HomeMy WebLinkAbout09-0177
Phelan Hallinan & Schmieg, LLP
Lawrence T. Phelan, Esq., Id. No. 32227
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Michele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esq., Id. No. 58745
Sheetal R. Shah-Jani, Esq., Id. No. 81760
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., Id. No. 93337
Vivek Srivastava, Esq., Id. No. 202331
Jay B. Jones, Esq., Id. No. 86657
Peter J. Mulcahy, Esq., Id. No. 61791
Andrew L. Spivack, Esq., Id. No. 84439
Jaime McGuinness, Esq., Id. No. 90134
Chrisovalante P. Fliakos, Esq., Id. No. 94620
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000 19sloa
CITIMORTGAGE, INC., SlBIM TO PRINCIPAL
RESIDENTIAL MORTGAGE, INC.
5280 CORPORATE DRIVE
MS1011
FREDERICK, MD 21703
Plaintiff
v.
LUCAS J. PRINS
NICOLE L. PRINS
1914 CARLISLE ROAD
CAMP HILL, PA 17011
Defendants
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM ~i~vi ~
NO. 461- ~~7
CUMBERLAND COUNTY
CIVIL ACTION -LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 19s104
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your 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 maybe entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Service:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
File #: 195104
Plaintiff is
CITIMORTGAGE, INC., S/B/M TO PRINCIPAL RESIDENTIAL MORTGAGE, INC.
5280 CORPORATE DRIVE
MS 1011
FREDERICK, MD 21703
2. The name(s) and last known address(es) of the Defendant(s) are:
LUCAS J. PR1NS
NICOLE L. PRINS
1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 06/21/2002 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to WAYPOINT BANK which mortgage is recorded in the Office
of the Recorder of CUMBERLAND County, in Mortgage Book No. 1763, Page 1434.
By Assignment of Mortgage recorded 06/27/2002 the mortgage was assigned to
PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 688,
Page 1277. The mortgage is attached as Exhibit "A".
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 08/01/2008 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of mortgagor to make such payments after a date specified
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
File #: 195104
6.
The following amounts are due on the mortgage:
Principal Balance $87
503.37
Interest ,
$3
053.68
07/01/2008 through 01/12/2009 ,
(Per Diem $15.58)
Attorney's Fees $1
325.00
Cumulative Late Charges ,
$150.25
06/21/2002 to 01/12/2009
Cost of Suit and Title Search 750.00
Subtotal $92,782.30
Escrow
Credit
Deficit ($311.82)
Subtotal $0.00
TOTAL 311.82
$92,470.48
7.
8.
If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above
maybe less than the amount demanded based on work actually performed. The
attorney's fees requested are in conformity with the mortgage and Pennsylvania law.
Plaintiffreserves its right to collect attorney's fees up to 5% of the remaining principal
balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if
the complexity of the action requires additional fees in excess of the amount demanded in
the Action.
Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
File #: 195104
9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or
Notice of Default as required by the mortgage document, as applicable, have been sent to
the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by
said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff
or an authorized consumer credit counseling agency, or has/have been denied assistance
by the Pennsylvania Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum
of $92,470.48, together with interest from 01/12/2009 at the rate of $15.58 per diem to the date
of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure
and sale of the mortgaged property.
PHELAN HALLINAN & SCHMIEG, LLP
By: `
Lawrence T. Phelan, Esquire
~ancis S. Hallinan, Esquire
Daniel G. Schmieg, Esquire
Michele M. Bradford, Esquire
Judith T. Romano, Esquire
Sheetal R. Shah-Jani, Esquire
Jenine R. Davey, Esquire
Lauren R. Tabas, Esquire
Vivek Srivastava, Esquire
Jay B. Jones, Esquire
Peter J. Mulcahy, Esquire
Andrew L. Spivack, Esquire
Jaime McGuinness, Esquire
Chrisovalante P. Fliakos, Esquire
Attorneys for Plaintiff
File #: 195104
~~~ ~ 3~(o
~~
Prepared By:
WaYpoint Bank
101 S. George St,
York, PA 17901
866-929-7646
Parcel Numbcr: 13-23-597-348
. _"." ~. ~f~GLER
.' '. . t;i' D~~G~
.. ';'. ~ Y - ~,~
'Q2 JEJN 27 fl~ 1~ 52
Return To:
101 S, George St
York, PA 17401
866-929-764b
Laos At7ore 17rr IAoe )Ror ReoordtsR I]atal
MORTGAGE
DEFINITIONS
Words used in multiple sections of this document ato defined mow, and other words are defined in
Sections 3, 11, 13, 18, ?A and 2I. Certain rules reg~~ ~
also provided is Section 16. ~Se of words used in this document are
(A) °~uNty Instrum~t" means this docttment~ which is dated June 21st, 2002
together with all Ride this document.
(B) ~~ ~" ~ a J Prins and Nicole T.,. Prins
/ULP
Borrower is the mortgagor under this Sequity h~atrument.
(C) "Lender" is tQaypoittt Bank
Lender is a E'ederal Savings Bank
AENNSYLVANIA -Single FamAy - Fn77fa MadFndda Mao tJ~gFORM INSTRUMHIIT
®o BtAAt ioooel ~i
Papo 1 0l 16 ~~ ~ ), ~
VM- MORTGA(gE FOIIMB - (s0017i27.7 ,f3V/fY~l
~yiy ~.~is/~ ,~(.
Bf((76;~~'G1434
Form 3039 1101
17/~(1/9011R 19.9fi•SR PM C:IIMRFRI ANf) (;nIINTY
Inst.# 200225966 - Paoe t of 18
organized and ratistittg urger the laws of the United States of Attterica
Lender's address is PO Box 1TI1, Harrisburg, PA 17105
^ Adjustable Rate Rider [~ Coadomiaium Rider
Baboon Rider ~ Ptattnod Unit Dever Seward Home Rider
VA Rider Biweekl °~t Rider 1-4 Fatally Rider
y Payment Rider otber(a) [tP~$'l
Rider to Paragraph 19
(H) "Applicable Law" mesas al! controlling applicable federal,
ordinances and admitdstrative rules sad orders (that have the effect of law) as well as all applicable final,
non-appealable judicial t~itt~ns.
(n "Comtnuplty Association ]Dtr~, Fees, and Aaaeasnrettts" areaos all dues, fees, aasesameata std other
charges that are imposed oa Borrower or the
association or similar orgaoizuion, Y ~' a cortdotnrwum association, hottreowrurs
(~ "~°dro°ic Freada ltanefea." means any transfer of funds, other than a
check, draft, or similar paper instrument, which is initiated throu as d ~d0a originated by
instrument, computer, or ~ econonic terminal, tetephonic
or credit an amount. Sut~ c ~ so as to order, instttx;t, or authorize a financial institution to debit
machine transactions, transfers ioit'ated~ byt ~ep~ ~n ~ t'ofaala transfers. atuomated teller
transfers. fora, and automated clearinghoase
(~ "Escrow heats" means those items that are described is Section 3.
~) ~~MLiceBaae°ua i{~0~~~ mesas aIIY eompattation, settlement, award of es or r
by any third parry (other than iasuratrce pmcoeds Paid under the cove es ~E P °COpds Paid
damage to, or destntction of, the Property: (ii) condeaanatioa or other t ~ ~ ~iOa S) for: (i)
Property; (iii) conveyance in lieu of condemnation; or (iv) mg of atl or any part of the
v~LLe and/or condition of the Property. ~srePraeatationa of, or omissions as to, the
(1~~M~ortgage Insurance" nrcans insurance Protetiiag ~~ against the nonpayment of, or default on,
q~ "Periodic A-ytoeut" aleaat the regularly scheduled amount due for i
Note, plus (ii) any amounts under Section 3 of this ()Pupa! and mteresi under the
Security Instrrtnrent.
®-6(PAl toaos~
'"o ~ 2 ~ ~~ Form 3pg8 1101
Larder is the mortgagee under this Security lattrutaent.
(D) "Note" meant the Promissory note signed by Borrower sad
The Note states that dated June 21st, 2002
BomowerowesLender Eighty Four Thousand and no/100,
(U.S. $ B4, 000.00 ) ply ~~ Borrowerhaa Dollars
Pay'tneats and to PaY ~ debt in full trot later hula July ls~a2032 ~ thin debt in regulaz Periodic
Property means the PmPe1tiY that is described below under the heading "Transfer of Rights in the
PAY "
(I'? "Loan" aneaas the debt evidenced by the Note, plus intet+eat, auY PmPayt~nt charges and late charges
due under the Note, and al[ sums due undo this Security insgvmetu, Plus interest.
(G) ~~~~" means VI Riders to this Security Ioatrutnent that are executed by Borrower. The following
Riders are to be executed by Borrower [check box as appticableJ:
8K 176;;F-~ j 435
12/30/2006 12:26:58 PM CUMBERLAND COUNTY
Inst.# 200225966 • Page 2 of 18
(O) "RESPA" ,Weans the Real Estate Settlement Ptoeedttrea Act
implementing regulation (12 U.S.C. Setxton 2601 et seq.) and its
Regtt[uioa X (24 C.F,R. Put 3500), ~ ~y might be a from time to
tune, or any additional or sttocessor legislatin m. ~ ~ govern t~ ssa~e subject matter. As used
m ~ minty Irstrument. "RESPA" refers to al]
to a "federally related ta~ortgage loan" u,~ if the L~ ~ a ~~,~~ ~~Y~ated mortgage
loan" under RESPA.
(P? "Sttocrasor to laterrat of Borenwer" mesas nay party ~ ~ caftan tick w the
not that party has aswmed Bornower'a obligation under the Note and/or this Savri ' whether or
ry trumeat.
TRANSFER OP RIGFITS IN THfi PROPERTY
This Sequ~ity Instrument secw,p to I.t»der: (i) the ttpayment of the i,oaq and all renewals, exteasioas and
modifications of the Note; and (il) the p of
Security Instrumem and the Note. For this purpose, Hon+o ~,ah~ ~ ~ ~ ~t'0~~ nAder this
oLender the following dearrlbed property logted is the county ' &'~ and convey to
Cumborland frYPa cf itowrdiets )urisdluioal
See Attached Legal Description ~"~ °f~01d'"a 7prinl:
which currently has the address of
1919 Carlisle Road
("Property Address"):~ Hill [ChYI, Pemtaylvaaia 17011 tZip ~)
TOGETHBR WiTA ail the improvements now of heaeaftzr orated on the property, and, all
addidons~shall~cove~ ~~ IIOw or heceaRer a part of the property. All raplaceatents and
N
Security Instrument as the 'Props ty ~ ~~ty ~. Ali of the fm~egoing is referne~ to is this
-8(PAl roooe~
r+o. a a is
Coen noes trot
B~{ ! 76:~Fi; t 436
12/30/2008 12:26:58 PM CUMBERLAND COUNTY
Inst.tl 200225966 -Page 3 of 18
BORROWER COVENANTS that , is lawfully seitred of the
the right to mortEage. grant ~ o~ estate herby conveyed and has
encumbrances of recortt. Borrower ~ ~ ' and that the Property is ~~ except for
claims sad and wi)I defend wally the tide to the
demands, aubjax m nay enwmbrancee of record. Y ~ttst all
THIS SECURITY INSTRUMENT combiner; uniform coveptmta for national nee sad non-uniform
covenants with limited variations by jttritdiction to
Ftopam,• eaetstitttte a uniform security lnstrutnent voveting real
UNIFORM COVENANTS. Borrnwce ~ I.endcr covenant and m follows:
gorrower~~i npey whw due they &ce+uw Items, Prepays Cbargm, and Lane C es.
P~Yment charges and laps chugu due under the on, the debt evidenoM by the Note anhad~aay
pursuant to Section 3. Payments due ttndet the Note and thm:hat! also pay fad for F.scr'ow Items
currency. However, if any check or other instrument received Scarcity Inst~ shall be made in U.S.
Security Inauurnent is rettuaed to I~der ~' I~der +~ Payment under the Note or this
due under the Note and this Securi I ~~~ I.eatler may n9~ thu arty or su
tY »elrnment be made in one ar mon of the followJ'ngtforms, as
selected by Lender: (a} cash; (b) money order; (c} certified rireck, bank t~tcek, tt+eaeurer's check or
cashier a check, provldod arty such check is drawn
federal agcy, inatrumemaiity, or enti ar d)~ectronIc an institution whose deposits are insured by a
~Y~ts are deemed received ~: () ~°~ Transfer.
such outer location as may be ~ I•~der wh°° ~~ ~ ~ location designated in the Note or at
Leader may return an ~~ ~ Leader in aooordaace with the notice provisions In Section IS.
bring the Loan current.Leader rots ~~ ~ if the payment or partial payments are insufficient to
current, without waiver of Y accept ~ PaY~nt or partial payment h~cieat to bring the Loan
~ ~u der or Prejudice to its rights to nfitse such payment or partial
P$Ymenta in the future, but bender is not obligated to apply such paymeata at the time each paYmants arc
accepted. If each Periodic Payment it appl~d as of its
interest on unapplied tlrads. Leader mauled ~ tltue, thm Lender need not pay
the Loan current. If ~Y hold such naappliex! funds until Bort+owgr mates pttytomt to bring
Borrower does not do so vrithia a teaeonabk period of time. Lender shall either apply
such ftruds or return them to Borrower. if not applied earlier, each fu»ds will be applied to the attstaading
Principal balance under the Note immediately prior to fondtuut+e. No oflhet or claim which Borrower
might have now or in the future against Leader shall relieve ~~~ from malting PaY~nts due under
the Note and thin Security Instrument or petfo
instrument. ~~ ~0 coveoan~ a~ socured by this Security
2. Application of Paymapta or
payments ao;,epted and applied by ~ ~~ as otherwise dea~i>~ in this Sootion 2, all
due under the Note: (b) principal due trader the No~M in the following order of priority: (a) interest
shall be applied to each , () ~~ ~ ~' Section 3. Strclt
Periodic Payment in the order iA which It bocame due_ PaYt~nts
shall be applied first to late charges, secrnrd to any other amounts due under this S ~ nmg e®Ot1ats
then to reduce the principal balaatx of the Note. tY iastnrment, sad
if Lender receives a payment from Bornower for a delinquent Periodic Paymprt which includes a
sufficient amount to pay any late charge due. the payment a»q, be applied to the delinquent payment and
the late charge. If more rhea one Periodic Payment is ou
from Borrower w the repayment of the Peiodic Payn>mta~ r~~• ~ ~ any Payment received
, each payment can be
-BfAA} ioooar ~~
rp.sor ~a
Form 3039 il'Ol
6K 1 7 6 ~'l~ i 4 3 7
~7l3~l9f111A 1T9R~Ffl PAA f:UMRFRI ANft Cfl11NTY
Inst.# 200225966 -Page 4 of 18
paid in full. To the extptt that nay excess exists after the paylm~etu is lied to the full
more Periodic Paytrteats, at~h exoesa may be applied to ~ Pay of one or
be applied first to my prepayment ehsrsa ~ rhea ~ described lapse, . Voittrttary Pr'ePaYmunts shall
My application of Paymuots, iasur~oe Pt'~ds, or Misoellapeouc Prooaeda to
the Note shall not extend or postpeae the due date, or e ~ P~dPal duc under
3. I~tnds for Eacmir Itpos. Borrower shall Chang ' of the P~iod;c I'aymwts.
wader the Note, until the Noce is ~ 1° La-det oa ~ day Periodic Payments are due
for: (a) taxes and P~ ~ tuts, a sum (the Funds) to provide for payer of atnouats due
and other items which can again priority over this Security instrtrrn~t as a
lieu or encumbrancx on the Property: (b) bold
premiums for any and all inawmcu paymertta or ground testa on the Property, if my; (c)
premiums, !f my, or ~ Currier udder Su~O° S+ sari (d) Mortgage Insurance
~Y stmu payable by Borrower to Lender
is lieu of the
Items." At originatl Qr wiW the provisions of Seaiga lp. 7~ ~ are calladMoEEscmw
Association Dues. Fees. and ~~ th0 term of the Lom, Lender ~, ~~ thu CO0°m~ty
asae:ameats sbatl be m Escrow~~ if ~, be escrowed by Borrower, ,I~ aucb does, fees and
be paid undo this Section. Borrower ahal ahatl ~'0~Y ~'~ to Lender all notices of an>founts to
13orTOwer's obli ~ Lender th0 ~+ for Furrow Items unless bender waives
obligation to 8~ to Pal' ~ Ftitods for my or au Exxow Items, Lcttder
Pay to Lender Pwtds for my or all Escrow ~' waive Borrower's
in writing. in the evem of such waiver, Borrower shall Items at ~' time. Aay such waiver asay only be
due for any Escrow Itealu far which Pt4Y di:+ealy, whm sari where pay~le, the amounts
shall furnish to Lander teoe3pts PaY~ of Funds ~ born waived by Leader and, if Lender requires.
Borrower's obligation to matte ~ p ~mmant within auk titre parlod as Lender ~, ~~.
be a covenant and agreement contained in this Security l~rumeattL~ ~ ail Ptt'P°B~ be donned to
is used in Suction 9. if Borrower is ob ' P1u'ate 'covanaat ~ agr'~nt'
Borrower fails to pay the amount due forgro~,~ ~ I~ ~Y. Putt to a waiver, and
and pay such amount and Borrower shall the~t be obi ~ tendar ~' exerolse its ~m ttttder Section 9
amount. Lender may revoke the waiver as to origated under Section 9 to repay to header my such
accordance with Suction 1 S and ~ Eacro~'-' Items u nay time by a notice given in
such arnottn[s, that are rhea ~ ~ such revocation, Borrower shall pay to Leader all Funds, and in
Lender ma ~ m roqutrod utuier this Section 3.
the Funds at the time
Y, fled trader RESPA Fhttba is m amount (a) sufficient to permit lender to apply
require wader RESPA. Lender shall ~ + and {b} opt tp exceed ~ aNOUat a lender can
reasonable estimates of lmate the amount of Funds doe on the basis of ptrrtxtt data and
Law. uxpeuditpt,m of truur+e Escrow Items or otherwise in accord,~e with Applicable
The Funds shall be held is m institution whore depoaiU are insured b
irratrumentrtlity, or entity (ineludirtg Louder, if Leader is m itratitutloa whose Y a federal agency,
any FoderaI Home Loaa Beak, Leader shall apply ~ ~~ ~ deposit: are so inaw+od) ar in
speclfiod wader RF.SPA. Leader shall not cLargu gprroaror for ~ ~ ~ tto later tium the tip
analyzing the escrow accormt, or idl~g ~ ~Yhtg the Funds, annually
Funds and Applicable Law v~'~ ~ Escrow ~, ~~ Lauder Pays Bon+ower iatereu oa the
or Applicable Law permits I.tader to °~ ~ a charge. Ualese an ~ trtade ~ wridng
y interest or
ar' earnings oa fire Funds Bp~ ~ ~~• I'mo' °~ not be t+oquirud W pay Borrower
Leader r;an agroe in writing, however, that intere~
®~ afPA{ +oooa w
Pw.ea~e
Form 303Y 1101
BK17Ei~~i;1438
~•~nnr~nnR t) 9R 5R PM RUMAFRI ANE) f:f)I INTY -• ^~ ~~~~ _ ~'-• ._ •^_
Inst.lf 200225966 -page 5 of 18
shall be paid on the Funds. Lender stroll give to Borrower, without charge, aq annual aocoutujng of the
Funds as requirod by RESPA.
If there is a surplus of Fonda heW in escrow, as defined coder ItESPA, Le+acler shall account to
Borrower for the excess foods is awot+daace with RESPA, If there is a shortage of Funds held in escrow,
as defiaod under ItFSPA, Lender shall notify Borrower as required by RBSPA, and Borrower shall pay to
i-ender the aa>tount necessary to taaice up the shortage is a with RESPA, lwt is rb moue tltao 12
monthly payments. If therz is a deficiency of Funds beJd is escrow, ss defmdd tro~dtr
notify Borrower as roquired by R$SPA, and Borrower sha11 RESPA, Leadex shall
up the deftcieacy )n acco[dance with ~ ~ ~rY ~wmsnt ~y~a' to matte
Upon payment is full of all sums ,Lender shall promptly nfttnd
to Borrowex any Fuada held by Lst>rier.
4. Charges; Liet>s. Borrower shall pay all taxes, assesameots,
attributable to the Pt~operty which can attain fines, sad impositions
gtnttnd rents on the P~ntY over thin Security In:rrumeat, leasehold payments or
~P~Y. U any, sad CommudtY Association Duea, Fees, and Asaessmeata, if atty. To
the extent that these items are F.sctow Items, Borrower shall pry thorn ~ the manner pmvidod is Section 3.
Borrower shall promptly dischat'ge say lien which hat
Borrower: (a) agrees is writing to the P~~Y ~' this Security Irrstrumeat unless
to Lender, but oni so ton as payareat of the obligation secat+ed by the lira in a manner acceptable
Y 8 Borrower is performing such aptx~t; (b) Mesta the lip in good faith
by, or defends against enfonoernent of the lien in, legal Proceeding: which in Lender a ittioa
prevent the enforcement of the lien while those ~ oP operate to
are concluded: or (c) secures from the holder of the anc ~~' ~ Daly until such proceedings
the lien to this Security Instrttmeat. I f ~~ detetmiaea ~t °~~or7' to Lender subordinating
which can attain priority over this Securi Y Part of the Property is subject to a lien
lien. Within FO Jaya of the dace on which • ~~ tray glue B°rr°wer a nonce idencifyittg the
more of the actions set fo[th above in this Section 4. ~ 8n'~. Borrower shall sa[&fy the lien or take one or
[.ender may regttue Borrower to pay acne-tittle cbuge for a real estrae tan verification and/or
reporting service used by Lender in cA,naectioa with this Loan.
S. Property Lswrasne, Borrower shall
ttte ~nY inattred agaiaat loss by fire ~ ~ tmproveauats now e>rhitiog or her+eafiter erected on
other hazards including, but not limited toh~s ~~ within the term •exteaded coverage," and any
This insurance shall be [naiatained in t>te wakes and floods. for which Lender re9uim insutaatx.
Leader [rquires. What Lender amouttsa (~~ ~ leveht) and for the periods that
the Loan. The insurance carrier~~ Plat to tIu pt~g can ~e during the term of
right to disapprove Borrower's choice w>u~'ch~~ shall be ~' ~~ subjea to Lender's
require Borrower to ~ :hall [>ot bo ~atencised u[rrea,onably. ~~, may
PaY. is connection with this Loan, dther: (a) a one-tlme charge for flood zone
determination, certificatbn and
and certification services sad services; or (b) a one-time cttatge for flood zone determination
reasonably might affect such ~t charges each time ren[appirtgs or similar changes occur which
txmination or certifltxtion. Borrower sdall dm ~ r'~apoasible for the
paynteat of say fens imposed by the Federal ~uageacY IKaarlgemeat Agency in correction with the
review of any flood zone determination tnsttiting from an objection by Borrower.
-6tPA) accost w ~p
~ s a is Form 3039 1101
BK 17'6:i~'~ ! 439
17l4l1Mf1l1R 17•~R•5R PAA C:I IMRFRt ANr}!:f)IIN1Y y
Inst.# 200225966 -Page 6 of 18
If Borrower fails to maintain nay of the ooversygea described ~~, Leader may obtain insurance
covq~~t. ac lender's option and Borrower's expwae. imtder 4 under no oblfgation to purchase any
P~~u1ar type or amount of covtntt;e, Therefor, ouch eoven~e shall ~~ . but
not protect Borrower, eorrower'a equity is the Property, or the omtents of the might or might
hazard or liability and might provide gnator ~ Iptlr ~ ~rtY, against sty risk,
acknowledges that tht cost of the insurtmx ~,~ ao o ~~ "~ Y ~ efi'ect. Borrower
insurance that Borrower could have ~~ s~rificatttly exceed the coat of
becottu sdditional debt of Bortnwet setau+ed b~thia ~~ ~ L,eoder ur>`der ~ Secdoa S shat]
at the Note rate from the date of disbursrateat and ahal~ty fit. ~~ amounts shall bear interest
Leader to Borrower nqucuigg payer, PaY~e, with auk interest, upon notice front
AlI insurance policies ~~ by I.wtkt and r~wali of :vcb- policies shall be
right to disapprove tuck Policies, shall iadtade a standard ~°~ to Latder's
martgagx and/or as an additional loss a ~auae, sad shall acme Lerder as
certificates. If Leader ~ ~~' Lander ahali have the right to hold the policies and renewal
renewal notlcea. Ff + ~ shall Y ~~ to Lender all reoeipu of psid premiums and
Boaower obtains nay form of iaaursncx oovarage, ant ot6araviae
for damage to, or deatrluxion of, the property such nquind by Leader,
shall name I.cnder as mortga,Qee and/or as an atlditionai ~ ~ , include a staadsmd mortaase ciawe sad
In the event of loan, Borrower ~1 gig prompt notice to the hrsttraace larrkt and
~Y asake proof of loan if not made promptly by Borrower, UnIeaa Lender sad . Lender
in writing. nay insurance ply, whesbor or twt the under] BOn'o~ otherwise agree
be applied to restoration or repair of the yiag insarauoc wan required by Lander, shall
Leader's security is not lessened. During a, if the reutoratioa ~ ~r ~ °0 feasible sad
hold such insurance proceeds anti! Leutder hoe had as ~~~ P~• Fender shalt have the right to
work has been completed to Lender's satisfaction. pnurided that inapaxion shall be ~~ the
promptly' Leatder may draburse Proceeds for the repairs sad nesta~ in a single ~
of progress Payments as the wait is completed. Unless as agr+eemprt is made in wd ~~ or in a aeries
requires interest to be paid on ouch insgraaoc prooaeda, T.eader shall not be rogaind w or Applicable Law
interest or earnings on such pr+otxeda, Fees for public erg jt~ Pay Bon'owa ,ay
Borrower shat] not be paid out of the ' ~ °~~ ~~ Pottle:. retained by
the restoration or repair is not et~nonticatl Procxeda and sbdl be the aok obligatiest of Borrower. if
y feaable or Lender s
P~~s sh f ~ aPPiied to the auma aeatred by tb~ ~~h' yutrumaat.~wbetherl~ ~tuwa
Section 2. y' paid to Borrower. Such iaautlurce p ahatl be
~ order provided for in
If Borrower abaadoga the prop~y~ Ltstckr
claim and related mauers. If Borrower does not ~Y fib' mate sad settle any available insurance
insurance carrier has offend to aside a wItbin 30 days to a notice from Leader that the
period will ~, then [,ender may aegog711e ~ awe the claim. '!Le 3O-day
begin whin the notice !s ~~. In ~~. event, or if Leader
Section 22 or otherwise, Borrower property under
~, ~igm to T.etder acquires the
Premeds in as amount not to exceed the (+~ Borrower's tights to any insurance
(b) any other of Borrower's amount: unpaid under the Note or this Security Ia:<rumeat, and
Borrower) under all inwrance~u (other than the right to awry refund of unearned prepriy~ paid by
coverage of the ~~ Q°VO~g the property, insofar as soeh
~'oP~Y• lender may use the iastnsmce proceeds either to riighta are appligble to the
to pay amounts wtpaid under the Note or this Security taatntment, why or not that due. ~ ~
(~-t;(PAl 10000 ~~
rw.~a~s
t-orm 3038 1101
BK 1763PG ! 440
12/30/2008 72:26:58 PM CUMBERLAND COUNTY
Inst.# 200225966 • Page 7 of 18
6. Oawpaacy, Borrower shall otxupy, establish, sad ttse the
residence within 60 days after the execution of this Y as Bortwer's principal
Property as Borrower's prlaGpttl resideatx for at least ~~~ aM shall c~ntinne to oxupy the
otherwise agrees IA writIag, which consent shall not be date of oxupuxy, uatesa Lender
circumstanoea exist which are beyond Borrower's oorttrol. Y withheld, or unkss eltteattating
d~lOy' damage °r ~~~perty, all~teetio~a of the Yropertr; InaPectloos. Borrower shall not
Y. Whether or not Borrower is res.. ' ~ d~mtasate or oormnit waste on the
order to prevent the prppE1rty {~ deteri ~ ~~ Y. tall tuaintaia the property in
determined tuattant to ~6 deg ~ vahte dae to its amdltioa. UNesa it is
Pt'omPUY repair the Propertynif ~ ~ or reswration is not ~onomically fea:ibk, Borrower shall
condemnation wed to avoid further deteHoratioa or damage. If insurance or
shall be re~onaib an P~ ~ QO~Op with dalaage to, or the taking of, the
repairing or restoring the Property only if Lender bas rele+sedY. Borrower
purposes. Leader taay disburse prooeede for the prvoeeds for such
progrlesa payments as the work is completed. If theme 'in ~ ~ 1A a sit~(e paY~tt or in a series of
to repair or restore the property, Borrower is sot relieved of or t~sndeamattoa p100°°ds ar+e °0t sufficient
such repair or restondoa. mower's obligation for the completion of
Linder or its agent may melee reasonable entries upon a~ inapetxiona of the pr
reasonable cause, Lender may inspect the interior of the unProvanents on the °piem`' ~ it has
Borrower notice at the dine of or prior to such an interior inspection ~P~Y' i.ender shalt give
S. Borrower's Loan Appiietttion. Borrower shall be in default fY~B atrch r~aaonable cause.
Process, Borrower or anY Persons or entities acting at the direction of Borrower or wL ~ Borower's
knowledge or rortscnt gave materially false, misleading, or inaocarate information or afar
(or fallod to provide Lender with ttaatetial information) is connoctioa with the ~~ to Lender
r'eFreaentatiaaa include, bnt are not limited to. represerttatiotu ~. Material
~PenY as Borrower's princppa( residentx. CO°0~°mB Borrower a otxupancy of the
4. Protectbn of Larder''s Iattt~ in the Property taod ~~ jJ~. tbie
(a) Borrower fails to perform the coveaatus ' instrwneat. If
is a legal procuding that might si ~ aW~aeats ~~a0d ~ ~ '~rrt3' fit, {b) thtrt
this Security Iastrutneat (match ~ a~Y affect Leader's ~~ in the Properly and/or tights under
enforcement of a lien which mrypup~tty off' 3 a~>1rt ' ~' ~nd~atron or forfeiture, for
regulations), or (c} Horroaer ~ abandoned ilia tY Iztz~tmmt or to enforoe laws or
reasonable or appropriate to protect Lettda's interest '.m' the pro ~Y do and pay for whatever is
Instrument, including proteetittg rtnd/~ aa:~aing the value of the Pew ~ rights under this Security
the Property. Lender's atxiona can ' Y. and sepuiag and/or repairing
include, but are tint limited to: (a) paying say atnr><s seatred by a lien
wftich has priority over this
aaorneys' fete to Security ~Wmmt; N) aPP~~ ~ court; and (c) prying reasonable
Protect its interest in the Property and/or
its secured position in a bankruptcy proceed ~u trades this Security Instrument including
entering the property to maker repairs, change ~ ~ ~o~y ~~• but is not limited to,
from pipes, eliminate building or other code vialatioru olax or board tip doors and windows, drain water
on or off. Although Lender may take action otmditions, and have utilities turned
under any duty or obligation to do so. It is agreed that Leader incurs oa liability orvuot taking any or all
actions authorized tinder this Section 9.
®-sll'AF ttwast
0
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Fenn 3tl39 1101
8K(76~P~1441
1713{1/7[1(18 17.7Fi•SR PM f:t1MRFRl ANn C:(111NTY -.,._~
)nst.# 200225966 -Page 8 of 18
Any amounts disbursed by Lender undo this Saxioa 9 shall become addttioaal debt of Borrower
secured by this Security Inattttnrerrt, '!~ amount: s>udl bear fntenat at the Note rate (from the date of
disbursement and shall be pzyabk, with etch interest, upon notitx from header to Borrower requesting
Payment.
If thls Security Insbwnent is on a leaaobwid, Borrowq~ shalt ~
base. If Borrower acqulyd Yee title to the ~Y with all the proviaioaa of the
Lender agrees to the merger in wrl ' Y. the leaaelrold turd the fee title shall tat merge artless
BotrowerMa)talO1 jib ~. If L~~aoder rogttit+cd Mortgage j>uuatimee as a conditiaat of nuking the Loan
the Mortgage Insurance coverage ~~ to ~ ~ Mortgage laauraace in effect. If, Por any reason,
previously provided such insurance and Bgrpq~. ~ to be available from tla mortgage inatrtrr that
toward the premiums for Mo a ~~ to melee aepaeuely deaig~ payrents
coverage aubstsatiall rt8aS HOn'0t"'°r th~l 1xY the p~~ requited to obtain
etpti alent to the coat to
v Y ~ Borrower of the M~ In+tttaa~ p~rousiy ~ ~ :< a °~ aubaantially
mortgage insurer selected by L~ertder. If subat~ pY m effect, from an alternate
available. Borrower shall continue to ~Y «luivalem Mortgage Inautaave coverage is rot
were due when the insuraaoe covet ~~ to I;~ader ~ amount of the :~telY deaigtrated
e ceased to be is tdfect. Leader will accept, use and retain these
PaY'~rs as a non-refiutdabk loan swerve is lieu of Mortgage Inwraaoe. ~ ltm traserve shall be
~iretirndable, notwithstanding the fatx that the Loan k dtimatety paid in full. and Leodetr shall sot be
pay Borrower any iatcrest ar eatnings on Latch lea rarrvc. Leatkr taut no ' nequlr,e Iola
reserve payments if Mortgage iasuraace coverage (tun the atraunt and for the period that Leader t+equines)
provided by an insurer se~etxed by Leader +i~ becomes avat~abk is
sepatwely desigasaed payments toward the obtaitad, and Lender tegttires
lnaurance as a condition of tnakiag rho l.o o a~ ~~°i~ . If Leader regairnd Mo
~Se
payments toward the premitrpot for Mortgage , Borrower ~ ~ ~ Y
marntain Mortgage [narrattce in effec or to required to
rl.~~r~vld r Mf rtg~ 6rstuatttx tads in accordance wWr any written agieememt utttll Leader's
p kg termination or until termination la required by Applitubla Law. N ~r sad
Section 10 affects Borrower's obligation to pay i>uet+mc st the rue provided is the Note. °~mg is this
Mortgage Insurancx ~ reader (~ ~, ens that pturhsaea the Note
may incur if Borrower does rat repay the Loan as agr~ood. Borrower Is act a PAY rtoMot~tgagie
Insurance,
Mortgage insurero evaluate their toW fiat oa ail audr tnsutaaue in force from time to time, sad tray
enter into agreenrenta with other parties that share or modify their risk, or reduce losses, T>fxse moments
are on terms and eonditioas that arc aatiafatxory to ~ iaaurer ~ tau other parry (or pubes) to
o~~ ~rnents.~Theae agreemeata may rtgttir+e the mortgage itutu+er to make payments using ,~y aou~c
Insurance premiums)~e insurer tray ~7C available (which may include fwrda obtainM from Mortgage
As a result of these >;groemwts, Lender, ~, per. of the Note
any other entity, or any ttfYliiate of say of the • a°O~r fir, any reitraurer,
derive from (or t be ~°~• ~Y ~?ive (directly or indirectly) amounts that
exchange for ahari~ag or mfyrag tbewmo portion of Bor'rower's paymeati for MortS'4Ba Insuraox in
provides that as affiliate of Leader fates a s o~r simurter's ~ loataea. If such t
premiums paid to the imut~er, the arranges is often termed •gpyve ~~e futt~er ~~ of the
(a) My such agr'captsrta r-tll sot s~lfed idle artaoutua tlssd Bosrewar ~ agreed to pay for
B~orro~were wt11 ~~ag~' terror of tLe Loan. Sn~ ~eab wt0 tact
Instrraoce, and they wilt toot entitle Bora+awer to atry ~fihe amount
(~-S1PA) ynooa~
ro• • a to Form 3039 1101
8K1763EsG1442
17/'i(1/7~(1A 17.78 5R PM rllMRFRI ANf) f:f111NTY ~+ `
Inst.# 200225966 -Page 9 of 18
(b) Any such its will trot aRect the testa Borrower bas - U
Mortgage itmtranee under ~ gouneowttKrs p~~~ ~ of 29913 or ~Y -with respell to the
may include the rtgLt to recNre eartttfa aW' other taw. These rights
Mortgage [ua~ttraatx, to have the Mortptge ~~ sad obptin qo of the
t~eftmd of any Morylage Inntewnce p~~y that wets ~~ M~'~ or to receive a
termi~tion. cvoodtatioa or
11. t of Mi.odi.aeow pt~py; ~tekure, Ail Mitcellatuous
~~~ ~ Maid to [.coder. Pt~nceeds are herby
the ' >uclti Misoetlaneats Pi+ocaeds obeli be applied to restoration or repair of
Property, if the restotyti~ or repair is a:anatooicdly femble and Lsadar s sera
During sorb ~r ,~ renotatioa Pte. Lander shall Lave the right to hold sndt Misr a anernu proooeds
uadl Lender ha had an opporpa~, ~ such
l:.eader'a satisfaction Y to emure tLe work La: been
r .provided flail ouch iaspoctien than be uodertaium ootnpleted to
epairs and restoration in a single disburterneat or is a snip of lY- Leader ~ ~` ~ the
completed. Unless an agreement is made ~ wtitit~ ar Apptipble Laws ~~~ '~ ~ work is
Mtuxilaneous Proceeds, Lender shall not be ~p to be paid on such
Misccilaneaua Proceeds. If the restoration or p PaY Borrower ally miereat or earnings oa ouch
be lessened, the MIacetlatreotra Peocoods shalt is not economitatlly taat'bto or Leader's security would
whetbu or not thin due, with t>w exops if an ~~ to the attars secured ~, ~ Saxtrhy Instnrrnent,
applied in the order provided for in Section 2. y' paid to Bon+ower. Such Mitcedlrmoous p sh~l be
In the event of a total taking, deaattcda~n, or loan in value of the
Pmceeda shall be applied to the rotas Y~ ~ MiscelIatuoua
the excess, if any, paid tp $p~pwQ, d~uied ~' ~ SGGirity Instttintent, whether or not thw due, with
In the event of a partial taking, dptlUCtiOn, or loss is value of the
value of the Property inimediatdy before the partial Y ~ ~~ tLe fair market
greater than the amount of the soars secured by this ~• ~, or loaf in value is equal to or
taking, destruction, or loo in value, unlps Borrower ~ ~ 0~~~0'd~Y before the partial
secured by this Security Iaatrttment shag be +~ in wny Proceeds
multiplied by the following fraction: a the rednoed by ~ amount of the Miaoell
putial () toW amottat of the soma seettred Imroediuely before the
taking, dptrtttction, or Iost in value divided by (b) the fair market value of the pt+operty
irn~i ~Y b~ore~ ~ tald~, won, or lost in value. Any batanoc shall be paid to Borrower.
value of ttte ~, , or toe in vahu of the Property in which tLe fair marks
immediately before tLe P~ ~~. datrttgioa, or loaf in vatne L lea than the
ar>lowu of the autt>: atxtrr+ed immediately beEor+e tLe partial
Borrower and Lender oi~r~vi:a ~ ~ write. tLe Mistxll ~, destnrction, or tots la value, unless
secured by this Security Instrument whether car not ~ AOSOUS ~oceedt shall be applied to the sums
If the Property is abartdoaed b tarot are rhea due.
y Borrower, or if. after notice by Lender to Borrower that the
OPPos~B Party (a defined is the next seatace) offaa to make as
Borrower fails to napond to Lender within 30 awed to aottle a claim for datnrtg
to collect sad apply the Misceliaruout proceed=ms's after the date tLe ttotiae is gives, Ltd is authorized
sums secured by thin Saatrity Instrument, whether or not then ~ ion or repair of flu Property or to the
drat owes Borrower Miscellaaeoua Proceeds or the party against whng Parry nreana the third party
regard to Miat:eitaneous Prvaeda. rrowror ha a right of action in
Borrower shall be in defwtt if arty action or
iettder's judgment, could nptilt in forfeiture of ing. civil or criminal, is begun that, in
interest in rho Property or ~~ ~, ~ nY or other msserial hnFairmeat of Lender's
acceleration has ~tY Tnstrtmunt. Borrower pre cure attcL a defauti and. if
occrtrted, reinstate as provided in Section 19, by causing the action or Proceeding to be
®0 BtPA) ioooa~ i
re• ~o ar ~e Fo~n 9o3a 1101
BKI763PCI443
19!'i~19nnR 19.9R•fiR PM RI IMRFRI ANI7 CI~UNTY
Inst.#200225966 • Page 10 of 18
dismissed with a ruling that, in Leader's judgmgrt, precludes forfaitnre of the Property or other tnuerial
itnpairt>xat of Leader's interest in the Property or righu under this Setarrity Iratntroent. The prooeeda of
any award or claim for dsmagea that an atMbtnable to the impairanent of l.ender'a intet+eat is the Property
are hereby assigned and shaq be paid to Deader.
All Miaxilaaeotra Proceeds that are not applied to restoration or repair of the Property chap be
applied in the order provided for in Section Z.
IZ. Borrows Not Rdeaaed; 1~esfiarasroe By Lander Not a Wah-a'. Extemion of the time for
payment or modificatimt of amordzatioa of the somas secured by this Sewrlty Insirummt granted by I.ender
m Borrower or atry Strooessor is Intelsat of Borrower shall not opeeare to rdaae the liability of Borrower
or any Successors in Interest of Bonovver: Leader shall ~t be rognired to oommeooe proceedings against
any 5ueoeaaor in Interest of $ocr~oMrer or to refine to extend tlase for payment err otherwise modify
arnortizatioa of the sums secured by this 3eprtity tnruamutt by rearon of any demand trade by the orlgiaal
Borrower or any 5uoceswrs in Interest of Borrower. Any forbearance by Lander in axmciaiog any right or
remedy including, without limitatMa, Lender's aooeptance of payments from third persoaa, etttitiea or
Successors in Interest of BorTOVwor or is aawuats lea than the amaau then due. shall not be a waiver of or
preclude the exer>riae of nay right oc remedy.
13. Joint and Several Llabllity; C Snoeeasors nail Amlgas Botrstd. Borrower wvetuutts
and agues that Borrower's obiigstiom andality ahail be joint and neutral. However, a~ Borrower who
co-slgas this Security Iaatrttmeat but don not ~tocuta the Note (a "co signer'}: (a) is co-signing this
Security tnstttrateat only w mortgage, grant and oom+ey she eo-dgrraa~'s interest in the Property under the
terms of this Security isutrtrment; (b} is not porsowliy obligtttod to pq the sans secured by thin Security
lasa~tment; and (c) agrees that Lender and nay other Borrower pat sgt?tx w etttend. modify, forbear or
make nay accoramodatioas with regard to the ttxaas of this Security Inmumeat or the Note without the
co-signer's consent.
Subject to the provisions of Saxton 18, any Strcassor in Interest of Borrower who assumes
Borrower's obligations under this Security Ltttrumenc in writlgg, and is approved by Lender, shall obtain
all of Borrower's rights sad benefits under thin Security lasttumenc. Bomowet shall trot be rdeased from
Borrower's obligations soil liability under Chia Socari<y inauumatt unlas Loader agrees to arch release in
writing. The oovenauts nail agreemaits of this Seatriry Inatmaseot ahail bind (e~toept as provided in
Section 20) sad benefit the arecesaon sad assigns of Leader
lA. Loan Charges. leader may charge Borrower fen for service performed in oortaetxion with
Borrower's defwlt. for the purpose of protading L+eoder's interest in the Property end rights carder this
Security Instrument, including, but not iimltad to, attorarys' Lees. property ittspoatiaa and valtertton fees.
In regard to any other fees, the absence of express suthoriry in this Saauity Inatrumeat to charge a specific
fee to Borrower shall trot be construed as a ~hibition ~ the charging of such fee. Leader mry not charge
fees that are expre»ly prvhibitai by this Sewriry Instrument or by Applicable Law.
If the Loan is subject to a law which seta maxrmrmt loan charges. sad that law is finally iatetpretod ao
that the interest or ocher loan charges collocced oc W be eolletxal in oonoeetion with the Lana extxed the
permitted limits, thin: (a) any arch loan ebarge shall be r+edtrood by the amount necessary to redutx the
charge to the permitted limit; soil (b) nay sums already coltectod from Borrower which exceeded permitted
limits will be retlraded to Borrower. L.mder may choose to malts dris refund by reducing the principal
owed under the Note or by making a direct paymart m Borrower. if a tefiad reduces principal, the
reduction wilt be treated as a partial prepayment without any prepayment charge (whether or not a
prepayment charge is provided for wader the Note). Borrower's atxxptance of nay atilt t~efund made by
direct payment to Borrower will constitute a waiver of a~+ right of notion Borrower might have arititrg out
of such overcharge.
IS. Notlkea. All notices given by Borrows or L,etrdcr is coanecdoa with this Security Instrument
must be in writing. Any nodes to Borrower in coaaection with thin Soauity Instruzlrwtt 1 be deemed to
~.P
6(PA) ioowi r~ n or +e Form 30]9 1101
B4~ 1763~G 1444
12/3012008 12:26:58 PM CUMBERLAND COUNTY tnst.# 200225966 -Page 11 of 18
have ban given to Borrower whtxt mailed by first class tuail or whey atxttaily delivet+ed to Borrower's
notice address if sent by other meaaa. Notice to atq one Harrower shall oooBihste noticx ~ all Borrowers
unless Applicable law exPrtxsly requinea otherxiae. The n~ca ttdthxss ahail be the Property Address
unless Borrower has designued a substitute notices addrat by notloe to Lender. Horrvwer shalt Pronsptly
notify Lender of Borrower's change of address. If Lender apocifia a prooedtste for reporting Borrower's
change of address, then Borrover shall only npurt a change of addrea thr+ostgh that apecifled p~cocedure.
There may be only one designated ttotica atWren under thin Security ltaaument u auy one lino.
notice to Lender shall be given by delivering it or by tuaitittg it by fi»t class nutil to Lender's address
stated herein unless Leader has anther eddreu by aotioa to Bore~ower. Auy notice in
connection with this Security Iasttuntatt shall not be deemed to have bas gives to Lender ttotil actually
received by Lendtx. If any tsotioe rooquiired b!' this Setauity tostrumeat is alas required under Applicable
I.aw, the Applicable Law requirt:meat will aatiafy the oorreapoudlug requirtutent tinder this Security
Instrument.
16. Governing Law; Severabttity; Rules a[ C.orotntctiast. Thies Security Iaatrsttnent shall be
governed by federal law end the law of the nuiadiction iA which the Property b located. All righu sad
obligations conteiaed is this Searity Imtnsmeot are wttjact w arty its sad tlmitatiotu of
Applicable Law. Applicable law toidtt eaplsidtlY os impWdttY allow the paetia to agree by ooturact or it
might be silent. but :tseh silences shad not b Maatrtwd as a prohibition against ase~aeaoaot by ooutract. In
the event that aa0' proviai~ or cJaute of this Security instrtsmeot or the Note coatlicta with Applicable
Law, such coa>lict ahaU trot affect other provisions of thin Security laatrumeat or the Note which cut be
gives effect without the oonAbdaj provision.
Ace rased is this Security Instrument: (a) worth of the masculine gender shall mean and incitiae
corresponding neuter words or words of the femiobc ,gender: (b) wotda is the singular shall mean and
include the plural and via vanes; and (c) the womd "may" gives sole discretion without any obSgatioa to
take any action.
17. Borrower's Copy. Borrower shall be given one copy of tits Note and of this Secasrity Instrument.
18. Transfer o[ the PsopertY oe a BeadlcJd Ietereat ist Borrower. As used is this 5a:tion 18,
'Interest in the Property" aseaoa soy legal ~ beneficial interest in the Property, incioding, but not limited
to, those beneficial interwu transferrod b a bond for deed. contract for decd, installment Saba contract or
escrow agrameat, the iateat of which is the traosfar of dtte by Borrower u a futnee date to a purchaser.
If all oc any part of the Property or say Intdrst in the Property is sold or traosftct>rd (or if Borrower
is not a neural person and a beneficial intasst in Borrower b sold or trtmsferred) without Imo': prior
written consent, Lender may require immediate paymgtt in lblt of all sums secured by this Security
Instrument. However, this option shall not be mteMsed by Leitdar if such exercise is pt+ohibitod by
Applicable Law.
If Lender exercitea this option, Leader sha11 give Borrower notion of ecalerittion. The notice ,hail
provide a period of not less chats 30 days from fire data the notice b gives in axotdantx with Section 15
within which Harrower must pay all aunt secured by tbia Security I»atttiaient. if Borrower fails to pay
these ,urns prior to the expiation of thin period, Lender may invoice any remedies permitted by this
Sccuriry toattvnseat without fSitther notice or demand ~ Borrower.
19. Borrower's Right to Rdt>rtate Ater Aoedantion. If Borrower locates certain conditions,
Borrower shall have the right to have entix+cameat of thin Secutiry iostnintaot diaoontimied at air time
prior to the earliest of: (a) five days bafaa+e nab of the Property pursuant to say power of sale cx>otttintd in
this Security Instrument; (b) such other Period as Apptic~ble Law might specify for the ternsination of
Borrower's right to t+einstau; or (c) entry of a judgment atforciog that Sorority Irutrtsnos:nt. Those
conditions eft that Borrower: (a) Payer Lander ail sums which then would be due untbr this Security
Instrument and the Note a iP m acceleration had oocumed; (b) queer any defatilt of any other covenants or
(~-6iPAt roooa) Paps t2 of is ~Fo~3039 1101
sn ~ ~6~~c i 44s
12/30/2008 12:26:58 PM CUMBERLAND COUNTY inst.# 200225966 -Pace 12 of 18
agretaaettis: (c) pays all expenses i» curred in ettfottdag this Security Iastrurnwt, irtcludiog, but not limited
to, reasonable attorneys' face, property inspection and valuation tees, and other fees hxstrred for the
purpose of protecting header's intet+est in the Property and tights under this Setarriry Ittatummt; and (d)
taloes such action as Lender may reasooabUr rngttire to asstue that Leader's irrterrrst in the Property and
rights under thin Saatriry Inttrttment, and Borrower's obligation to pay the wtf~ secured by this Seauity
Inurwaent, shall ooatinue unchanged. Leader racy engttire that Borrower pay atx:h ~t sutn4 and
expenses in one or moue of the foUowtog [orms, as selecsed by Lender: (a) puh; (b) moony order; (c)
oertitiod check. bank tgtedt, traattt+er'a checyt or cashier's td>aJc, provided any sucb tdtadc is drawn upon
an it~titutian whose deposits are insured by a fedantl ageary, inttrumentalliry or eatiry; or (d) Electronic
funds Tranefcr. Upon reimtatemeat by Borrower, this Seauiry Inunufaeot and obligations secttr+ed hereby
shall remain fully effective as if no aotxieration had occurred. However, thL right to reinstate shall sot
apply is the cane of accelersti~ wader arteries 18.
?A. Sale of Note; Change of Laauf Sa~ticer; Notke of C,rlevance. The Note or a ptntial interest in
the Notc (tageiher with this Sa:uriry ]nstrummf) txn be sold sax ~ more times without print notice to
Borrower. A sale alight result in a change in the entity (knows as the "Corm Servicer7 that collects
Periodic Payrnetus due under rite Nora and this Security inst[tto~eat and performs other mortgage leas
servicing obligations under the Note, this Security lasauma~t, sari Applicable Law. There also might be
one or more changes of the Loan Senncer unrelated to a sak of tha Note. ]f theme it a change of the Loan
Servicer, Borrower will bt given wtittea ootioe of the c>taoge which will state the name sad address of the
new Loan Servicxr, the addr+eas to which payments should be trade sad arty other information IZESPA
requires in connection with a notice of transfer of servicing. if the Note is sold sad thereallrar the Loan is
serviced by a Loan Servicer other theses the pturiwtr of the Note, the mortgage loan servicing obligations
to Borrower will remain with the Loan Services or be trrmsfemed to a strccettor Loan Servicer and arc not
assumed by the Note purchaser unless otherwise provided by the Note purchaser.
Neither Borrower nor Leadtx may commtmce, join, or be johted to any judicial action (as either an
individual litigant or the member of a daft) that atisas from the other party's actions purauaat to this
Security lrtstruroeat or that alleges that the other party has breached any provision of, or any duty owed by
trae0n of, this Security Inatrunreat, until such Borrower or Leader has notified the OthCt' party {with such
notice given in compliance with the requirtmtms of 5ecxion 15) of snch alleged ba+each and afforded the
other party hereto a reasonable period a[ger the giving of strdt trotioe to take corrective action. If
Applicable Law provides a time period whirA tmtst etapte before rxltsin action can be taken, that tune
period wiU be deemed ro be rasonable for purposes of this paragraph. The notiot: of at:celeration and
oppotttmiry to sue given to Borrower pursuant to Soaion 22 and the notice of aocciersfion gives to
Borrower pursuant to Soctiaa 18 shall be deemed to satisfy the notice and opportuairy to take corrective
action provisions of this Section Z0.
2]. Hazardous Str>>stAnoes. As used is this Section 21: (a) "Haaatdotrs Subata~ei" are those
substances defined as toxic or hawrdous aubetnncea, pollutants, or wastes by Environmental Law snd the
following subatatrtxs: gasoline, lterosene, other 8attsmsble or toxic petroleum prodtttxs, tox~ pesticides
and herbicides, volatile solvents, materlsls oontaiaing asbestos or formalddtyde, and radioatxive materials;
(b) "Enviroanrental Law" therms federal laws and Lws of the jurisdiction whea+c the Pt+opeurty is located that
relau to health, safety or environmental protecdoa; (c) "Enviroaavecnal Cleaturp" includes say response
action. remedial action, or removal action. as defined in Emironmattai Law; and (d) as "Eavir+onmental
Condition" means a condition that can tastse, oo®otr~ttte to, or othene+lse trigger an Envirottm,ental
Cleanssp.
6(PA) IOOOBf hy" t D er 1i +~
Form 3038 1 f0'1
8K 1763PG 1 X46
~~lZft/9(1f1R 1~~~R•FR PM f:l IMRFRI ANfI f:f)IINTY
Inst.# 200225966 -Page 13 of 18
Borrower shall not cause or permit the presence, use, disposal. sxorage, or tdase of aqy Hazardous
5ubstatrces, or threaten to release say Hazardous SuMtaorxs, oa or is the Proposty. Borrower shall tat do,
nor allow anyone else to do. anytbiag affecting the Property (a) that Is ja violation of ary Bnviroomeatai
Law, (b) which creates an Envirorrmaspd t7onditioa, or (c) which, due tQ tha pi~panoe, use, or release of a
Hazardous Substance, create: a condition that adversely affects the vahre of the Property The preceding
two sentencxs shall not apply to the ,use, or storage ~ the Property of small quantities of
Hazardous Sabatasrces that are y tooogpizod to be app~rlate a normal rpidential uses and to
mairuenance of tht Property (' tiding, but not lisuited to, hazardors nrbstaooa is otuesasm~ae pro~uxs).
Borrower shall promptly give Loader written notice of (a) say lav~a~a, claim, deusactd, lawsuit
or other action by say governmental at regulatory u~' a' private Pte' ~ ~ Y ~ ~Y
Hazardous Subctaace or Envitanmerrtal Ltw of whrch Borrowtr bas actual knowledge, (b) any
Environtnaual Condition, including but not limbed to,a~y apilting,lsaltiog. dia~harge, release or thrra[ of
release of any tiazudous Substanx. and (c) aqy ooarKtiea caused by the presence. use or release of a
Hazardous Subataace which adversely aftecq the value of tha Property. If $orrowsr learns, or is mtified
by any ernmrotal or regal authority. or say private parry, that uqy rnraoval or other r+eraediation
of any l~azardow sub:tanee a!~ the Psvperty is aoetstsary. Borrower' ahau promptly tale all neoa:ary
remedial actions is aceomdratoe with Baviroamesrtal Law. Nothing heroin shall create say obligation on
Lender for as Envit+ottmentrd
NON-UNIFORM COVEN Borrower sad Larder further eovewat and agree as foilowa:
22. Accetetwtton; Remedta. Louder s1eaU ~ ootkx to Borrower paiodawtion tolbwfag
Borrower's bt~adr of any anensuet tar ags+asnaat is thb Saaaity Itt (ltut not prbr to
acceleration adder Secttou I8 colas La p,ovWat otitsrwise). Leteder afeail aotity
Borrower ot, among other tbiapt (a) tfaAd~ (b) the aetba retry6~ed to era ribs idtudt; (c) wher
the ddautt must be carat; sad (d) that fallm~e to etn,e tiffs dappek as clay rook ha
aaodauioa of the sums secured b tfds 9eeortty Ltah'tmsat, l~edowts+e by s~dkdttt pe+oeeedtag and
sale of the Property. LeAder shall intoew Borrower of the right to r+d>~e alts' aots'isratioa
and the right to assert is the toerctoatre prsosediog the ado-mace o[ a de[auk or any akher
ddeose of Bomow~ to aoce]eratlon surd tae+eeisame. Itt the eldadt is not erased as apedfLed Leedq~ art
its option tray requirs imsaediata ppaayymm~ot la ttitU of aB surds scarred by tLis Sscarlty Iostrumesst
without further dema~ and slay toe~eclose this Sewsity Imbrvasaet by Jodfdal~. Lends
shall be entitled to twliect all eapeosa fttatrred in flee rromedla pt+ov fa thb 3ectloa Z2,
including, but cat limited to, attorweys' tea and costs tftte evidence to the eattmt permitted by
Applicable Law.
23. Relearn. Upon payment of all sums secured by this Socuriry Iostrutneat, this Sctxtrity Instrument
and the estate convoyed shall terminate and become void. After such oocurreoee, Lender shall diacltargc
and satisfy thi: Security Itrscrument. Borrower ahaU pay say reeordatbn cost:. Lender may dtarge
Borrower a fee for releasing this Seastity Insaesmeat. brit only it the tee is paid to a tlsird party for services
rendered and the charging of the fee is permitted under Applicable Law.
24. Waivers. Bortrnver. to tM extern ~aneltted by Applicable Law, waives and releases any error or
defects in proceodings to enforce this Soaterty Irz;trumast. sad hereby waives the benefit of any present or
future laws providing for stay of execudan, exteasioa of time, atemption from attachment, levy and sale,
and homutead exeentption.
Z5. Reissatataadst Period. BOr'r~owe['s time t0 [eleatatC provided in Section 19 shall extend t0 one
hour prior to the comnaenoement of bidding at a sheriff's sale or othor sale pctrauant to this Security
lnstruntent.
Z6. Purchase Mosey Mortgage. If any of the debt accused by this Savrlty Inatrntrient is lent to
Borrower to acquire title to the Property, this Security Instrttrnent Mall be a purchase money age.
2?. Ioterat Rate After Judgment. Borrower agr+eet that the i~t rate payable afro as ~~it is
enured on tJse Note or in as action of mortgage foreclosure :hall be the rata payable trine to time
under the Nou.
®-BiPA) ioooo ro.,. err s ~ suss trot
BK1763PGt447
,~i~nr~nnA ,~•9a~SA pRA !'I IhARFFiI ANrf f:(111NTV Info # 90099.59FiEi - Paoe 14 of 18
BY SIGNING BELOW, Borrower atxxpts and ggreea to the terms and covenants contained in this
Security Instrument and in any Rider executed b3` Borrower and horded with it.
witnesses:
~" /'~.
(Sear
Lu J isre •8orrower
(SCa1)
Nfcole L.VTsri~ -Borrowu
(Seat) (Seal)
-Borrower -Borrower
~~~ ~~~
-Borrower -Hortower
($Cet) (SCaI)
-Borrowv -Borrower
®-6tPA1 ioowi rp. rs a re
m Form 9osta 1101
g~ l 7b3PG l 448
17/3[>l~~f1R 19~9fi 5R PM (:l1MRFRl ANt7 f:f)I INTY InSt.# 20022596fi -Page 15 Of 18
Certificate of Residence
I, • do htx~y txrttfy that
the correct address of the within aaaled Mortgagee is PO Box 1711, xarriaburq, PA 17105
Witness my hand this Zlat day of June 2002
W u~/Gf/
Anent of Mortaaga
COMMONWEALTH OF PENNSYLVANIA, Cumberland County sa:
On this, the 21st day of June 2002 ,before me. the
undersigned officer, personalty appeatad Lucas J Prina g~ Nicole L. Prins
..-:~
satisfactorily proven) to be the person(s) whose name(s) ia/att atbacribed to the withid• inatctiitd~af' and , .° "
acknowledged that he/ahe/they exearud the same for the purposes herein ooatahxd. -~~•~
. ' 'y.,,
IN WITNESS WHF•REOP, I het+eltato set and official seal. `'~~;
~:~Y a".
My Commission Expitl;a: .Nh~y°.
NOTARIAL SEAL Fabric _ -
gxisbna L HatsheY. rltxaty~~
~Y~~. ~p ~'~j~un z5, 2oos
~.BiPA} pooh hpr to a is
BK 17 63P~ 1449
~nlaw: N~"P
Form 3039 7f01
19/~t119n(1R 1~ ~fi~SA PM f:l IMRFRI ANI7 C:nI1NTY Inst.iF 200225966 -Page 16 of 78
ALL THAT CERTAIN piece or parcel of land situate in Lower Allen
Township, Cumberland County, Pennsylvania, described according to
Plan No. 7 of Highland Estates Development made by D.P.
Raffensperger, Registered Surveyor, dated April 1, 1952, and also
according to a Plot Plan of Highland Estates made for F.B.J.
Branagan by D.P. Raffensperger, Registered Surveyor, Lemoyne,
PA., dated January 20, 1955, more particularly bounded and
described as follows, to wit:
BEGINNING at a point on"the Northerly side of Carlisle Road at the
distance of four hundred thirty-five (435) feet westerly from the
Westerly side of 19th Street {SO feet wide); thence extending
Westwardly along the Northerly side of Carlisle Road, sixty (60)
feet to a point; thence extending Northwardly along the line
dividing Lots Nos. 30 and 31 on the above mentioned Plan, and
crossing a ten {10) feet wide easement one hundred twenty (120)
feet to a point; thence extending 8astwardly sixty (60) feet to a
paint; thence extending Southwardly recrossing said ten (10) feet
wide easement and along the line dividing Lots 31 and 32, one
hundred twenty {120) feet to the Northerly side of Carlisle Road,
the first mentioned point and place of BEGINNING.
BEING known as Lot 31, Block "E" on the above mentioned Plan.
HAVING THEREON ERECTED~a.dwelling known and numbered as 1914
Carlisle Road, Camp Hill, Pennsylvania.
BEING the same premises which Wayne D. Harris and Melissa K.
Harris, husband and wife, by their deed to be recorded
simultaneously herewith in the Office of the Recorder of Deeds of
Cumberland County, granted and conveyed unto Lucas J. Prins and
Nicole L. Prins.
T C'..^.~iry ;',in t-^ Fc rL:cordcd
in C;u~~~bcrland County PA
~~ 17 6 3 PG 14 5 0 "' Recorder of Deeds
12/30/2008 12:28:58 PM
CUMBERLAND COUNN
Insk# 200225966 -Page 17 of 18
• ~ ~~ ~,
'„~~~n~
Rider to Paragraph 19
(Moztgage)
I/We, the undersigned Borrowerts), do hereby agree that the following
Rider to Paragraph 19 of the Mortgage, executed by me/us this 21st
day of June, 2002 shall be effective in accord with the terms and
conditions there of and shall be deemed to be a condition of the
Mortgage.
The "reasonable attorney fees", as set forth in Paragraph 19 hereof,
shall be deemed to mean five percent (5~) of the principal due at the
time of foreclosure ar 5300.00, whichever is greater. This provision
shall be void in the event this Mortgage is transferred to the Federal
Home Loan Mortgage Corporation t"Freddie Mac"}, the Federal National
Mortgage Association ("Fannie Mae"), or any other entity utilising
assignment or transfer. This provision shall also be voided if this
Rider to Paragraph 19 is in violation of any provision of Freddie Mac
or Fannie Mae.
ri
(sue)
(SEAL)
Ni le L. ins
if/4o
r
WCRDRO (12/001
gK 1763PG l 451
12/30/2008 12:26:56 PM
CUMBERLAND (:AUNTY {nst.aY 200225968 -Page 18 of 18
~~
oz ts~"9~ ~
DEEDS
`!!l?Y - PA
'oz JuN ~~ s~ ii s2
. ,~
r
'4Y~e744ST -aR~y
Rcrotding itequesoed By/Return To: Waypoint Bank, 101 9. teorge st.
York, PA 17401 •~,,..
ASSIGNMENT OF MORTGAGE
For Value Receivod, the uttdenigoed holder of a Mortjaje (herein "Aaaigrtor') whose address is
PO Box 1711 ,Harrisburg, PA 17105
does ~~ &~' ~• aYlJia. tra+u(er and ~', unto Principal Reaidentiai Mortgage, Inc.
existing under the taws of Iona a PD~on_ ~ Or~aoirrd and
711 Righ Street ,Den tdoiaas, IA 50392 ~~ '~l~ )~ ~~ ~~ L
a certain Mtutgsge Jane 21, 2002 .made and executed
Lucas J Pr Nicole L. Prins ~
to 2nd in SraYPoin~t~Bank
payntaatof Eighty Four Thousand end no/100, dollars aodgivmtosxum
(S 84,000.00 ) 07/01/2032
Usehds ohs Original Maipal Aaeouea sad Dale or Now(s1)
which Mortgage is of [eeord in Book, Volume, or Liber No. ~ , >K P~ ~ 43 ~ (or as
No. ) of the Records of Cumberland
County. State of Pennsylvania ' whh ~ tea) ~ o6ligattons tbereirt
described sad the tmoey due and to become due thetnon wlth intereat. and all righu aCCrtted or to accrue
under such Mortgsge.
TO HAVE AND TO HOLD the arise unto Aaaigax, its otocesaot ~ assign. fortver, ~~~ only to
the terms and coaditlans of the above.descrlbed Mortgage,
IN WITNESS WIdERBOF, the tutdudgaed Aaigmr has ezecuted thin
June 2]r, 2002 ~1~ _ Allaigamatt of Mortgage on
pr ` Navooint Bank
(A d
n By:
w~
Colleen Santucci
^~ Assistant Vice President
Seal:
Thu Initrutoml l>tepared By: Waypoint Bank
Harrisburg, PA 17303 ~~~~ ~ Box 1711
. tel. m.: 8G6-929-7646
STRTE OF PENNSYLVANIA
- SS:
COUNTY OF YORK -
on thls the 21st day of June
Public, the undersigned officer, ' 2002 befoze me, Notary
personally appeared
Colleen Santucci who acknowledged she to be the
Aasietant Viee President of Waypoint Bartk
thatherself as such Assistant Viae Pr~aident, beingaauthozised to dod
so, executad the foregoing instruessrtt foz the purpose therein contained
by signing the name of the corporation by herself as
Assistant Vics President
IN WITNESS WHEREOF , I herr:unto set my hand and official
s~~i
AAXJOV 5/02
rau.euMMwi w..~~...n «a.r.rs arts
t~sswx awawi
vw ~saae rorrre. aoaeuraai
.. _ ~~14ek. YaR~ Pspae I
g~.^,~ 68~ ~:ir,~ t 277
12/30/2008 12:27:56 PM CUMBERLAND COUNTY Inst.# 200225967 • Page 1 of 2
f ~
J
ALL THAT CERTAIN piece or parcel of land situate in Lower Allen
Township, Cumberland County, Pennsylvania, described according to
Plan No. ~ of Highland Estates Development made by D.P.
Raffensperger, Registered Surveyor, dated April 1, 1952, and also
according to a Plot Plan of Highland E~Itates made for F.B.J.
Branagan by D.P. Raffensperger, Registered Surveyor, Lemoyne,
PA-, dated January 20, 1955, more particularly bounded and
described as follows, to wit:
BEGINNING at a point on the Northerly side of Carlisle Road at the
distance of four hundred thirty-five (435) feet Westerly from the
Westerly side of 19th Street {60 feet wide}; thence extending
westwardly along the Northerly side of Carlisle Road, sixty (601
feet to a paint; thence extending Northwardly along the line
dividing Lots Nos. 30 and 31 on the above mentioned Plan, and
crossing a ten {10) feet wide easement one hundred twenty (120)
feet to a paint; thence extending Eastwardly sixty {60) feet to a
point; thence extending Southwardly recrossing said ten (10} feet
wide easement and along the line dividing Lots 31 and 32, one
hundred twenty {220) feet to the Northerly side of Carlisle Road,
the first mentioned point and place of BEGINNING.
BEING known as Lot 31, Block ~~$~~ on the above mentioned Plan.
HAVING THEREON ERgCTgD'a dwelling known and numbered as 1914
Carlisle Road, Camp Hill, Pennsylvania.
BEING the same premises which Wayne D. Harris and Melissa K.
Harris, husband and wife, by their deed to be recorded
simultaneously herewith in the Office of the Recorder of Deeds of
Cumberland County, granted and conveyed unto Lucas J. Prins and
Nicole L. Prins.
I Certify this to be recorded
In CumbcrIand County PA
.-~-~
~ '`~° %~`
o;~ r~1,~
~ :J~.
BOOR fi~~ PAf~E ~.~ i H
12/30/2008 12:27:56 PM CUMBERLAND COUNTY Inst.# 200225967 - Page 2 of 2
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in Lower Allen Township, Cumberland
County, Pennsylvania,. described according to Plan No. 7 of Highland Estates Development
made by D.P. Raffensperger, Registered Surveyor, dated April 1, 1952, and also according to a
Plot Plan of Highland Estates made for F.B.J. Branagan by D.P. Raffensperger, Registered
Surveyor, Lemoyne, PA., dated January 20, 1955, more particularly bounded and described as
follows, to wit:
BEGINNING at a point on the Northerly side of Carlisle Road at the distance of four hundred
thirty-five (435) feet Westerly from the Westerly side of 19th Street (60 feet wide); thence
extending Westwardly along the Northerly side of Carlisle Road, sixty (60) feet to a point;
thence extending Northwardly along the line dividing Lots Nos. 30 and 31 on the above
mentioned Plan, and crossing a ten (10) feet wide easement one hundred twenty (120) feet to a
point; thence extending Eastwardly sixty (60) feet to a point; thence extending Southwardly
recrossing said ten (10) feet wide easement and along the line dividing Lots 31 and 32, one
hundred twenty (120) feet to the Northerly side of Carlisle Road, the first mentioned point and
place of BEGINNING.
BEING known as Lot 31, Block'E' on the above mentioned Plan.
HAVING THEREON ERECTED a dwelling known and numbered as 1914 Carlisle Road, Camp
Hill, Pennsylvania.
File #: 195104
BEING the same premises which Wayne D. Harris and Melissa K. Harris, husband and wife, by
their deed to be recorded simultaneously herewith in the Office of the Recorder of Deeds of
Cumberland County, granted and conveyed unto Lucas J. Prins and Nicole L. Prins.
PROPERTY BEING 1914 CARLISLE ROAD
PARCEL 13-23-0547-348
File #: 195104
VERIFICATION
I hereby state that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside
the jurisdiction of the Court and/or the verification could not be obtained within the time allowed
for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P.
1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are
based upon information supplied by Plaintiff and are true and correct to the best of my
knowledge, information and belief.
The undersigned understands that this statement is made subject to the penalties of 18
Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities.
DATE: ` ~ Z ~ /
Attorney for Plaintiff
File #: 195104
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ,..,~, ~,
Sheriff FLtL _::' r,(;~
Jody SSmith -
Chief Deputy 2Q ~ ~ ~~~~ ! ~ ~~ ~:
Edward L Schorpp
Solicitor ~} '
_ ~ ;,y ~,
CITIMORTGAGE, Inc.,
vs. Case Number
Nicole I Prins 2009-177
SHERIFF'S RETURN OF SERVICE
06/29/2009 02:02 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on
6/29/09at 1400 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and
Description, in the above entitled action, upon the property of Lucas J. Prins and Nicole L. Prins, located
at, 1914 Carlisle Road, Camp Hill, Cumberland County, Pennsylvania according to law.
06/30/2009 06:15 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
6/30/09 at 1809 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the
above entitled action, upon the within named defendant, to wit: Nicole I Prins, by making known unto,
Lucas Prins, husband, at, 1914 Carlisle Road, Camp Hill, Cumberland County., Pennsylvania its contents
and at the same time handing to him personally the said true and correct copy of the same.
06/30/2009 06:15 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
6/30/09 at 1809 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the
above entitled action, upon the within named defendant, to wit: Lucas J. Prins, by making known unto,
Lucas J. Prins, personally, at, 1914 Carlisle Road, Camp Hill, Cumberland County, Pennsylvania its
contents and at the same time handing to him personally the said true and correct copy of the same.
09/01/2009 Property sale postponed to 11/4/2009.
11/03/2009 Property sale postponed to 1/6/2010.
01/04/2010 Property sale cancelled on 1/4/2010
01/07/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED,
per letter of instruction from Attorney Schmieg.
SHERIFF COST: $869.77 SO A~~
*1.. t~ ~.
January 07, 2010 ~~'~~:.
RO Y R ANDERSON, SHER~~'~`"
s ;~ ~ U C o
Ci_~ "~~~~~~
CITIMORTGAGE, INC., S/B/M TO PRINCIPAL
RESIDENTIAL MORTGAGE, INC.
`'~ ~ Plaintiff;
v.
LUCAS J. PRINS
NICOLE L. PRINS
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. CIVIL-09-177
AFFIDAVIT PURSUANT TO RULE 312'9.1
CITIMORTGAGE, INC., S/B/M TO PRINCIPAL RESIDENTIAL MORTGAGE, INC ,Plaintiff
In the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information concerning the real property
located at ,1914 CARLISLE ROAD, CAMP HILL, PA 17011-5911
1. Name and address of Owner(s) or reputed Owner(s):
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
LUCAS J. PRINS 1914 CARLISLE ROAD
CAMP HILL, PA 17(111-5911
NICOLE L. PRINS 1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
2. Name and address of Defendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained,. please indicate)
LOWER ALLEN TOWNSHIP AUTHORITY
LOWER ALLEN TOWNSHIP AUTHORITY
C/O STEVEN P. MINER, ESQ.
2233 GETTYSBURG ROAD
CAMP HILL, PA 17011
1035 MUMMA ROAD, SUITE 101
WORMLEYSBUR.G, PA 17043
4. Name and address of last recorded holder of every mortgage of record.:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
5. Name and address of every other person who has any record lien on the property:
' ' Name Last Known Address ~;if address cannot be
reasonably ascertained, please indicate)
LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEKILN ROAD
NEW CUMBERLAND, PA 17070
6. Name and address of every other person who has any record interest in the property and whose
interest maybe affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertainedl, please indicate)
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
Internal Revenue Service
Federated Investors Tower
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
6th Floor, Strawberry Sq., Dept. 28061
Harrisburg, PA 17128
13th Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
P.O. Box 8486
Willow Oak Building
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.
March 27. 2009
DATE
~ ~ '1
DANIEL G. SCHMIEG, E E
Attorney for Plaintiff
CITIMORTGAGE, INC., S!B/M TO PRINCIPAL
RESIDENTIAL MORTGAGE, INC.
Plaintiff,
v.
LUCAS J. PRINS
NICOLE L. PRINS
Defendant(s).
CUMBERLAND COUNTY
No. CIVIL-09-177
March 27, 2009
TO: LUCAS J. PRINS
1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
NICOLE L. PRINS
1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
* *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAYS PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOU.GD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY. * *
Your house (real estate) at , 1914 CARLISLE ROAD, CAMP HILL, PA 17011-5911, is
scheduled to be sold at the Sheriffs Sale on SEPTEMBER 2, 2009 at 10:00 a.m. in the Cumberland
County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of
$93,078.10 obtained by CITIMORTGAGE, INC., S/B!M TO PRINCIPAL RESIDENTIAL
MORTGAGE, INC. (the mortgagee) against you. In the event the sale is cantinued, an announcement
will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT TH1S SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how rriuch you must pay, you may
call: X215) 563-7000.
2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other Iegal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling 215 563-7000.
2. You maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You maybe entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is vrrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. I_t may not be sold
in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be
postponed or stayed in the event that a representative of the plaintiff is not present at the sale.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
LEGAL DESCRIPTION
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Township
of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, described
according to Plan No. 7 of Highland Estates Development made by D. P. Raffensperger, Registered
Surveyor, dated April 1, 1952, and also according to a Plot Plan of Highland Estates made for F. B.
J. Branagan by D. P. Raffensperger, Registered Surveyor, Lemoyne, PA, dated January 20, 1955 as
follows, to wit:
BEGINNING at a point on the Northerly side of Carlisle Road at the distance of lour hundred thirty-
five feet Westerly from the Westerly side of 19th Street (sixty feet wide); THENCE extending
Westwardly along the Northerly side of Carlisle Road, sixty feet to a point; THENCE extending
Northwardly along the line dividing Lot Nos. 30 and 31 on the above mentioned flan, and crossing a
ten feet wide easement one hundred twenty feet to a point; THENCE extending Eetwardly sixty feet
to a point; THENCE extending Southwardly recrossing said ten feet wide easement and along the
line dividing Lot Nos. 31 and 32, one hundred twenty feet to the Northerly side of Carlisle Road, the
first mentioned Point and Place of BEGINNING.
BEING known as Lot No. 31, Block 'E' on the above mentioned Plan.
HAVING THEREON ERECTED a dwelling known and numbered as 1914 Carlisle Road, Camp
Hill, Pennsylvania.
UNDER AND SUBJECT to certain rights of way, conditions, and restrictions as now appear of
record.
TITLE TO SAID PREMISES IS VESTED IN Lucas J. Prins and Nicole L. Prins, h/w, by Deed from
Wayne D. Harris and Melissa K. Harris, h/w, dated 06/07/2002, recorded 06/27/2002 in Book 252,
Page 1921.
PREMISES BEING: 1914 CARLISLE ROAD, CAMP HILL, PA 17011-5911
PARCEL NO. 13-23-0547-348
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-177 Civil
CIV [L ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITIMORTGAGE, INC., SB/M TO PRINCIPAL
RESIDENTIAL MORTGAGE, INC., Plaintiff (s)
From LUCAS J. PRINS AND NICOLE L. PRINS
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found. in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $93,078.10 I.L. $.50
Interest FROM 02/21/2009-09/02/2009 (PER DIEM - $15.30) - $2,968.20 AND COSTS
Atty's Comm % Due Prothy $2.00
Atty Paid $177.40 Other Costs
Plaintiff Paid
Date: MARCH 31, 2009
rtis R. Long, P onota
(Seal) By:
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: PHELAN HALLINAN &SCHMIEG, L.L.P.
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
,t '~ fi t '.... .;.~.,~ yn .r{ Wi
7 ~ ~ 5
r~ ~~ ~~~'
~rt+r~r
Real Estate Sale #
On May 5, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA
Known and numbered as, 1914 Carlisle Road,
Camp Hill, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: May S, 2009
~J' • ~' 1
~r / , ti, 't1
Real Estate Coordinator
;;_ _~,
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
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:
July 24, July 31 and August 7, 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.
~- ~ ~ ~v
GL' isa Marie Coyne, ~~Qitor
SWORN TO AND SUBSCRIBED before me this
7 da of Au ust 2009
Notary
•~•~~~.~.'Ai1fr=,l SEAL
DE9uP.AN P-~ CCLLINS
Notary Public
CARLISLE BORC3, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
REAL ESTATE SALE NO. 73
Writ No. 2009-177 Civil
Citimortgage, Inc., s/b/m to
Principal Residential Mortgage, Inc
vs.
Nicole I. Prins
Lucas J. Prins
Atty.: Daniel Schmieg
LEGAL DESCRIPTION
ALL THAT CERTAIN tractor Parcel
of land and premises, situate, lying
and being in the Township of Lower
Allen in the County of Cumberland
and Commonwealth of Pennsylvania,
described according to Plan No. 7
of Highland Estates Development
made by D. P. Raffensperger, Regis-
tered Surveyor, dated April 1, 1952,
and also according to a Plot Plan of
Highland Estates made for F. B. J.
Branagan by D. P. Raffensperger,
Registered Surveyor, Lemoyne, PA,
dated January 20, 1955 as follows,
to wit:
BEGINNING at a point on the
Northerly side of Carlisle Road at
the distance of four hundred thirty-
five feet Westerly from the Westerly
side of 19th Street (sixty feet wide);
THENCE extending Westwardly
along the Northerly side of Carlisle
Road, sixty feet to a point; THENCE
extending Northwardly along the line
dividing Lot Nos. 30 and 31 on the
above mentioned Plan, and crossing
a ten feet wide easement one hun-
dred twenty feet to a point; THENCE
extending Eastwardly sixty feet to
a point; THENCE extending South-
wardly recrossing said ten feet wide
easement and along the line dividing
Lot Nos. 31 and 32, one hundred
twenty feet to the Northerly side of
Carlisle Road, the first mentioned
Poi;~t and Place of BEGINNING.
BEING known as Lot No. 31, Block
on the above mentioned Plan.
HAVING THEREON ERECTED
a dwelling known and numbered
as 1914 Carlisle Road, Camp Hill,
Pennsylvania.
UNDER AND SUBJECT to certain
rights of way, conditions, and restric-
tions as now appear of record.
TITLE TO SAID PREMISES IS
VESTED IN Lucas J. Prins and
Nicole L. Prins, h/w, by Deed from
Wayne D. Harris and Melissa K.
Harris, h/w, dated 06/07/2002,
recorded 06/27/2002 in Book 252,
Page 1921.
PREMISES BEING: 1914 CAR-
LISLE ROAD, CAMP HILL, PA 17011-
5911 PARCEL NO. 13-23-0547-
348.
The Patriot-News Co.
812 I~larket St.
Harrisburg, PA 17101
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
c~he ~lahiot News
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
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant 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 she 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 she 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 ran on the date(s) shown below:
07/24/09
Sworn to a ~~scribed before met is 14..daAugust, 2009 A. D.
~,, ,_
--~--~
Notary Public
`~~~~t~~~~r ~~~ln_
COAIlN1JNV~1EkLFti OF PENNSYLVANIP.
~Va#artai Seal
Sherri ~. Kisner, Notary Public
City Of Harrisburg, Dauphin County
MY Commission F.;q~ires Nov. 26, 2011 a
Member, Pennsvlu~nfa ~+ss+~claCion ..if ~l.ata.~.~4a
07/31 /09
08/07/09
Sale No. 73
1lVrit No. 2009-177 Civil Term
CITIMORTGAGE, Inc.,
s/b/m to Principal Residential
Mortgage, Inc
vs.
Nicole 1 Prins
Lucas J Prins
Atty: Daniel Schmieg
LEGAL DESCRIPTION
ALL THAT CERTAIN tract or Parcel of land
and premises, situate, lying and being in the
Township of Lower Allen in rho County of
Cumberland and Commonwealth of
Pennsylvania, described according to Plan No. 7
of Highland Estates Development made by D. P.
Raffensperger, Registered Surveyor, dated April
1, 1952, and also acwrding to a Plot Plan of
Highland Estates made for P. B. J. Branagan by
D. P. Raffensperger, Registered Surveyor,
Lemoyne, PA, dated January 20, 1955 as
follows, to wit: BEGINNING at a point on the
Northerly side of Carlisle Road at the distance
of four hundred thirty- five feet Westerly from
the Westerly side of 19th Street (sixty feet wide);
THENCE extending Westwazdly along the
Northerly side of Carlisle Road, sixty, feet to a
point; THENCE extending Northwazdly along
the line dividing Lot Nos. 30 and 31 on the
above mentioned Plan, and crossing a ten feet
wide easement one hundred tpventy feet to a
point; THENCE extending Eastwardly sixty feet
to a point; THENCE extending Southwazdly
recrossing said ten feet wide easement and along
the line dividing Lot Nos. 31 and 32, one
hundred twenty feet to the Northerly side of
Cazlisle Road, the first mentioned Point and
Place of BEGINNING. BEING known as Lot
No. 31, Block on the above mentioned Plan.
HAVING THEREON ERECTED a dwelling.
known and numbered as ]914 Cazlisle Road,
Camp Hill, Pennsylvania. UNDER -AND
SUBJECT to certain rights of way, conditions,
and restricfiong a?; now appeaz of record. TTTLE
TO SAID PREMISES IS VEST)JD IN Lucas J.
Ptms and Jiicole L. Prins, h1w, by Deed from
Wayne D. Harris and Melissa K. I~tris, hlw,
dated Ob1072002, recorded 06/27120f)2 in Book
252, Page 1921. PREMISES BEINGr 1914
CARLISLE ROAD; CAMP HILL, PA 17011-
5911 PARCEL N0.13-23-0547-348
PRAECIPE TO REASSESS DAMAGES
P.R.C.P. 3180-3183
CITIMORTGAGE, INC., SB/M TO PRINCIPAL RESIDENTIAL COURT OF COMMON PLEAS
MORTGAGE, INC.
Plaintiff CIVIL DIVISION
V. : NO.: CIVIL-09-177
LUCAS J. PRINS
NICOLE L. PRINS CUMBERLAND COUNTY
Defendant(s)
PRAECIPE TO REASSESS DAMAGES
To the Prothonotary:
Kindly Reassess the Damages per the Court Order dated 8/17/2009 _,? ? fa er
of the Plaintiff and against LUCAS J. PRINS AND NICOLE L. PRINS, defendant(s). a S.
:Z:70 ;z
As Set Forth in the Order $ 98,621.04
m
al 1?1 G? j fxbuinrusS
?jjj
C?S3 2
L14 (I c
Attorne or Plaintiff
Phelan Hallinan & Schmieg, LLP
Lawrence T. Phelan, Esq., Id. No. 32227
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Michele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esq., Id. No. 58745
Sheetal R. Shah-Jani, Esq., Id. No. 81760
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., Id. No. 93337
Vivek Srivastava, Esq., Id. No. 202331
Jay B. Jones, Esq., Id. No. 86657
Peter J. Mulcahy, Esq., Id. No. 61791
Andrew L. Spivack, Esq., Id. No. 84439
Jaime McGuinness, Esq., Id. No. 90134
Chrisovalante P. Fliakos, Esq., Id. No. 94620
Joshua I. Goldman, Esq., Id. No. 205047
Courtenay R. Dunn, Esq., Id. No. 206779
Andrew C. Bramblett, Esq., Id. No. 208375
Allison F. Wells, Esq., Id. No. 3009519
-a '
w,?
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
LUCAS JOHN PRINS
NICOLE LYNN PRINS
Chapter: 13
Debtor(s)
CHARLES DEHART
Movant(s)
vs.
LUCAS JOHN PRINS
NICOLE LYNN PRINS
Respondent(s)
Case Number: 1:09-bk-06803-RNO
ORDER DISMISSING CASE
Upon consideration of the Trustee's Motion to dismiss case and it having been
determined after notice and no response that the case should be dismissed, it is
ORDERED that the above-named case of the debtor(s) be and it hereby is
dismissed.
Date: December 21, 2010
By the Court,
6?,A v. o,?4,r
Robert N. Opel, H, Bankruptcy Judge
(W)
MDPA•Dismiss Case.WPT - REV 03/09
Case 1:09-bk-06803-RNO Doc 43 Filed 12/21/10 Entered 12/21/1013:35:17 Desc
Main Document Page 1 of 1
1l
AUG 17 2009 IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CITIMORTGAGE, INC., SB/M TO PRINCIPAL Court of Common Pleas
RESIDENTIAL MORTGAGE, INC.
Plaintiff Civil Division
V. CUMBERLAND County
LUCAS J. PRINS No. CIVIL-09-177
NICOLE L. PRINS
Defendants
ORDER
AND NOW, this l day of 2009 the Prothonotary is ORDERED to
amend the in rem judgment and the Sheriff is ORDERED to amend the writ nuns pro tune in this
case as follows:
Principal Balance $87,503.37
Interest Through September 2, 2009 $6,651.30
Per Diem $15.58
Late Charges $390.65
Legal fees - $1,325.00
Cost of Suit and Title $701.50
Sheriffs Sale Costs $0.00
Property Inspections/ Property Preservation $300.00
Appraisal/Brokers Price Opinion $0.00
Mortgage Insurance Premium / 10.00
Private Mortgage Insurance
wa.
195104
R_?
Non Sufficient Funds Charge $0.00
Suspense/Nlisc. Credits ($0.00)
Escrow Deficit $1,749.22
TOTAL $98,621.04
Plus interest from September 2, 2009 through the date of sale at six percent per annum.
Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above
figure.
7Y( COURT
Michele M. Bradford, Esq., Id. No. 69849
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
TEL: (215) 563-7000
FAX: (215) 563-3459
LUCAS J. PRINS
NICOLE L. PRINS
1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
,.
`•'?:? n' t?`?' <?`";:i4f?r;, :c?v?4'?b ? ? ?k'L'? 4'v"? 3`d`k? ?"ds''?%E.
-117
195104
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-177 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITIMORTGAGE, INC., S/B/M TO PRINCIPAL
RESIDENTIAL MORTGAGE, INC. Plaintiff (s)
From LUCAS J. PRINS AND NICOLE L. PRINS
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she, has been added as a
garnishee and is enjoined as above stated.
Amount Due $98,621.04
L.L.
Interest FROM 09/03/2009 TO DATE OF SALE ($0.00 PER DIEM) -- $0.00
Atty's Comm %
Atty Paid $1,082.67
Plaintiff Paid
Date: 1110111
(seal)
REQUESTING PARTY:
Name: JAIME McGUINNESS, ESQ.
Address: PHELAN HALLINAN AND SCHMIEG
Due Prothy $2.00
Other Costs
Da ' . Buell, rothonotary
By:
Deputy
1617 JFK BLVD, SUITE 1400
ONE PENN CENTER
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 90134
01
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
CITIMORTGAGE, INC., SB/M TO PRINCIPAL RESIDENTIAL COURT OF COMMON PLEAS
MORTGAGE, INC.
Plaintiff CIVIL DIVISION
v
LUCAS J. PRINS
NICOLE L. PRINS
Defendant(s)
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due
Interest from 09/03/2009 to Date of Sale
($0.00 per diem)
TOTAL
At 06
Pd 4
,
V-'-/0
C?
/u, 0o
7 -7
iu. GO ?
?y 0 p 0
"? m ei&' oa.
60 P H? IbNua153
5
OA,?53? -7
Note: Please attach description of property.
PHS # 195104
NO.: CIVIL-09-177
CUMBERLAND COUNTY
- 1 _3
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r
r-
$98
621
04 r
;
`" '
,
. c:j
$ 0.00 ca
$98,621.04
k4vv'
Attorney for Plaintiff
Phelan Hallinan & Schmieg, LLP
? Lawrence T. Phelan, Esq., Id. No. 32227
? Francis S. Hallinan, Esq., Id. No. 62695
? Daniel G. Schmieg, Esq., Id. No. 62205
? Michele M. Bradford, Esq., Id. No. 69849
? Judith T. Romano, Esq., Id. No. 58745
? Sheetal R. Shah-Jani, Esq., Id. No. 81760
? Jenine R. Davey, Esq., Id. No. 87077
? Lauren R. Tabas, Esq., Id. No. 93337
? Vivek Srivastava, Esq., Id. No. 202331
? Jay B. Jones, Esq., Id. No. 86657
? Peter J. Mulcahy, Esq., Id. No. 61791
? Andrew L. Spivack, Esq., Id. No. 84439
? Jaime McGuinness, Esq., Id. No. 90134
? Chrisovalante P. Fliakos, Esq., Id. No. 94620
? Joshua I. Goldman, Esq., Id. No. 205047
? Courtenay R. Dunn, Esq., Id. No. 206779
? Andrew C. Bramblett, Esq., Id. No. 208375
? Allison F. Wells, Esq., Id. No. 309519
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LEGAL DESCRIPTION
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania,
described according to Plan No. 7 of Highland Estates Development made by D. P.
Raffensperger, Registered Surveyor, dated April 1, 1952, and also according to a Plot Plan of
Highland Estates made for F. B. J. Branagan by D. P. Raffensperger, Registered Surveyor,
Lemoyne, PA, dated January 20, 1955 as follows, to wit:
BEGINNING at a point on the Northerly side of Carlisle Road at the distance of four hundred
thirty-five feet Westerly from the Westerly side of 19th Street (sixty feet wide); THENCE
extending Westwardly along the Northerly side of Carlisle Road, sixty feet to a point; THENCE
extending Northwardly along the line dividing Lot Nos. 30 and 31 on the above mentioned Plan,
and crossing a ten feet wide easement one hundred twenty feet to a point; THENCE extending
Eastwardly sixty feet to a point; THENCE extending Southwardly recrossing said ten feet wide
easement and along the line dividing Lot Nos. 31 and 32, one hundred twenty feet to the
Northerly side of Carlisle Road, the first mentioned Point and Place of BEGINNING.
BEING known as Lot No. 31, Block'E' on the above mentioned Plan.
HAVING THEREON ERECTED a dwelling known and numbered as 1914 Carlisle Road, Camp
Hill, Pennsylvania.
UNDER AND SUBJECT to certain rights of way, conditions, and restrictions as now appear of
record.
TITLE TO SAID PREMISES IS VESTED IN Lucas J. Prins and Nicole L. Prins, h/w, by Deed
from Wayne D. Harris and Melissa K. Harris, h/w, dated 06/07/2002, recorded 06/27/2002 in
Book 252, Page 1921.
PREMISES BEING: 1914 CARLISLE ROAD, CAMP HILL, PA 17011-5911
PARCEL NO. 13-23-0547-348
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
CITIMORTGAGE, INC., SB/M TO PRINCIPAL RESIDENTIAL
MORTGAGE, INC.
Plaintiff
V.
LUCAS J. PRINS
NICOLE L. PRINS
Defendant(s)
CERTIFICATION
Attorneys for Plaintiff
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: NO.: CIVIL-09-177
CUMBERLAND COUNTY
The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned
matter and that the premises are not subject to the provisions of Act 91 because:
( ) the mortgage is an FHA Mortgage
( ) the premises is non-owner occupied
( ) the premises is vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities.
By:
O
LJ M U
Attorney for Plaintiff
Phelan Hallinan & Schmieg, LLP
? Lawrence T. Phelan, Esq., Id. No. 32227
? Francis S. Hallinan, Esq., Id. No. 62695
? Daniel G. Schmieg, Esq., Id. No. 62205
? Michele M. Bradford, Esq., Id. No. 69849
? Judith T. Romano, Esq., Id. No. 58745
? Sheetal R. Shah-Jani, Esq., Id. No. 81760
? Jenine R. Davey, Esq., Id. No. 87077
? Lauren R. Tabas, Esq., Id. No. 93337
? Vivek Srivastava, Esq., Id. No. 202331
? Jay B. Jones, Esq., Id. No. 86657
? Peter J. Mulcahy, Esq., Id. No. 61791
? Andrew L. Spivack, Esq., Id. No. 84439
? Jaime McGuinness, Esq., Id. No. 90134
? Chrisovalante P. Fliakos, Esq., Id. No. 94620
? Joshua 1. Goldman, Esq., Id. No. 205047
? Courtenay R. Dunn, Esq., Id. No. 206779
? Andrew C. Bramblett, Esq., Id. No. 208375
? Allison F. Wells, Esq., Id. No. 309519
MIMORTGAGE, INC., SB/M TO PRINCIPAL
! RESIDENTIAL MORTGAGE, INC.
Plaintiff
V.
LUCAS J. PRINS
NICOLE L. PRINS
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.: CIVIL-09-177
CUMBERLAND COUNTY
PHS # 195104
AFFIDAVIT PURSUANT TO RULE 3129.1
CITIMORTGAGE, INC., SB/M TO PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff in the above action, by
the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the
real property located at 1914 CARLISLE ROAD, CAMP HILL, PA 17011-5911.
Name and address of Owner(s) or reputed Owner(s):
Name
LUCAS J. PRINS
2.
NICOLE L. PRINS
Name and address of Defendant(s) in the judgment:
Name
SAME AS ABOVE
Address (if address cannot be reasonably
ascertained, please so indicate)
1914 CARLISLE ROAD -- "a
CAMP HILL, PA 17011-5911
1914 CARLISLE ROAD to r--
-,; _ ? n7
CAMP HILL, PA 17011-5911
330
Address (if address cannot be reasonably
ascertained, please so indicate)
tt
.,,3
Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address (if address cannot be
reasonably ascertained, please indicate)
LOWER ALLEN TOWNSHIP AUTHORITY
LOWER ALLEN TOWNSHIP AUTHORITY
LOWER ALLEN TOWNSHIP AUTHORITY
C/O STEVEN R. MINER, ESQUIRE
120 LIMEKILN ROAD
NEW CUMBERLAND, PA 17070
2233 GETTYSBURG ROAD
CAMP HILL, PA 17011
1035 MUMMA ROAD, STE. 101
WORMLEYSBURG, PA 17043
4. Name and address of last recorded holder of every mortgage of record:
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
51- Name and address of every other person who has any record lien on the property:
Name Address (if address cannot be
reasonably ascertained, please indicate)
UCC DIRECT SERVICES
AQUA FINANCE, INC.
LOWER ALLEN TOWNSHIP AUTHORITY
LOWER ALLEN TOWNSHIP AUTHORITY
LOWER ALLEN TOWNSHIP AUTHORITY
C/O STEVEN R. MINER, ESQUIRE
P.O. BOX 29071
GLENDALE, CA 91209-9071
P.O. BOX 844
WAUSAU, WI 54402
120 LIMEKILN ROAD
NEW CUMBERLAND, PA 17070
2233 GETTYSBURG ROAD
CAMP HILL, PA 17011
1035 MUMMA ROAD, STE. 101
WORMLEYSBURG, PA 17043
Name and address of every other person who has any record interest in the property and whose interest may be affected by the
sale.
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may
be affected by the sale:
Name Address (if address cannot be
reasonably ascertained, please indicate)
TENANT/OCCUPANT
Domestic Relations of
Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Internal Revenue Service Advisory
U.S. Department of Justice
U.S. Attorney for the Middle District of PA
COMMONWEALTH OF PENNSYLVANIA
BUREAU OF INDIVIDUAL TAX
INHERITANCE TAX DIVISION
DEPARTMENT OF PUBLIC WELFARE
TPL CASUALTY UNIT
ESTATE RECOVERY PROGRAM
1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
13 North Hanover Street
Carlisle, PA 17013
P.O. Box 2675
Harrisburg, PA 17105
1000 Liberty Avenue Room 704
Pittsburgh, PA 15222
Federal Building, P.O. Box 11754
228 Walnut Street
Harrisburg, PA 17108
6TH FLOOR, STRAWBERRY SQUARE
DEPT. 280601
HARRISBURG, PA 17128
P.O. BOX 8486
WILLOW OAK BUILDING
HARRISBURG, PA 17105-8486
•S.
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsificati Iauthorities.
Jan 2011 By: gk?
Attorney for Plaintiff
Phelan Hallinan & Schmieg, LLP
? Lawrence T. Phelan, Esq., Id. No. 32227
? Francis S. Hallinan, Esq., Id. No. 62695
? Daniel G. Schmieg, Esq., Id. No. 62205
? Michele M. Bradford, Esq., Id. No. 69849
? Judith T. Romano, Esq., Id. No. 58745
? Sheetal R. Shah-Jani, Esq., Id. No. 81760
? Jenine R. Davey, Esq., Id. No. 87077
? Lauren R. Tabas, Esq., Id. No. 93337
? Vivek Srivastava, Esq., Id. No. 202331
? Jay B. Jones, Esq., Id. No. 86657
? Peter J. Mulcahy, Esq., Id. No. 61791
? Andrew L. Spivack, Esq., Id. No. 84439
? Jaime McGuinness, Esq., Id. No. 90134
? Chrisovalante P. Fliakos, Esq., Id. No. 94620
? Joshua I. Goldman, Esq., Id. No. 205047
? Courtenay R. Dunn, Esq., Id. No. 206779
? Andrew C. Bramblett, Esq., Id. No. 208375
? Allison F. Wells, Esq., Id. No. 309519
CITIMORTGAGE, INC., SB/M TO PRINCIPAL
RESIDENTIAL MORTGAGE, INC.
: COURT OF COMMON PLEAS
: CIVIL DIVISION
Plaintiff :
: NO.: CIVIL-09-177
VS.
LUCAS J. PRINS
NICOLE L. PRINS
CUMBERLAND G.QU>a TY,--- .
Defendant(s)
2 i71
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: LUCAS J. PRINS
NICOLE L. PRINS
1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
sAA
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at 1914 CARLISLE ROAD, CAMP HILL, PA 17011-5911 is scheduled to be
sold at the Sheriff's Sale on 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover
Street, Carlisle, PA 17013 to enforce the court judgment of $98,621.04 obtained by CITIMORTGAGE, INC.,
SB/M TO PRINCIPAL RESIDENTIAL MORTGAGE, INC. (the mortgagee) against you. In the event the
sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling 215-563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this
has happened, you may call 215-563-7000.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if
the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff
gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of
distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his
office. This schedule will state who will be receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten (10) days after the filing of the proposed schedule.
7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately
after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
LEGAL DESCRIPTION
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Township of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania,
described according to Plan No. 7 of Highland Estates Development made by D. P.
Raffensperger, Registered Surveyor, dated April 1, 1952, and also according to a Plot Plan of
Highland Estates made for F. B. J. Branagan by D. P. Raffensperger, Registered Surveyor,
Lemoyne, PA, dated January 20, 1955 as follows, to wit:
BEGINNING at a point on the Northerly side of Carlisle Road at the distance of four hundred
thirty-five feet Westerly from the Westerly side of 19th Street (sixty feet wide); THENCE
extending Westwardly along the Northerly side of Carlisle Road, sixty feet to a point; THENCE
extending Northwardly along the line dividing Lot Nos. 30 and 31 on the above mentioned Plan,
and crossing a ten feet wide easement one hundred twenty feet to a point; THENCE extending
Eastwardly sixty feet to a point; THENCE extending Southwardly recrossing said ten feet wide
easement and along the line dividing Lot Nos. 31 and 32, one hundred twenty feet to the
Northerly side of Carlisle Road, the first mentioned Point and Place of BEGINNING.
BEING known as Lot No. 31, Block 'E' on the above mentioned Plan.
HAVING THEREON ERECTED a dwelling known and numbered as 1914 Carlisle Road, Camp
Hill, Pennsylvania.
UNDER AND SUBJECT to certain rights of way, conditions, and restrictions as now appear of
record.
TITLE TO SAID PREMISES IS VESTED IN Lucas J. Prins and Nicole L. Prins, h/w, by Deed
from Wayne D. Harris and Melissa K. Harris, h/w, dated 06/07/2002, recorded 06/27/2002 in
Book 252, Page 1921.
PREMISES BEING: 1914 CARLISLE ROAD, CAMP HILL, PA 17011-5911
PARCEL NO. 13-23-0547-348
a
PLAINTIFF
CITIMORTGAGE, INC., SB/M TO PRINCIPAL RESIDENTIAL
MORTGAGE, INC.
DEFENDANT
LUCAS JOHN PRINS A/K/A LUCAS J PRINS
NICOLE LYNN MORGAN A/K/A NIC LE LYNN PRINS A/K/A
NICOLE L. PRINS
PHS # 195104
SERVICE TEAM/ kxc
COURT NO.: CIVIL-09-177
C ?
C33 ?
(P T;
-4p
SERVE NICOLE LYNN MORGAN A/lUA NICOLE LYNN PRINS TYPE OF ACTION ?`.
A/K/A NICOLE L. PRINS AT: XX Notice of Sheriffs Sale
1914 CARLISLE ROAD SALE DATE: 06/01/2011 cl?,
CAMP HILL, PA 17011-5911 C=-
Served and made known to NICOLE
OD , o'clock -r. M., at 191
Defendant personally served.
- Adult family member with whom I
Relationship is
- Adult in charge of Defendant's resi
- Manager/Clerk of place of lodging
- Agent or person in charge of Defer
an officer of sa
AFFIDAVIT OF SERVICE (FHLMC)
CUMBERLAND COUNTY
SERVED
fendant on the $?"day of 6"W , 20 It , at
%tt, DA , in the manner described below:
reside(s).
nce who refused to give name or relationship.
which Defendant(s) reside(s).
ant's office or usual place of business.
Defendant's company.
-t C3
W
_ Other:
Description: Age cells Height ?K Weight AO Race 14) Sex F Other
I, ?gN?D /tee k. a competent adult, being duly sworn according to law, depose and state that I personally
handed a true and correct copy of the !Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned
case on the date and at the address indi ated above.
-
Sworn to and subscribed
before me this & !-day Y CLIRTY
L?. aY PUBLIC
of, 201 j
G A:?r fr JERSEY
Not By: MY CO =, v F%?1RES MARCH 7, 2013
NOT SERVED
On th a 20 at _ o'clock M., Defendant NOT FOUND because:
acant _ Does Not E ist _ Moved _ Does Not Reside (Not Vacant)
_ No Answer on at at
Service Refused
Other:
Sworn to and subscribed
before me this day
of By:
Notary: ATTORNEY FOR PLAINTIFF
Lawmnm T. Phelan, Esq., Id. No. 32227
Francis S. Hallman, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Michele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esq., Id. No. 58745
Shectal R Shah-Jani, Esq., Id. No. 81760
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., ld. No. 93337
Vivek Srivastava, Esq., Id. No. 202331
Jay B. Jones, Esq., Id. No. 86657
'., Peter J. Mulcahy, Esq., Id. No. 61791
Andrew L. Spivack, Esq., ld. No. 84439
Jaime McGuinness, Esq., Id. No. 90134
Chrisovalante P. Fliakos, Esq., Id. No. 94620
Joshua 1. Goldman, Esq., Id. No. 205047
Courtenay R. Dunn, Esq., Id. No. 206779
Andrew C. Brambiett, Esq., Id. No. 208375
Allison F. WeBS, Esq., Id. No. 309519
One Penn Center at Suburban Station
1617 John F. Kennedy Blvd., Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
t
-.- ,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
CITIMORTGAGE, INC., S/B/M TO PRINCIPAL Court of Common Pleas
RESIDENTIAL MORTGAGE, INC.
Plaintiff Civil Division
V. CUMBERLAND County
LUCAS J. PRINS No.: CIVIL-09-177
NICOLE L. PRINS
Defendants
RULE
AND NOW, this /3' day of ??2011, a Rule is entered upon the Defendants
to show cause why an Order should not be entered granting Plaintiffs Motion to Reassess
Damages.
Defendant(s) shall have twenty (20) days of the date of this Order to file a responsive pleading
to Plaintiffs Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file
a Motion to Make Rule Absolute and no hearing will be scheduled on this matter.
BY THE COURT
195104
Lawrence T. Phelan, Esq., Id. No. 32227
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Michele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esq., Id. No. 58745
Sheetal R. Shah-Jani, Esq., Id. No. 81760
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., Id. No. 93337
Vivek Srivastava, Esq., Id. No. 202331
Jay B. Jones, Esq., Id. No. 86657
Peter J. Mulcahy, Esq., Id. No. 61791
Andrew L. Spivack, Esq., Id. No. 84439
Chrisovalante P. Fliakos, Esq., Id. No. 94620
Joshua I. Goldman, Esq., Id. No. 205047
Courtenay R. Dunn, Esq., Id. No. 206779
Andrew C. Bramblett, Esq., Id. No. 208375
Allison F. Wells, Esq., Id. No. 309519
William E. Miller, Esq., Id. No. 308951
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
"TEL: (215) 563-7000
FAX: (215) 563-3459
LUCAS J. PRINS
NICOLE L. PRINS
1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
' Ali egm F klella, ,
P14+s
LUCAS J. PRINS
NICOLE L. PRINS
146 FOREST DR
CAMP HILL, PA 17011-8309
C,op1es u
195104
IijI I Ah P R 20 AM II' .?.x
UMBERLAND COUH 1 ,`,
J, ?
PENNSYLVANIA
Phelan Hallinan & Schmieg, LLP
By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Michele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esq., Id. No. 58745
Sheetal R. Shah-Jani, Esq., Id. No. 81760
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., Id. No. 93337
Vivek Srivastava, Esq., Id. No. 202331
Jay B. Jones, Esq., Id. No. 86657
Peter J. Mulcahy, Esq., Id. No. 61791
Andrew L. Spivack, Esq., Id. No. 84439
Chrisovalante P. Fliakos, Esq., Id. No. 94620
Joshua I. Goldman, Esq., Id. No. 205047
Courtenay R. Dunn, Esq., Id. No. 206779
Andrew C. Bramblett, Esq., Id. No. 208375
Allison F. Wells, Esq., Id. No. 309519
William E. Miller, Esq., Id. No. 308951
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
CITIMORTGAGE, INC., SB/M TO PRINCIPAL Court of Common Pleas
RESIDENTIAL MORTGAGE, INC.
Plaintiff Civil Division
v CUMBERLAND County
LUCAS J. PRINS No.: CIVIL-09-177
NICOLE L. PRINS
Defendants
CERTIFICATION OF SERVICE
195104
I hereby certify that a true and correct copy of our Motion to Reassess Damages noting a
Rule Return date of May 3, 2011 was sent to the following individuals on the date indicated
below.
LUCAS J. PRINS
NICOLE L. PRINS
1914 CARLISLE ROAD
CAMP HILL, PA 17011-5911
DATE:
LUCAS J. PRINS
NICOLE L. PRINS
146 FOREST DR
CAMP HILL, PA 17011-8309
Phelan Hallinan & Schmieg, LLP
By:
Lj Lawrence T. Ptelan sq., Id. No. 32227
? Francis S. Hallman, Esq., Id. No. 62695
? Daniel G. Schmieg, Esq., Id. No. 62205
? Michele M. Bradford, Esq., Id. No. 69849
? J dith T. Romano, Esq., Id. No. 58745
Sheetal R. Shah-Jani, Esq., Id. No. 81760
? Jenine R. Davey, Esq., Id. No. 87077
? Lauren R. Tabas, Esq., Id. No. 93337
? Vivek Srivastava, Esq., Id. No. 202331
? Jay B. Jones, Esq., Id. No. 86657
? Peter J. Mulcahy, Esq., Id. No. 61791
? Andrew L. Spivack, Esq., Id. No. 84439
? Chrisovalante P. Fliakos, Esq., Id. No. 94620
? Joshua I. Goldman, Esq., Id. No. 205047
? Courtenay R. Dunn, Esq., Id. No. 206779
? Andrew C. Bramblett, Esq., Id. No. 208375
? Allison F. Wells, Esq., Id. No. 309519
? William E. Miller, Esq., Id. No. 308951
ATTORNEY FOR PLAINTIFF
195104
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CITIMORTGAGE, INC., SB/M TO PRINCIPAL
RESIDENTIAL MORTGAGE, INC.
Plaintiff,
v
LUCAS J. PRINS A/K/A LUCAS JOHN PRINS
NICOLE L. PRINS F/K/A NICOLE LYNN
MORGAN A/K/A NICOLE LYNN PRINS
Defendant(s)
CUMBERLAND COUNTY
COURT OF COMMON PLKAS
CIVIL DIVISION
r-
No.: CIVIL-09-177
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
PHILADELPHIA COUNTY ) SS:
rn F
am
-?-t o
-n
r-3-n
In C'-i
t :1
As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders
and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of
the persons or parties named, at that address, set forth on the Affidavit and as amended if
applicable. A copy of the Certificate of Mailing (F 3817) and/or Certified Mail Return
Receipt stamped by the U.S. Postal Service is atta he hereto Exhibit "A?'?
Date: ell /
? yAJbhfncE fi Phelan, Esq.,!/. No. 32227
F ancis S. Hallinan, Esq., Td. No. 62695
aniel G. Schmieg, Esq., Id. No. 62205
ichele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esq., Id. No. 58745
E]Aeetal R. Shah-Jani, Esq., Id. No. 81760
Jenine R. Davey, Esq., Id. No. 87077
? Lauren R. Tabas, Esq., Id. No. 93337
? Vivek Srivastava, Esq., Id. No. 202331
? Jay B. Jones, Esq., Id. No. 86657
? Peter J. Mulcahy, Esq., Id. No. 61791
? Andrew L. Spivack, Esq., Id. No. 84439
? Chrisovalante P. Fliakos, Esq., Id. No. 94620
? Joshua I. Goldman, Esq., Id. No. 205047
? Courtenay R. Dunn, Esq., Id. No. 206779
? Andrew C. Bramblett, Esq., Id. No. 208375
? Allison F. Wells, Esq., Id. No. 309519
? William E. Miller, Esq., Id. No. 308951
Attorney for Plaintiff
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
PHS 4 195104
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CITIMORTGAGE, INC., SB/M TO PRINCIPAL
RESIDENTIAL MORTGAGE, INC.
Plaintiff
VS.
LUCAS J. PRINS
NICOLE L. PRINS
Defendants
Court of Common Pleas
Civil Division -_
CUMBERLAND Cy
No.: CIVIL-09-177
10
ORDER 71--
AND NOW, this 1G' day of m,97 , 2011, upon consideration of Plaintiff's`
Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered
upon Defendants shall be and is hereby made absolute and Plaintiff's Motion to Reassess
--A
y
-XI
Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED
to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows:
Principal Balance
Interest Through June 1, 2011
Per Diem $15.35
Late Charges
Legal fees
Cost of Suit and Title
Sheriffs Sale Costs
Property Inspections/ Property Preservation
Suspense/Misc. Credits
Escrow Deficit
TOTAL
a?
Plus interest from June 1, 2011 through the date of sale at six percent per annum.
Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above
figure.
Joshua-z. C3ddman,
? LVeas J . Prins
Nicol-, L. Pri nS
$86,201.63
$11,673.25
$150.25
$2,000.00
$1,301.50
$869.77
$262.50
($571.72)
$2,009.67
$103,896.85
BzE COURT:
e
e
J.
195104
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson . ; 4
Sheriff -Jody S Smith
Chief Deputy 4 ! 'T Richard W Stewart i;tlrlcsBL ?? ? it 2-1 zF
Solicitor
PEMSYZO!n,Nlr;
CITIMORTGAGE, Inc.,
vs.
Nicole I Prins (et al.)
Case Number
2009-177
SHERIFF'S RETURN OF SERVICE
03/10/2011 06:54 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Nicole I
Prins at 1914 Carlisle Road, Lower Allen, Camp Hill, PA 17011, Cumberland County.
03/10/2011 06:54 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be Nicole I Prins (F) (Spouse),
who accepted as "Adult Person in Charge" for Lucas J Prins at 1914 Carlisle Road, Lower Allen, Camp
Hill, PA 17011, Cumberland County.
03/30/2011 Ronald Hoover, Deputy Sheriff, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 1914 Carlisle Road, Camp Hill, PA, Cumberland County.
05/31/2011 As directed by Daniel G Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/3/2011
07/26/2011 As directed by Daniel G Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/5/2011
09/26/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $699.54
September 29, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
.Do
(c GourtySuite Seert Teleo;ott. ir.;;.
SHORT DESCRIPTION
By virtue of a Writ of Execution NO. CIVIL-09-177
CITIMORTGAGE, INC., S/B/M TO PRINCIPAL RESIDENTIAL MORTGAGE,
INC.
vs.
LUCAS J. PRINS
NICOLE L. PRINS
owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland
County, Pennsylvania, being
(Municipality)
1914 CARLISLE ROAD CAMP HILL PA 17011-5911
Parcel No. 13-23-0547-348
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
JUDGMENT AMOUNT: $98,621.04
Phelan Hallinan & Schmieg, LLP
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
215-563-7000
CUMBERLAND LAW JOURNAL
Writ No. 2009-177 Civil
CITIMORTGAGE, Inc.
VS.
Nicole I. Prins
Lucas J. Prins
Atty.: Daniel G. Schmieg
By virtue of a Writ of Execu-
tion NO. CIVIL-09-177, CITIMORT-
GAGE, INC., S/B/M TO PRINCIPAL
RESIDENTIAL MORTGAGE, INC. vs.
LUCAS J. PRINS, NICOLE L. PRINS,
owner(s) of property situate in the
TOWNSHIP OF LOWER ALLEN,
Cumberland County, Pennsylvania,
being 1914 CARLISLE ROAD, CAMP
HILL, PA 17011-5911.
Parcel No. 13-23-0547-348.
Improvements thereon: RESIDEN-
TIAL DWELLING.
JUDGMENT AMOUNT: $98,621-
.04.
63
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
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:
April 22, April 29, and May 6, 2011
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.
:::?? L-- --
Lisa Marie Coyne, di=tor
SWORN TO AND SUBSCRIBED before me this
=dof 201 1
ary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
It The Patriot-News Co.
2020 Technology Pkwy
Suite.300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
14( Patriot-News
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
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant 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 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly editions which appeared on the date(s) indicated below. That neither she 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 she 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 ran on the date(s) shown below:
04/22111
04129/11
05/06/11
LBy 'LrbX aft W* d E> Nowe M.
R
1; is 2 f M y, 2011 A. D.
CIVRAPIVI Sworn to apd scribed befor a
%V
CnVOOR"Aft W, "#A
MOMAGE, INC.
vs. Notary Public
LUCAS J.
NICOLE L MM
mvom(s) of pop* !n 1be COMMONWEALTH OF
?, ? , ? ? sYLvar?ra
Cm*, Powft ia,twt Sherrie L ota# r?
I ? Publk
191(M4CCARLMEROAR,CA1iW1#111. ( Lower TwP.. 0auphln County
PA 17011-5911 Be6 Nov. 260 2011
Parcel No. 13-n-0547-348 Member, ?SiOn
` Penn sYlvanla Assocletion Of Notaries
(Aaup or ~ ad*"P)
?9ly6Q1#