon's infidel ANNUAL PERCENTAGE RATE Is 12%al IM time you take theba+. yen _Nu prele ad ANNUAL PERCENTAGE RATE will be NIAW Your Initial preferred ANNUAL PERCENTAGE RATE will den vary accodkg to the Index, as dladosed in Ira Yedable Rate' provision above. Fixed Rea Preferred Loans. If your loan is a axed rate ban and you quality for a prcbnred rate, your ANNUM PERCENTAGE RATE will be the preferred ANNUAL PERCENTAGE RATE disclosed above for as long as luaus remains in ease, y Ope?ty Number of Psymdnta Amount of Payrnams PaymentFrequency When Payments Are Due 8f?r?y Insurance; You I Wham I x11 nraOCeptabk 10 oe"" ur'bn• IfYOU get IM insurance from the i B i hl = 6 al nn y - eg ng 121 119 5544.78 Mont 400 union pe wile Y f NIA Sd.w. 1 $544.08 Final Due • On 11/0112016 woo b. Secunry: Collateral securing Other loans with the cleft Ira goads a Dto Other ova also sacrwe this loon. You taro gm a sea'it IKaesr In behlg ptwc (Describe): on' yaw shares arwor Deposit in the credit unon e a MORTGAGE Lae Cterga: N a paymem isOle by 10 days ormaa you vent Ragdred Deposit Behrrs: Tim Annual Percentage Rile does FIR Fees: NomFiKng Insurame: rat eke he accent your required deposit bona. it any. f WA f r's'A aw scheduled poymen ea s We lad of 5% of ror b . y g e c PM ha. InIr1aYT rlWlpyrnYx. ^ Y `".?e:nw P'y .rte 1O p"y' ovialIT ISM"=Olrnia . my m4wol lgwp- w anmvopFrlw+?'Ekwasw PNal:ss. 111_rYIr LI111V1. VE AMOUNT FINANCED f AMOUNT GIVEN TO YOU DIRECTLY $ AMOUNT PAID ON YOUR ACCOUNT f PREPAID FINANCE CHARGE $ 43.594.97 Amount Paid to otterson your berme 5,474.09 S$'.' To kNSwsds Ub Soso To Mrewrda I" 38,120.88 $ To I To 0.00 5 To Read SOWbm S To 5 To $ TO $0.00 To I- $ To Ahee soulms OTHER (Describe): 585-8 GENEVA DR endlor Deposits of 1 f f .way...r.,..,R..,.....•...........-.__._--------- b-Wanm security - - ENS ban slaK amm sea whams Vw ..... r...,... an ary ageSl e then an line agu ft al me node: a co•sfgrke ou ore d9'd"9 n D" .you ackrnosbdga tecefpt den ore borrower. Ve ntx: H ren •si t C g en g . m o received a copy al Ua Security agreements and dbcbsEwa xa b wsit y conafnadon 2. SIGNER DATE O '' - BORROWER'S SIGNATURE DATE - C OTHER OWNER MAKER tSEAU X (SEAL) X CO•MAKER 13 'OTHER OWNER 0••CO-SIGNER DATE a CO-MAKER []'OTHER OWNER 0''CO-SIGNER t5E UTE X ISEAU X CO MAKER O'OTHER OWNER 0 "CO-SIGNER DATE 0 CO-MAKER a -OTHER OWNER 0 ''CO-SIGNER (SEAL) X (SEAL) X -eTNR awwEe: Aq naaw: •Awbaa • Pe.a•/ Aaraal Ina err: w E INerr N Nrrwl wtlaNM ONOaM TAMaaMlageMhae.llwNha pwwr,Y,aaraM ? G>mYa. bro abeawea w ea7l:.ea•M. V uww^ewE era OWE.aY°rhN a raaery bwelr mur mpaNEl naEPwoM err Yw r?N,q Aranrwa.'YAtlriwfR: Wen Mww.ew want unenr^aY EwE arww.ew Iwrnw^I leave nw.erwa a aM taw M Brenta eusa.tw bM tlr 9urNaararrwsal rwaww rrrrOrlR w alw wwMaMrreaaauba>! Yr.. _ _ _ _ ._._.._ _ ..__ 1?'(ApplcxhN l°wkwVelte wlmWwpye E^triyoMUaM T°. MINa.raa°70maw WwmesxaWeKaylaWnr fwd Ywtt lxMf y4t Iy LJ u u u OlM?lpo.?L NiONhxM°sm sa'eNx^YIO 30 der1+?w lwwb?MpFaw:belaMpiEaNEl9 Q ? ? O 7. ppA?wNyp ykyy?aa?1W?Y°Ilanr?Yier+et13g, 11Wa?pxyAOYt tar]DrwylwCSeSUy mae par d. Also b- wwww .Nm AIOS Roo fir. Cei1CM. MAI17w MaLN aNMyx:tNY?NMyfYOM°' ? ? prhyey, /,CyWra.°r°ar:r:yey dr[inc STwM tAI or Ny LyO xnwNE blM Eae:ie y:Raw.ereV:wblM ae11 d m1101w1 k..A.aaaeanpe?a tAaM?.t1iay ?a.wmArNR N I a11awN •N? w 41MMN°° t w a. vr.YNNNM:t YW aYs Pnf°n b rY.Y?W Iw ENUrenEe ilk ri nit W MwaO. Y my [a.appfcalY a 1 awwM Yes' b gYesam 3, M NnaNalana Yrl ova Nor apw txi InN+nN. W'° xn erra'nt' n°'.N''a°e^9 Slea. Th. etadiw taw d r Fly Nx ) 6-anv, wt b. ore dale or thx ? Nun. My pNSan who iOlwM^dY '° a °°^'^O° °• oar PNS°^ INax an EMdenEO wtal.. fa Moran N NMmtd claim oentM lNlq say mal.rlWyfalfe or mnc.M r°"pwaKadf xE er?Vltle miW?.I llrreboommNsafrNd~3nui Act P whichisaahwend Nlapds stlM pw6on aLTYdrW and lullpaWlla. Oemf xqh lNS W1?''ONim(Nw?ry( Ea°s Nw.TN. g0tMi nwiNnw be ureamcat.xEYNl appiable bWlk spaces tale -al bW wmpkhod. Ow dablar hxx nor aiy'°d xrddNlnd tw xpp5crion was N IM nppaolwrl has nit balm wM .ft CREDIT INSURANCE APPLIED FOR: NOTE: ONLY ONE APPLICANT MAY APPLY FOR DISABILITY COVERAGE. ? Yes E No Single Credit Life Total Premium ? Yes Q No Credit Disability Total Premium 0 Yes Q No Joint Credit Life Indicate which applicant(s): ? Applicant a Co-Applicant $0-00 mdrete which appTicarx(s): O AppYcam ? Cc-Applicant f 0.00 h1NC.911.43511.37 A COPYRIONT 1997 14- MwW CernpNww. IK. NI rghn -1.d. D+..,. 1 ..r ? NHC.9] 4200 37 USFA.wORO F. 43769 Rua. lAt IBORROWERSNAW IOANNWaFR ACCOUNT NIlY9ER DATE Or 10M MARY A ALHAJ ?7S 177713 251008(15 11/03/2D08 NEED AS 80R EMIE S)THE WORDS'CREDIT UNION' MEANS MEMBERS 1ST FEDERAL CREDIT UNION. THE WORDS 'YOU; 'YOUR' AND 'YOURS' MEAN THOSE LOAN AGREEMENT to Day. at sm alsW1r118nt by the ame a is am. you war pay tna overdue snout[. must us to meet close conditions m goer lD Rasp If you a1 to meet those conditions, your lisle will x tgng ran '=39"=" n. Yto carmue d ro meet an aaicader this ment even if you no amger receive the prererreop raw. yo a. agree to pay a fate charge Lttr or=. `d oan' papa i a'thliadocui et u I urance: If oblakl a ban secured by amore vehicle or a r to orapeMYYaouu must obtain insurance which aofeas the creel. urrcn firrerlMi IdsS. The amount and cOVaraeg9se of ttre prapeny klsaarl IH rrr[St be acrepable to the creel t union.5uch a pd must prov de at 1eas1 pre, ales cbmbhigd addkonM cow as and toatsial In ranee. K must wnlaln a Loss PPaysple clause endre?rsement nemin? the credit uron es hen holder. You rrwy DWaln Ws msurarlce ham an °a8nt or yyoabu choice and direct the agent to send the credit union a copy t Fancy. Debtor ResDerlsbility: You pr wit yaodv Ia amn Y2u ripryfN?se ow name less of You omlse to not union of ? know there is a raasaiebb pprr yy ai yojouur, od'rgat.ln . rdao to title tpnms of Bre a?t eldensbn. You promise to edam pack union d bry new adormacion relates to vyooatx ability to repayY yyq4uur obi Ion. You Dromise not to sUbrtit raise or )neccuraro inTOrfna40 a 1v11Mu1y conceeal ahiormefwnregarding yea uedeworthiness, credit standing. or credit y. Statutory Lien: If are in defaulL federal laves the creo. union It@ /a d s, in 9ccdunt(s) at rio to rs the b a d shalas arld te I, auk to swapry phi; loan. unhe nota In ou.a the credit t e ante of def to union may exsclse Ws rictj}n wrfotA lustier talcs to you. cing any of the credit Datay in Enforcement: Credo Ur11orl in Bela enfor union rights under this agreement vritit loslrl? them. ulamr PaymerMs:'The credit union may accept late payos * enr partial e Irrreq raa't uns. rns urleer this eeaihenlM In tut, wit MUt r any of the Co-makers: if you are sgign this aggrreeeemend as a ca,-m114f. yyou We to be equaky rasppoonnslble vnTh d% bo c r. but the Credit u may site either or both a roes The ceedk [anon does not have to nor you that Ws a9repentant has rroe been paid. The aedk union mey extend leans or pbyymerr aid release any security without notifying or releasing you from r nsibihty on this agreement. Coroeaual Pladge of Shares: You pldrpei all your shares and deposits In the cr dh urdon. Inoludkrg future addidom as security for Wa loan. Incase you d0suh, the credit union may %My tress arteres and di;l s to tla payment of all sums clue at tria tim l d default. including costs O colbcaC and reasonable attorney's feu. OW the credit Won may Incur. up to 2N or the unpaid prMpat and Interest. No lien or Agm to Impress a ken on shares and cleposlts shsk apply to airy of stares whkh may be told in an "Individual RDlhemar Accoar orICs Ftlsn." ieing asked to glraranaee this debt. Thir t have o, and than you want to accept 11 have to pay up to the full amount of the pay the debt. you will have 10. Be sure you can 5100 7199 rorlstouxy. the borrower does not pay. You may also have to pay We fees or C'O1eCdOn costs, which Increase this this debt from ou without first [lying tp ccolliectt from the borrower. The credior can use the s?me may bec Dena k e n ay methods ' ins[ You that it the contract cche? smokes /pu Iwble fa & debt es, suit II this deb[ is ever in default, that ea ma our creel's SECURITY AGREEMENT 1. Twlion in ndwlrh ?[t!sear a1 rono walit xaelnxQxitqures s kx3mr,oo by that credit %L bm la,lon ?! irrerest kclu0esal? rq on and on propbn?ey'-ihd sl°??en° Ing?i e? d From IV ser.Tred property. cross-colt l?s Pr v Divan as Bocakv nor des fa any joan or aha ban Burr wtNO trod. If era a I anwrres SBeocrroywlasaorwaelsw brim nowan?n?ie?tursafi am.-aopautY p1Barayy0 It Incl re1?e?' arl°qu reps a8e un s . are none-pp°asctla°se more 7 you actl4A01urmn 2wlaan conttve sell or tnreter the Collateral untbss you raw: 3. F.437691/02 A"Ro sywams,1%- 22410 n Page 2 of 2 iAUi tlia neoassayt?t Ma°maearcrea?r°?°wrarntPlion sr aaquna°Cmwrp?ico Center ?afu a= an??crj?kbyo°u°Rpl y°Iraly°6p0ut spry ?asta??etRdoCemaWorndthe it o nl ai6n ?sals la of M°asxry? t Irde° union age ew°lt? P°S?°u loss. tied soa a? a as Atarnlyn-Fora 1D OMr md°Ow aoswlMGt NQ ao?oIl ? axy asarost whkn cis agnaernant uRaeres Praa?cQua this caopafNpael)g11 s nl °SaY9afa1, so beU?s ell( °RSpO a te1 ellfill ale brtlK d U°S Me M. This less °CK.1°Cm net only birds you. W your exaculers, adminetralors. SITUATED IN THE TOWNSHIP OF UPPER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA: ALL THAT CERTAIN UNIT, BEING UNIT NO. 595-8 (THE "UNITS") OF SUNGUILD III, A CONDOMINIUM, LOCATED IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH UNIT IS DESIGNATED IN THE DECLARATION OF SUNGUILD III, A CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") AND DECLARATION PLATS AND PLANS AS RECORDED IN THE RECORDER'S OFFICE OF CUMBERLAND COUNTY IN MISCELLANEOUS BOOK 357, PAGE 20 AND RIGHT OF WAY PLAN BOOK 9, PAGE 24. TOGETHER WITH AN UNDIVIDED 5.8918 PERCENT INTEREST IN COMMON ELEMENTS AS MORE PARTICULARLY SET FORTH I THE AFORESAID DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS. TOGETHER WITH THE RIGHT TO USE ANY LIMITED COMMON ELEMENTS APPLICABLE TO THE UNIT BEING CONVEYED HEREIN, PURSUANT TO THE DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS. Permanent Parcel Number: 42240791163 U-595-8 MARY ANN ALHAJ, MARRIED WOMAN 7'NF. Grantee, for and on behalf of the Grantee and the t r-antee's heirs, personal representatives, successors and assigns, by the acceptance of this Deed covenants and agrees to pay such charge for maintenance, repairs, replacements and other expenses in connection with the Common Elements, and any Limited Common Clements appurtenant to said Unit, as may be assessed against him, her, than, it, or said Unit, from time to time by the Exwutive Board of the Sunguild Ill Condominium Association in accordance with the Un form Condominium Act of Pennsylvania. and further covenants and agrees that the Unit conveyed by this Deed shall be subject to a lien for all amounts so assessed except insofar as Section 3407 0 of said Uniform Condominium Act may relieve a subsequent Unit Owner of liability far prior unpaid assessments. This covenant shall run with and bind the land or Unit hereby conveyed and all subsequent owners thereof. Exhibit "B" Prepzred By: ?z Members 1st FCU 5000 Louise Drive Mechanicsburg, PA 17055 When recorded mail to: FIRST AMERICAN TITLE INSURANCE LENDERS ADVANTAGE I100 SUPERIOR AVENUE, SUITE 200 CLEVELAND, OHIO 44114 ATTN. FT1120 5 E P1, DIE El i .-,,. f v R I. ER 2006 NOU 28 AEI 10 32 pc,ot 12 4 0'1 a l l `3 l MORTGAGE Made 10/30/2006 Between MARY A ALHAJ (hereinafter called "Mortgagor") And MEMBERS IST FEDERAL CREDIT UNION (hereinafter called "Mortgagee") Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter called the "Note") o even date herewith, payable to the order of Mortgagee in the principal sum of $ 43.594.97 , lawful money of the United States of America, and has provided therein for payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and containing certain other terms and conditions, all of which are specifically incorporated herein by reference; Now, Therefore, Mortgagor, in consideration of said debt or principal sum and as security for the payment of the same and interest as aforesaid, together with all other sums payable hereunder or under the terms of the Note, does grant and convey unto Mortgagee, All that certain property of the Mortgagor located in UPPER ALLEN TOWNSHIP , Cumberland County, Pennsylvania SEE EXHIBIT "A" which currently has the address of 595-8 GENEVA DR [Street] MECHANICSBURG Pennsylvania [City] Acct No 251008-05 AppID 177713 Exhibit "C» BKI974PG1410 17055 [Zip Code] Page 1 of 4 Together with the buildings and improvements erected thereon, the appurtenances thereunto belonging and the reversions, remainders, rents, issues and profits thereof. To Have and To Hold the same unto Mortgagee, its successors and assigns, forever. Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum, including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder and under the terms of the Note, together with interest thereon, and shall keep and perform each of the other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby granted and conveyed shall become void. This Mortgage is executed and delivered subject to the following covenants, conditions and agreements: (1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall be added to the principal debt. (2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt secured hereby, (b) pah all ground rents reserved from the mortgaged premises and pay and discharge all mechanics' liens whic maybe filed against said premises and which shall or might have priority in lien or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax, including interest and penalties thereon, if any, now or hereafter becoming payable on the Note evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged premises, with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear, and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge the foregoing charges be paid in installments to Mortgagee. (3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair of the buildings and improvements erected thereon. AcctNo 251008-05 AppID 177713 Page 2 of 4 BKI974PG1411 (4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fails to maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the principal debt secured hereby, and collect the same as a part of said principal debt. (5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this Mortgage. (6) In case default be made for the space of thirty (30) days in the payment of any installment of principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum, additional loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice become immediately due and payable, and foreclosure proceedings may be brought forthwith on this Mortgage and prosecuted to judgment, execution and sale for the collection of the same, together with costs of suit and an attorney's commission for collection of five percent (5%) of the total indebtedness or $200, whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said proceedings, waives stay of execution, the right of inquisition and extension of time of payment, agrees to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions from levy and sale of any property that now is or hereafter may be exempted by law. (7) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage. Mortgagor shall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing this Mortgage, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. The covenants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall inure to, the respective parties hereto and their respective heirs, executors, administrators, successors and assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each shall be joint and several. Acct No 251008-05 APPID 177713 Page 3 of 4 BK1974PG1412 Witness the due execution hereof the day and year first above written. --S MARY A Aof Pennsylvania County of CUMBERLAND ss: On this, the 3 0TH day of O _TORFR 1 2006 , before me, BEVERLY X MORCAN the undersigned officer, personally appeared MARY A ALHA I satisfactorily proven to me to be the person(s) whose name(s) is/are subscribed to the within Mortgage, and acknowledged that he/she executed the same for the purposes therein contained. In Witness Whereof, I hereunto set my hand and official seal. My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Bevery K. Morgan, Notary Public Upper Allen Twp., Cumberland County C'Prrtificate of Residence of Mortgagee My Comm'Issiort E)Ores July 7, 2009 Member, Pennsylvania Association of Notaries Members 1ST Federal Credit Union, Mortgagee within n , hereby ce ' Ies that its residence is 5000 Louise Drive, Mechanicsburg, PA 17055. Acct No 251008-05 AppID 177713 Page 4 of 4 8KI974PG1413 4. EXHIBIT A SITUATED IN THE TOWNSHIP OF UPPER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA: ALL THAT CERTAIN UNIT, BEING UNIT NO. 595-8 (THE "UNITS") OF SUNGUILD III, A CONDOMINIUM, LOCATED IN UPPER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, WHICH UNIT IS DESIGNATED IN THE DECLARATION OF SUNGUILD III, A CONDOMINIUM (THE "DECLARATION OF CONDOMINIUM") AND DECLARATION PLATS AND PLANS AS RECORDED IN THE RECORDER'S OFFICE OF CUMBERLAND COUNTY IN MISCELLANEOUS BOOK 357, PAGE 20 AND RIGHT OF WAY PLAN BOOK 9, PAGE 24. TOGETHER WITH AN UNDIVIDED 5.8918 PERCENT INTEREST IN COMMON ELEMENTS AS MORE PARTICULARLY SET FORTH I THE AFORESAID DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS. TOGETHER WITH THE RIGHT TO USE ANY LIMITED COMMON ELEMENTS APPLICABLE TO THE UNIT BEING CONVEYED HEREIN, PURSUANT TO THE DECLARATION OF CONDOMINIUM AND DECLARATION PLATS AND PLANS. Permanent Parcel Number: 42240791163 U-595-8 MARY ANN ALHAJ, MARRIED WOMAN 595 8 GENEVA DRIVE, MECHANICBURG PA 17055 Loan Reference Number 1777713 First American Order No: 10710624 Identifier: L/FIRST AMERICAN LENDERS ADVANTAGE ? lIIII II II III illl 111 111 ALHAJ 10710624 -- FIRST AMERICAN LENDERS ADVANTAGE MORTGAGE 111111111 III11111111IH1111111111111114111111111 Certify this t be In CuMberlartr C record 'd °unty xt Y4s 1 d N BK1974PG1414 Recorder of J Date: August 12, 2008 ACT 91 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. 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). Exhibit "D" This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA 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): MARY A ALHAJ PROPERTY ADDRESS: 595-8 GENEVA DR MECHANICSBURG, PA 17055 LOAN ACCT. NO.: 251008 - 05 ORIGINAL LENDER: Members 1st Federal Credit Union CURRENT LENDEPAERVICER: Members 13t 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 AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 595-8 GENEVA DR, MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MORTGAGE PAYMENTS for the following monthly installments and the following amounts are now past due: $502.26 for 06-01-08, $544.78 for 07-01-08 and $544.78 for 08-01- 08. Other charges (explain/itemize): TOTAL AMOUNT PAST DUE: $1,591.82 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,591.82, 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: Members 18t Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA 17055, Attention: Dave Thomas 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.) 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, 595-8 GENEVA DR, MECHANICSBURG, PA 17055 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 pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately Three(3) 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: Members 1 at Federal Credit Union Address: 5000 Louise Drive, Mechanicsburg, PA 17055 Phone Number. (717) 795-5133 or (800) 283-2328 Ext. 5133 Fax Number. (717) 795-5207 Contact Person: Dave Thomas EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may 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 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 Certified Mail # 70080150000275416112 HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 10/15/2007 10:03:08 AM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565 Relief Act and Urban Development (exp 4/30/2007) Notice Disclosure Office of Housing Legal Rights and Protections Under the SCRA Servicemembers on "active duty" or "active service," or a dependent of such a servicemember may be entitled to certain legal protections and debt relief pursuant to the Servicemembers Civil Relief Act (50 USC App. §§ 501-596) (SCRA). Who May Be Entitled to Legal Protections Under the SCRA? • Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard, and active service National Guard; • Active service members of the commissioned corps of the National Oceanic and Atmospheric Administration; • Active service members of the commissioned corps of the Public Health Service; • United States citizens serving with the armed forces of a nation with which the United States is allied in the prosecution of a war or military action; and • Their spouses. What Legal Protections Are Servicemembers Entitled To Under the SCRA? The SCRA states that a debt incurred by a servicemember, or servicemember and spouse jointly, prior to entering military service shall not bear interest at a rate above 6 percent during the period of military service. The SCRA states that in a legal action to enforce a debt against real estate that is filed during, or within 90 days after the servicemember's military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 90 days after the servicemember's military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate. The SCRA contains many other protections besides those applicable to home loans. How Does A Servicemember or Dependent Request Relief Under the SCRA? • In order to request relief under the SCRA, a servicemember or spouse, or both, must provide a written request to the lender, together with a copy of servicemember's military orders. The Lender providing this Notice is Members I" Federal Credit Union, ATTN: Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The phone number is toll free (800) 283-2328. How Does a Servicemember or Dependent Obtain Information About the SCRA? The U. S. Department of Defense's information resource is "Military OneSource". Website: http://www.mililMonesource.com The toll free telephone number for Military OneSource are: o From the United States: 1-800-342-9647 o From outside the United States (with applicable access code): 800-3429-6477 o International Collect (through long distance operator): 1-484-530-5908 • Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal assistance office locator for all branches of the Armed Forces is available at http://legalassistance.law.af.mil/content/locator.php form HUD-92070 (2/2007) t? (Domestic Mail Only; I Insurance Coverage I 1 T? i i F d li i f i on v s or e very n ormat 1 1 t our U1 Postage $ N?Gss?R L Certified Fee 2-110 C P V? ?11(? rk •p O O Return Receipt Fee (Endorsement Required) © SCI 1 y S? M O Restricted Delivery Fee (Endorsement Required) (gyp co G? 2UOa ??? LrI r-I Total Postage & Fees 170?h O C3 SM --------- ' --- --- -- ---- --- ---- -------- ----- N t 1 ----- - -------- C' t fe, -14 t PS Form 3800. AugLlS 20N, See Reverse fot ln?Ntjctions Exhibit "E" bd d? H U7 m M ° D v O °o o :C 00 7-< o z m,D ••. ,...... D >. nZr ,gFcr o?. C D ` y? C7 X D +Z 3 d cc G) s f V, r yi f , ?' D o 'A a 1 m_MD ? I As* to ?- cr b ru SSCi L 3043d17LAJO)44 n--xIwLu mws-. VERMC,A TION I, Arlanda Collateial Liquidation Specialixt for Members 1" Federal Credit Union, being authonzed to do so on behalf of Members 1 n Federal Credit Union, hemby verify that the stahments made in the foregoing pleading are u= and correct to the best of my informatio knowledge and belief. I understand that false statements are made subject to the penal es of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Members 1" Fedeml Qedit Union By;,X? - ?10? Arlanda Dimman, Co&ttlal Liquidation specialist 6 00 d c:> ? - 1 e t ;7"7'1 ? ri 77- SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06570 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT UNI VS ALHAJ MARY A AKA MARY ANN ALHA R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ALHAJ MARY A AKA MARY ANN ALHAJ but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT ALHAJ 595-8 GENEVA DRIVE MECHANICSBURG, PA 17055 NOT FOUND , as to , ALHAJ MARY A AKA MARY ANN DESPITE NUMEROUS ATTEMPTS. THE PAPER EXPIRED BEFORE SERVICE COULD BE MADE. Sheriff's Costs: So answers - -=' - Docketing 18.00 Service 29.70 Postage .42 R. Thomas ine Surcharge 10.00 Sheriff of Cumberland County Not Found .00 8.12 KARL LEDEBOHM fal ??? Y ? 58.12- 12/08/2008 Sworn and Subscribed to before me this day of , A.D. Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1„ FEDERAL CREDIT UNION PLAINTIFF V. MARY A. ALHAJ a/k/a MARY ANN ALHAJ DEFENDANT To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA NO.: 08-6570 Civil Term CIVIL ACTION-LAW MORTGAGE FORECLOSURE PRAECIPE Please reinstate the complaint filed in the above captioned matter. Date: December 16, 2008 ?Arl A Ledebbhm, Esquire upreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ?a CO SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06570 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT UNI VS ALHAJ MARY A AKA MARY ANN ALHA R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ALHAJ MARY A AKA MARY ANN ALHAJ but was unable to locate Her in his bailiwick. COMPLAINT - MORT FORE , He therefore returns the NOT FOUND , as to the within named DEFENDANT , ALHAJ MARY A AKA MARY ANN ALHAJ 595-8 GENEVA DRIVE MECHANICSBURG, PA 17055 AT TIME OF SERVICE (12/22) THERE WERE NOTICES STUCK IN DOOR DATED 12/7 AND 12/11. BELIEVED TO BE VACANT. Sheriff's Costs: Docketing 18.00 Service 9.00 Not Found 5.00 Surcharge 10.00 Postage, 42 l?1/o f 41- ? 42.42 So ans R.-Thomas Kl' e Sheriff of Cumber and County KARL LEDEBOHM 12/23/2008 Sworn and Subscribed to before me this day of A. D. Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 ST FEDERAL CREDIT UNION PLAINTIFF/Petitioner Vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA NO.: 2008-06570 MARY A. ALHAJ a/k/a MARY ANN ALHAJ DEFENDANT/Respondent CIVIL ACTION-LAW MORTGAGE FORECLOSURE PETITION FOR ALTERNATE SERVICE PURSUANT TO RULE OF CIVIL PROCEDURE 430 AND 410(c) AND NOW, comes your Petitioner, Members 1't Federal Credit Union ("Petitioner"), by and through its attorney, Karl M. Ledebohm, and respectfully avers the following in support of the Petition for Publication: 1 1. Petitioner is Members 1St Federal Credit Union, a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Respondent is Mary A. Alhaj a/k/a Mary Ann Alhaj ("Respondent'), an adult individual having a last known address of 595-8 Geneva Drive, Mechanicsburg, PA 17055. 3. On or about November 6, 2008, Petitioner filed a complaint in mortgage foreclosure to the above captioned matter with regards to the property at 595-8 Geneva Drive, Mechanicsburg, PA 17055 (the "Property"). 4. R. Thomas Kline, Sheriff for Cumberland County, made a return of service dated December 8, 2008 which indicated that the Sheriff was unable to find the Respondent in his bailiwick and was unable to serve the Respondent at the Property noting as follows: "Despite numerous attempts, the paper expired before service could be made." A copy of the Sheriffs return dated December 8, 2008, is attached hereto as exhibit "A" and made part hereof. 5. Petitioner reinstated the complaint on December 18, 2008 and requested the Cumberland County Sheriff to make additional attempts to serve process upon Respondent. 6. R. Thomas Kline, Sheriff for Cumberland County, made a return of service dated December 23, 2008 which indicated that the Sheriff was unable to find the Respondent in his bailiwick and was unable to serve the Respondent at the Property noting as follows: "At time of service (12/22) there were notices stuck in Door dated 12/7 and 12/11. Believed to be vacant." A copy of the Sheriffs 2 return dated December 23, 2008 is attached hereto as exhibit "B" and made part hereof. 7. Petitioner was informed by the US Postal Service that it is no longer possible for a private party to request a forwarding address without a court order. 8. Pursuant to the affidavit attached hereto and made part hereof as exhibit "C", after considerable investigation, Petitioner has been unable to locate Defendant for service. WHEREFORE, Petitioner respectfully requests this Honorable Court to enter an Order permitting service by posting the Property, by regular mail to the last known address of Respondent and by advertising one time in the Cumberland Law Journal and in one newspaper of general circulation in Cumberland County of the Complaint, the Important Notice under Pa. R.C.P. 237. 1, Notice of Judgment, Writ of Execution, Notice of Sheriffs Sale and any and all subsequent and/or additional documents pertaining to the foreclosure action filed to the above captioned matter, execution on any judgment entered in connection therewith and sale of the Property. Date: /- (Z, V e( Karl M. Ledebohm, Esq. Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Petitioner 3 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06570 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT UNI VS ALHAJ MARY A AKA MARY ANN ALHA R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ALHAJ MARY A AKA MARY ANN ALHAJ but was unable to locate Her in his bailiwick. COMPLAINT - MORT FORE , He therefore returns the NOT FOUND , as to the within named DEFENDANT ALHAJ 595-8 GENEVA DRIVE ALHAJ MARY A AKA MARY ANN MECHANICSBURG, PA 17055 DESPITE NUMEROUS ATTEMPTS, THE PAPER EXPIRED BEFORE SERVICE COULD BE MADE. Sheriff's Costs: Docketing 18.00 Service 29.70 Postage .42 Surcharge 10.00 Not Found .00 58.12 So answers: - ---> R. Thomas F{l ine Sheriff of Cumberland County KARL LEDEBOHM 12/08/2008 Sworn and Subscribed to before me this day of A. D. Exhibit `6A" SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06570 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT UNI VS ALHAJ MARY A AKA MARY ANN ALHA R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ALHAJ MARY A AKA MARY ANN ALHAJ but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT ALHAJ 595-8 GENEVA DRIVE NOT FOUND , as to ALHAJ MARY A AKA MARY ANN MECHANICSBURG, PA 17055 AT TIME OF SERVICE (12/22) THERE WERE NOTICES STUCK IN DOOR DATED 12/7 AND 12/11. BELIEVED TO BE VACANT. Sheriff's Costs: Docketing 18.00 Service 9.00 Not Found 5.00 Surcharge 10.00 Postage .42 42.42 So an R. `Thomas Kl fie Sheriff of Cumbe5zand County KARL LEDEBOHM 12/23/2008 Sworn and Subscribed to before me this day of A. D. Exhibit "B" MEMBERS I ST FEDERAL : IN THE CO U 0 OP COMMON PLEAS CREDIT UNION : CUMl3 COUNTY, . PENNSYL'V , PLAINTIFF 'Vs. NO,: 2008-065 0 I MARY A. AL W aWa MARY ANN ALHAJ - DEFENDANT C1VlL'ACno 'QV j : MORTGAGE F CLOSURE G AFFIDAVIT I, Arlan& DinWnan, Collateral Liquidation Specialist for Members Ia Federal r 8... Credit Union C Peti tioner"), do hereby report the following inf on in support of my k' Petition for Publication: ' 1. The only address which Petitioner possesses with regar to the May A. Aaj aWa Mars' Ann Alai (the uDefendant is the address . I t forth in the Pitibn Fur Ji A ltenwite Service Pursum t.to Rule of Civil Proaeduce 43 Se i ') d d i 0 elpetition for Alternate , rv ce unne ately.proceeding this Affidavit. The P 'lion for Alter Service is incorporated herein by reference as if set fo herein in M 2. On or about January 5, 2009, Petitioner, through its att i . ey, Ka111d, Y,edebohm f Esq., contacted directory assistance for Mechanicsburg, , ennsylvania and was informed that. no listings exist for Defendant. I On or about January 5, 2009, Petitioncr, through its Wo I.arl M. Ledobuhm Esq., inspected the local phone directory for Cumber , County which revealed Y no listing for Defendant. 4. On or about January 5, 2009, Petitioner, through its atto ey, Karl M. Iodebbhm ?' , , E sq., contacted Cumberland County Bureaus of Electi ., , ai d was informed that . Defendant does not appear in the said Bureau's records . 5. On or about January 5, 2009, Petitioner, through its atto ey, Karl M. Ledebbhm Esq-, contacted Cumberland County Tax Assessment , confirmed that the' only address available for Defendant is that set forth in the P ' 'on for Alternate Service attached hereto and made part hereof, being the a address imported 'by ? the Cumberland Ca Sheriffs Office as being vacan 41 6. Petitioner rrequested a -social security number tY search ugh Trans Union to locate the whereabouts of Defendant. Exhibit "C" r' ? I 'H 7, On or about January 2009, Petitioner received a rt from Trans Union y vAnch does not Indio to any additional addresses for endatnt other tlrmu 595-8 Geneva Drive, Mechanicsburg, PA 17055 (thlc being the same address F reported by the Cumberland County Sheriffs Office as ing vacant, i 8. On or about January _1, 2009, Petitioner conducted an internet phone number search for DefeWant which revealed no phone numbers listed for Defendant 9. As of the date hereof, Petitioner has not received any ' oama?ation Concerning the whereabouts of Defendant from Trans Union or any o source. 10. As set forth in the re turn of service by the Cumberland linty Sheres Office w dated December 23, 2008, a copy of which is attached the Petition for Alternate Service as exhibit "A" and made part thereof and here by refmaa?ce, the Sheriff ?? was unable to fmd the Defendant in his bailiwick and not able to serve ;I Defendant at the Property and observed, "[a]t time of ice there were notices j stuck in door dated 12/7 and 12/11,11 from which the S 'Ifs Office concluded that the Property is believed to be vacant. I; ' NI 11. For the reasons set forth herein and in the Petition for Al a Service, Petitioner bas reason to believe that Defendant has left the area. 1 Date: J G n uG `? 7 2009 1 Arlanda Dingy Collateral E Members l a Sworn and subscribed to before me, a Notary Public, this 7 ?1 day of January 2009. Notary) ZU) My commission expires: N 6Uc,/n,b e r 1 Z II i? MMONWEALTH OF PENNSYLVANIA Notarial Seal Daniel F Summers, Notary Public Swatara Twp., Dauphin County My Commission 'Expires Nov. 12, 2012 Member, Pennsylvania Association of Notaries 2 Ci !s VERMCAMN fi I, Arlandaa Collateral Liquidation Specialist for Members I sc Federal r I g Credit Union, being 'zed to do so on behalf of Members I" Federal Credit Union, hereby verify that the stet is made in the foregoing pleading axe true and correct to the best of nay Wonaabio knowledge, and belief I understand that false statements ere C.1. made subject to the es of 18 Pa. C.S.A. Section 4904, reWing to unsworn falsific t ion to authorities Members 1 a Federal Credit Union Arlanda Dfin mwn Collateral Liquidation specialist 6 S 4 ?+y ?7 1 E _ ? 6r7 J+ j" Ln Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1sT FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF/Petitioner Vs. NO.: 2008-06570 MARY A. ALHAJ a/k/a MARY ANN ALHAJ DEFENDANT/Respondent CIVIL ACTION-LAW MORTGAGE FORECLOSURE AMENDED PETITION FOR ALTERNATE SERVICE PURSUANT TO RULE OF CIVIL PROCEDURE 430 AND 410(c) AND NOW, comes your Petitioner, Members 1St Federal Credit Union ("Petitioner"), by and through its attorney, Karl M. Ledebohm, and respectfully avers the following in support of the Petition for Publication: 1 1. Petitioner is Members 0 Federal Credit Union, a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Respondent is Mary A. Alhaj a/k/a Mary Ann Alhaj ("Respondent"), an adult individual having a last known address of 595-8 Geneva Drive, Mechanicsburg, PA 17055. 3. No judge has ruled upon any other issue in the above captioned matter or any related matter. 4. No counsel for Respondent has entered an appearance of record, the Sheriff's Office having been unable to serve the complaint in this matter upon Respondent and; therefore, Petitioner has been unable to seek the concurrence of counsel for Respondent to the instant petition. 5. On or about November 6, 2008, Petitioner filed a complaint in mortgage foreclosure to the above captioned matter with regards to the property at 595-8 Geneva Drive, Mechanicsburg, PA 17055 (the "Property"). 6. R. Thomas Kline, Sheriff for Cumberland County, made a return of service dated December 8, 2008 which indicated that the Sheriff was unable to find the Respondent in his bailiwick and was unable to serve the Respondent at the Property noting as follows: "Despite numerous attempts, the paper expired before service could be made." A copy of the Sheriff s return dated December 8, 2008, is attached hereto as exhibit "A" and made part hereof. 2 8. Petitioner reinstated the complaint on December 18, 2008 and requested the Cumberland County Sheriff to make additional attempts to serve process upon Respondent. 9. R. Thomas Kline, Sheriff for Cumberland County, made a return of service dated December 23, 2008 which indicated that the Sheriff was unable to find the Respondent in his bailiwick and was unable to serve the Respondent at the Property noting as follows: "At time of service (12/22) there were notices stuck in Door dated 1217 and 12/11. Believed to be vacant." A copy of the Sheriff's return dated December 23, 2008 is attached hereto as exhibit "B" and made part hereof. 10. Petitioner was informed by the US Postal Service that it is no longer possible for a private party to request a forwarding address without a court order. 11. Pursuant to the affidavit attached hereto and made part hereof as exhibit "C", after considerable investigation, Petitioner has been unable to locate Defendant for service. WHEREFORE, Petitioner respectfully requests this Honorable Court to enter an Order permitting service by posting the Property, by regular mail to the last known address of Respondent and by advertising one time in the Cumberland Law Journal and in one newspaper of general circulation in Cumberland County of the Complaint, the Important Notice under Pa. R.C.P. 237.1, Notice of Judgment, Writ of Execution, Notice of Sheriffs Sale and any and all subsequent and/or additional documents pertaining to the foreclosure action filed to the above captioned matter, execution on any judgment entered in connection therewith and sale of the Property. 3 Date: I "W_O New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Petitioner Supreme Court ID # : 59012 P.O. Box 173 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06570 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT UNI VS ALHAJ MARY A AKA MARY ANN ALHA R. Thomas Kline duly sworn according to law, inquiry for the within named ALHAJ MARY A AKA MARY ANN unable to locate Her in his COMPLAINT - MORT FORE , ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and DEFENDANT ALHAJ but was bailiwick. He therefore returns the NOT FOUND , as to the within named DEFENDANT , ALHAJ MARY A AKA MARY ANN ALHAJ 595-8 GENEVA DRIVE MECHANICSBURG, PA 17055 DESPITE NUMEROUS ATTEMPTS, THE PAPER EXPIRED BEFORE SERVICE COULD BE MADE. Sheriff's Costs: So answers- Docketing 18.00 Service 2 9 . 7 0 Postage .42 R. Thomas .Kl ine Surcharge 10.00 Sheriff of Cumb6rland County Not Found .00 58.12 KARL LEDEBOHM 12/08/2008 Sworn and Subscribed to before me this day of , A.D. Exhibit "A" SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06570 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT UNI VS ALHAJ MARY A AKA MARY ANN ALHA R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ALHAJ MARY A AKA MARY ANN ALHAJ but was unable to locate Her in his bailiwick f"nhAT1T T TTTT TiT/\T)T He therefore returns the the within named DEFENDANT ALHAJ 595-8 GENEVA DRIVE NOT FOUND , as to ALHAJ MARY A AKA MARY ANN MECHANICSBURG, PA 17055 AT TIME OF SERVICE (12/22) THERE WERE NOTICES STUCK IN DOOR DATED 12/7 AND 12/11. BELIEVED TO BE VACANT. Sheriff's Costs: Docketing 18.00 Service 9.00 Not Found 5.00 Surcharge 10.00 Postage .42 42.42 So ans R. "Thomas K1 if e Sheriff of Cumber/land County KARL LEDEBOHM 12/23/2008 Sworn and Subscribed to before me this day of A. D. Exhibit "B" i I MIrMBERS In FEDERAL : IN THE COUK ',. CREDI 1 V 1V IO a \? V LYl27i} PENNSYL V PL.AYN IFF Vs. NO, : 2009-06571 ?I MARY A. ALHAJ aWa MARY ANN ALHAJ DEFENDANT : C1V1L,'ACTION. : MORTGAGE PC ?I ii AHMAVIT I, Arlanda Dintaman, Collateral Liquidation S pecialist for r Credit Union ("Petitioner"), do hereby report the following info Petition for Publication: ?i 1. The only address which Petitioner possesses with regard I j aWa Mary Ann A1haj (the "Defendant) is the address s Alternate Service Pursuaut.to Rule of Civil Procedure 4: Service") immediately proceeding this Affidavit. The Pe Service is incorporated herein by reference as if set ford 2. On or about January 5, 2009, Petitioner, d mugh its attol Esq., contacted directory assistance for Mechanicsburg, informed that. noLstings exist for Defendant.' 3. On or about January 5, 2009, Petitioner, through its attoi Esq., inspected the local phone directory for Cumberlm no listing for Defendant. 4. On or about January 5, 2009, Petitioner, through its attoi Esq., contacted Cumberland County Bureau of Election Defendant does not appear in the said Bureau's records. 5. On or about January 5, 2009, petitioner, through its attoi f Esq-, contacted Cumberland County Tarr Assessment an address available for Defendant is that set forth in the Pc Service attached hereto and made part hereof, being the f the Cumberland County SherifTs Office as being vacant 6. Petitioner requested a "social security number search" d locate the whereabouts of Defendant. Exhibit "C" OF COMMON PLEAS COUNI"Y, A ?a W [embers lz` Federal`'i mation in support of my to the Mary A. A.lhaj .t forth in the Petition for 0 ("Petition for Altemate ition for Alternate herein in full. iey, Karl M. Ledebobn4 'ennsylvania and was ley, Karl M. Ledebohm, County which revealed ,k " 41 aey, Karl M.,Ledebohm, aiad was informed that aey, Karl M. Ledebohm, I confirmed that the only j ition for Alternate me address reported'b rough Trans Union to r 7. On or about January 2009, Petitioner received a ? i rt from Trans Union which does not indicate any additional addresses for D e ndant other than 595-8 Geneva Drive, Mechanicsburg, PA 17055 (the "Pro ' being the some address reported by the Cumberland County Sherifs Office as ing vacant. 8. On or about January _1, 2009, Petitioner coiutucted an i nt+ejnet phone number search for Defendant which revealed no phone numbers l isted for Defendant 9. As of the date hereof, Petitioner has not received any ' o rnmtion concerning the whereabouts of Defendant from Trans Union or any oth source. 10. As set forth in the rett?a of service by the Cumberland ounty Sherif s Office I dated December 23, 2008, a copy of which is attached the Petition for Alternate Service as exhibit "A' and made part thereof and he= by reference, the Sheriff' was unable to find the Defendant in his bailiwick and w not We to serve Defendant at the Property and observed, "[aft time of se - 'ce there were noti'res stuck in door dated 12/7 and 12/11," from which the S 'Ws Ofce concluded that the Property is believed to be vacant. 11. For the reasons set forth herein. and in the Petition for Al erna?te Service, Petitioner has reason to believe that Defendant has left the area Date:'JG nuc,--, 7 20()q = aWal l; Members 1 Swom and subscribed to before me, a Notary Public, this 7 f } day of January 2009. z9l? My commission expires: A j 0 v cr ,b e r 12,, it i h COMMONWEALTH OF PENNSYL.VANRA Notarial Seal i Daniel F Summers, Notary Public _ i Swatara Twp., Dauphin ,aunty My Commission'Exores Nov. 12, 2012 Member, Pennsylvania Association of Notaries 2 submittal, imam juidation Specialist for Federal Credit Union r .? 4 ,I ,C w ?'t 11 f VERIFICATION I, Arlanda Dintamaa, Collateral Liquidation Specialist for Mcmben 1'c Federal Credit Union,, being authorized to do so on behalf of Members I" Feda-A Credit Union, hereby verify that the statements made m the foregoing pleading are true and correct to the best of my information laivwlcdge and belief. I understand that false statements are made subject to the penalties of l A Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Membema I # Federal Credit Union By: Arlattda Dintac, me, Collateral Liquide4on Specialist 6 ^? t:? _ ? ? _?.y ', ` t... ;,? , s 7 r,, -o r-r? r _, ,- w, , ? ta? =?> r`rt . •• :-; ?x ? ??d li 2009 6 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS I ST FEDERAL CREDIT UNION PLAINTIFF/Petitioner Vs. MARY A. ALHAJ a/k/a MARY ANN ALHAJ DEFENDANT/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2008-06570 CIVIL ACTION-LAW MORTGAGE FORECLOSURE ORDER AND NOW, this day of o.*A %a C1 Y' , 2009, upon consideration of Members 1St Federal Credit Union's Petition for Alternate Service Pursuant to Rule of Civil Procedure 430 and 410(c), it is hereby ORDERED THAT Members 1St Federal Credit Union shall make service of the Complaint, the Important Notice under Pa. R.C.P. 237.1, Notice of Judgment, Writ of Execution, Notice of Sheriff s Sale and any and all subsequent and/or additional documents pertaining to the foreclosure action filed to the above captioned matter, execution on any judgment entered in connection therewith and sale of the property known and numbered as 595-8 Geneva Drive, Mechanicsburg, PA 17055 (the "Property") by posting the Property, by regular mail to the last known address of Respondent and by advertising one time in the Cumberland Law Journal and in one newspaper of general circulation in Cumberland County. By the Court: Notice addresses: Zic-arl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 ? Mary A. Alhaj 595-8 Geneva Drive Mechanicsburg, PA 17055 e4f CU 9?1S( LI 1/240? 2U liNVC 6 E, 'U" Z -7j Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1„ FEDERAL CREDIT UNION PLAINTIFF V. MARY A. ALHAJ a/k/a MARY ANN ALHAJ DEFENDANT To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA NO.: 08-6570 Civil Term CIVIL ACTION-LAW MORTGAGE FORECLOSURE PRAECIPE Please reinstate the complaint filed in the above captioned matter. Date: February 3, 2009 Respec y submitted, Karl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ... r m a ` • ? .?.? in 91 ? - ?, O J .D 17 IZ S „ '' w SHERIFF'S RETURN - REGULAR CASE NO: 2008-06570 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT UNI VS ALHAJ MARY A AKA MARY ANN ALHA KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ALHAJ MARY A AKA MARY ANN ALHAJ the DEFENDANT , at 0017:35 HOURS, on the 9th day of February-, 2009 at 595-8 GENEVA DRIVE MECHANICSBURG, PA 17055 by handing to POSTED PER COURT ORDER AT 595 8 GENEVA DR., MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 11.70 Posting 6.00 Surcharge 10.00 R. Thomas Kline Postage .42 46.12 02/11/2009 KART, M T,RT)RRnT4M Sworn and Subscibed to before me this day By: of A. D. C7 a f] -n ?f rJ i ? $1 MI d9F Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PLAINTIFF : PENNSYLVANIA V. NO.: 08-6570 Civil Term MARY A. ALHAJ a/k/a CIVIL ACTION-LAW MARY ANN ALHAJ DEFENDANT MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE I, Karl M. Ledebohm, Esquire, being duly sworn according to law hereby swear and affirm that on the 9s' day of February 2009 I served the complaint in foreclosure filed to the above captioned matter upon the following individual by first class mail, postage prepaid, as required by the Order of Court dated January 29, 2009 entered in the above captioned matter addressed as follows: Mary A. Alhaj a/k/a Mary Ann Alhaj 595-8 Geneva Drive Mechanicsburg, PA 17055 t ,' ... cri ti e C-' ?.J ?4 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1" FEDERAL CREDIT UNION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA PLAINTIFF V. MARY A. ALHAJ a/k/a MARY ANN ALHAJ DEFENDANT : NO.: 08-6570 Civil Term CIVIL ACTION-LAW MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE I, Karl M. Ledebohm, Esquire, being duly sworn according to law hereby swear and affirm this 26 h day of February, 2009, that notice of the filing of the complaint in the above captioned matter was published in The Patriot News, a newspaper of general circulation in Cumberland County, on February 13, 2009 and in the Cumberland Law Journal on February 20, 2009. Proofs of publication for which are attached and made part hereof. submitted, Sworn before me, a not"Tic thisc;q&_ day of February, 2009. ?5 M commission expires: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBRA L. SWIGERT, NOTARY PUBLIC SOUTH MIDDLETON TWP., CUMBERLAND COUNTY MY COMMISSION EXPIRES JUNE 26, 2010 arl M' Ledebohm, Esq. upreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 TtH" atriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 KARL M. LEDEBOHM ATTORNEY-AT-LAW P.O. BOX 173 NEW CUMBERLAND PA 17070 14e PatriotmNews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad # 0001949088 ran on the dates shown below: LUY11 f 1 February 13, 2009 that Notice It1yrwr 91~ that on rtw.m . k SOOL MA alblr tltt Fed?ral CrWlT W ? I, r IlNlon (^M«i1Mh 1tY I hat }IIW v corn - , ?.. plaM1 M mprlpep? TwtGlotuh caailOMO ' ... . . at M igrth,Mlav (the FKtdpture ) 0001rat MARY A. ALMA,)/A MARY N ALH ,41h01) pp11 r n ... ........... Court b1 ComTiR wa iln &l M nYl i l - 1 2009 A D f F b cbnr* w i W om h umunB H 1 I H ?= 1 ' . . e ruary, Sworn to and subscribed before me this 13 day o br A lol. n A on I0 Cu 1.hd Cou.,V, Ptah - - - ' ' ? trIJd01a, known olyd nuMD6iW d 595.6 ? . ? - GmYV6 DYIW, Abrh F lo PA 17055 •P F Kl Th 6 "* ) Th ? ( - orm s r or oiun ( * P . e fartalo ThtIlesofrMMl[Owing mart - „awmw,+? Pro?MandalptL Notary Public , also.-d Gne tArrwP 36.,44 mW . Old Ln 10*C Nobbn5.°1006 Olld n ' - dw Of O a t n a nw b COMMONWEALTH OF PENNSYLVANIA N1 fflu a brl ack i I, Pow 14%. Notmal Seal 1 V THE 'COURT OF COMMON -PLEAS CUMBERLANDCOUNTY, G $t1elile t„ KlSrlef, Notary Public PENNSYLVANIA City Of HaRi8bw9, Dauphin (i0Uf1(y 201 CI V L ACT.IO - LAW My Cortbrdeeiorl E>ipim Nov. 26, 2011 MORTGAGEFORECLOSURE ??EME'ERS.IST FEd7E5rftREDIT Member, Pennsylvania AssoGation of Notaries n- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 a Marie Coyne, Edito SWORN TO AND SUBSCRIBED before me this 20 day of February, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz February 20, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. 1 r CUMBERLAND LAW JOURNAL LEGAL NOTICE NOTICE IS HEREBY GIVEN that on November 6, 2008, Members 1st Federal Credit Union ("Members 1 st") has filed a complaint in mortgage foreclosure captioned as set forth below (the "Foreclosure") against MARY A. ALHAJ A/K/A MARY ANN ALHAJ ("Alhaj") before the Cumber- land County Court of Common Pleas in connection with the condominium unit owned by Alhaj situate in Up- per Allen Township, Cumberland County, Pennsylvania, known and numbered as 595-8 Geneva Drive, Mechanicsburg, PA 17055 (the "Prop- erty"). The Foreclosure forecloses the lien of the following mortgage against the Property and alleges, among other things, the failure to make the monthly payments due to Member 1st under the following note and mortgage: Closed-End Note, Disclo- sure, Loan and Security Agreement dated October 30, 2006 in the origi- nal principal amount of $43,594.97 and corresponding mortgage also dated October 30, 2006 and recorded in the Cumberland County Recorder of Deeds Office at Mortgage Book 1974, Page 1410. In the Court of Common Pleas, Cumberland County, Pennsylvania Civil Action-Law NO.: 2008-06570 MEMBERS 1ST FEDERAL CREDIT UNION PLAINTIFF vs. MARY A. ALHAJ a/k/a MARY ANN ALHAJ DEFENDANT MORTGAGE FORECLOSURE If you wish to defend, you must enter awritten appearance personally or by attorney and file your defenses or objection in writing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the 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 RE- DUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 THIS NOTICE AND ANY SUBSE- QUENT CORRESPONDENCE FROM THIS OFFICE IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFOR- MATION OBTAINED MAY BE USED FOR THAT PURPOSE, KARL M. LEDEBOHM, ESQUIRE Legal Counsel for Members 1st Federal Credit Union P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Feb. 20 NOTICE r.,, c° <::) -TY r r ? C`a r=C p•? Sheriffs Office of Cumberland County R Thomas Kline flolffil", of .?u+R6rrt Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy 4Ff1CE OF -',E i HERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/24/2009 10:20 AM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 24, 2009 at 1020 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Mary A. Alhaj pursuant to Order of Court by posting the premises located at 595-8 Geneva Drive, Mechanicsburg, Cumberland County, Pennsylvania, with a true and correct copy of the same according to law. SHERIFF COST: $46.12 March 25, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF De ty Sheriff Docket No. 2008-6570 Members 1st v Mary A. Alhaj t%j Cal MLU i :1- C C Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1sT FEDERAL CREDIT UNION : PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO.: 2008-06570 MARY A. ALHAJ a/k/a CIVIL ACTION - LAW MARY ANN ALHAJ : DEFENDANT MORTGAGE FORECLOSURE PRAECIPE TO SETTLE. DISCONTINUE & END To the Prothonotary: Please mark the docket in the above captioned matter settled, discontinued and ended without prejudice. submitted, Date: April 21, 2009 'Karl M. Ledebohm, Esq. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff OF THE 2009 APR 22 PM 3, 0 9 ,? _ jY