HomeMy WebLinkAbout09-1464I%
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938.6429
MEMBERS 1 ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
JACK V. COBLE, JR.
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
. NO.: O} - I4104 eNt'l Term
: CIVIL ACTION -LAW
: MORTGAGE FORECLOSURE
NOTICE TO DEFEND AND CLAIM RIGHTS
THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE
ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY
INFORMATION OBTAINED FROM YOU WELL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20) days after this
Complaint and Notice are served by entering a written appearance personally or by
attorney and filing in writing your defenses or objections to the claims set forth against
you. You are warned that if you fail to do so, the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money
claimed in the Complaint or for any other claims or relief requested by the Plaintiff. You
may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
NOT I
Le ham demandado a usted en la corte. Si usted guiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dies de plazo al
partir de la fecha de la demanda y la notification. Usted debe presenter una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensais o
sus objections a W demandas en contra suya.
Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar
una Orden contra usted sin previo aviso o notification y por cualquier queja o alivio que
es pedido en la peticion de demands. USTED PUEDE PERDER DINERO O OTROS
DERECHOS B4PORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE, SI
USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS
OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C.
SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN
WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S)
WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE
ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30)
DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND
DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF
DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY
(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING
YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT
YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT
TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THE THIRTY (30) DAYS AFTER YOU
HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF
THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR
WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT
OF THIS COMPLAINT, THE LAW REQUESTS US TO CEASE OUR EFFORTS
(THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE
MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS
IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS
NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A
LIEN ON REAL ESTATE.
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070
MEMBERS 1 ST FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
-?
Vs. NO.: (29- /y6"
JACK V. COBLE, JR.
DEFENDANT : CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
COMPLAINT
AND NOW, comes Members I " Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
1
1. Plaintiff, Members I" Federal Credit Union ("Members 1 sr) is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
2. Jack V. Coble, Jr., ("Defendant"), is an adult individual having a last known
address of 208 4th Street, Summerdale, PA 17093.
3. On or about June 22, 2006, Defendant borrowed from and agreed to repay to
Members I" THIRTY THOUSAND AND 00/100 ($30,000.00) dollars (the
"Loan"). The Loan is evidenced by a Closed-End Note, Disclosure, Loan and
Security Agreement dated June 22, 2006 (the "Note") executed and delivered
to Members 1St by Defendant. A copy of the Note is attached hereto as Exhibit
"A" and made part hereof.
4. As security for the Loan, Defendant executed and delivered to Members 1 St a
mortgage ("Mortgage") also dated June 22, 2006, on all that certain real estate
and improvements erected thereon situate in East Pennsboro Township,
Cumberland County, Pennsylvania, known and numbered as 208 4tb Street,
Summerdale, PA 17093 (the "Property"). At all times relevant hereto,
Defendant has been and continues to be the record and sole owner of the
Property. A description of the Property is attached hereto as Exhibit "B" and
made part hereof.
5. On or about July 14, 2006, the Mortgage was recorded in the Cumberland
County Recorder of Deeds Office at Mortgage Book 1958, Page 2778. A true
and correct copy of the Mortgage is attached hereto as Exhibit "C" and made
part hereof.
2
6. The Note and the Mortgage have never been assigned by Members 15t and
remain held by it as a valid and subsisting obligation of Defendant.
7. Pursuant to the terms and conditions of the Note, Defendant agreed to pay to
Members 1st monthly installments of principal and interest in the amount of at
least $308.26 each, which amount was subsequently adjusted to $307.87 each,
beginning on July 16, 2006 and continuing on or before the 16th of each month
thereafter.
8. As a result of Defendant's failure to make the payments due under the Note
for October through December 2008, Members 1st gave written notice of its
intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41
P. S. section 101, et. sue., and in particular section 403 thereof, and of
Defendant's rights in accordance with the Homeowners' Emergency
Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S.
Section 1680.401(c), et. M by letter dated December 19, 2008, addressed to
Defendant via certified mail, return receipt requested. A copy of the said
notice is attached hereto as Exhibit "D" and made part hereof.
9. A copy of the electronic tracking confirmation evidencing the mailing of said
Notices is attached hereto as Exhibit "E" and made part hereof.
10. Simultaneously, Members 1st forwarded to Defendant the same Notices as set
forth in paragraph 8 above addressed to Defendant by United States mail, first
class, postage prepaid, bearing the return address of Members 1st. The Notices
forwarded to Defendant in said manner have not been returned to the offices
of Members 1st as undeliverable or otherwise.
3
11
12.
13
Although Defendant made a partial payment since the date of the notice
attached hereto as Exhibit "D" and made part hereof, at no time relevant
hereto did Defendant bring the Mortgage and Note current and, as of the date
hereof, Defendant is in default of Defendant's obligations under the Note as a
result of Defendant's failure to make the monthly payments due to Plaintiff as
set forth in the Note in the amount of $307.87 each for the months of January
and February, 2009, as set forth in the Note.
As of March 2, 2009, Defendant is indebted to Members I" in the amount of
THIRTY THOUSAND NINE HUNDRED THIRTY-EIGHT and 08/100
($30,938.08) dollars itemized as follows:
a. Outstanding principal $28,270.18
b. Interest to March 2, 2009 167.90
c. Late fees 0.00
d. Attorney fees 2,500.00
e. Total due to Members l" as of 3/2/2009 $30,938.08
The above attorney's fees are estimated through sheriff sale and are in
accordance with Defendant's agreements as set forth in the underlying
Mortgage and Note. Defendant will be responsible for actual reasonable legal
fees incurred by Members I" in this matter subject to any limitation set forth
in the Note.
Defendant also agreed under the terms and conditions of the Mortgage that in
the event of default there under Defendant would pay, in addition to the
4
amounts set forth in paragraph 12 above, costs incurred by Members 1 ' as a
result of the institution of these legal proceedings.
14. The obligation owed to Members I" continues to accrue interest at the rate of
$7.1566 per day, through the date of payment and continues to accrue late
charges and attorney's fees.
15. As set forth above, Members 1' has made demand upon Defendant to cure
the default under the Mortgage and the Note. However, as of the date hereof,
Defendant continues to fail and refuse to cure the default.
WHEREFORE, Plaintiff, Members lst Federal Credit Union, demands judgment
against Jack V. Coble, Jr. in the amount of THIRTY THOUSAND NINE HUNDRED
THIRTY-EIGHT and 08/100 ($30,938.08) DOLLARS plus interest at the rate of $7.1566
per day, through the date of judgment entered on this complaint and at the legal rate
thereafter until the date of payment, additional legal fees and costs of suit and for
foreclosure and sale of the mortgaged property.
Date: ?q p 7
Respectfully submitted,
Karl M. Led&ohm, Esq.
Supreme Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
5
1St CLO3ED•EN0 NOTE, DISCLOSURE,
50001.Ctrae Drive, P.O. Bolt 40 eORllOwIT'i EANO r100Rles
Meehanfcsburg, PA 17065 JACK V COBLE. JR
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AMOUNT PAID ON YOUR ACCOUNTS 23,798.71 S To $ TO
PREPAID FINANCE CHARGE S 0.00 It To A1te•ttdu M $0.00 TO F«.
$ To Awaaa?dw.
W1KE INFORMATION
MODEL I.D. NUMBER AL E
OTHER (Describe): 206 4TH STREET SUMMERDALE PA 17093
You PkdBe imm AMOUNT ACCOUNTNUMBER
and/or DepaeBa of $ SMOG ACCOUNT NUMBER
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mare
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R TUR DATE C04AAKER ' HER 0 R ••COSSIGNER DATE
(SEAL),,' -,p (SEAL)
O ER ? -OTHER OWNER ? -CO-SIGNER GATE ? C04AAKF-R []'OTHER OWNER ? -CO-SIGNER DATE
(SEAL)
(SEAL)
? C04 WER ? 'OTHER OWNER ? ''COSIGNER GATE ? CO-mwelt ? -OTHER OWNER 113 -COSIGNER
X (SEAL) X (SEALDATE
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CREOIT INSURANCE APPLIED FOR: NOTE: ONLY ONE APPLICANT MAY APPLY FOR DIBA81UPr COVERAGE.
? Yes a No Single Credit Life Total Premium ? X Yes
? No Credit Disabllly ? Total Premium
? Yes ? No Joint Credit Life
kwicar which applimirl ? Appel Co•App11nm $0.00 Indiedr wHd1
apprcantp): O AppavM ? Co-MPSC.rs 0.00
Y,7
F. 43799 R.r. 1101
Ilan., Mw. AN right n.med.
Exhibit "A"
JACK V COSLE, JR ^"'"eC1 ACabuHr rAme R DATE OF Lam
1361x2 26686$W 08122/2066
=%E AGREEk?H76,)THE WORDS'CREDIT LHOW MEANS MEMBERS IST FEDERAL CREDIT UNION. THE WORDS'YCU,• 'YOUR' AND YpyRg-MEAN THOBE
LOAN AGREEMENT
to ply, at
you
you ra lonber receive dIS PIa/OrM awre w aw ass Aglearllent ewn N
Hale Tac rSp y: M 6u ruin a Yppa?M, you agree to pay a we charge
P an paps 1 of We
aoclmsni,
IaslNSeee: If you obtain • loan scoured M mbar vshids or
l+nbnde S s0bNalet TaM1m?pw? iinsurenoe w?dpm"WIS the CretW
ffLot at h" 10 the cradt union. a psg "Mud
WW bollision
No
Milan * a LOU weds r oft rendonam
1
snI nne?rnYg the
aabe and tltretx the spent to send die credit triorl a copy
'af Ih °"
Oe1KOr ReepoasbllMv: You prorrNas b notlty orodR txlbn d any dwlpe In
rrsma, aefdn&es aa cuff amplo oi.d a YOU ppnlea not to apply for a loan tl
1Krim IBUS Itnl you will be unable to repay
toy amt7bli0aadbeAnl ad abeord . to the l it extension. YOU ptaniae
a Y any nrr klbrnratton which relates to your abANy to
y Yoor Ou mp Irmo W t rabwA faln or kroburMe
in
CmallonorWiftly
CrOM slaridklp, or swill :'ably. regarding your CradltvrorUlklnw.
Statutory LNn: K you are in delsWt lWeral_tew Ives the aeAl union the
tlpM b eDONbelenoe q1 sheroe errdbr elvlbende youM(s
the Ikrie y des b ae6fy Ns ban. Once you re lnIndefaun, ther eobbuZt thle at
union may axrdN npm w81ad further nlfa b you
In Enforcement, Crew
bh 01"
urM oft aproemsMiwd6wd ft.. ro any of the aedll enfo der =
Irregular PaymrRS: The UMN union rnsyina? . 4o Qt.=lal
late My nnp d tBal
payrrleres, a gquah
wor%Mo
ft agreement as a co-er you alp fbutgre to unkio t 61b
You. 0 Union dOes riot hem
d union notl?y
has 0. reN ore ? sOW. ecu ry witavdit hout notlM? creed ing leans of
reap onaibi ity on No agreement. ep or releasing you from
SECURITY AGREEMENT
1. unl0nr pypp N Owl a?l? ? arm i??YOa
?i??ea7 Oe
aaeuoC a e to
?r?Ci1wA I?wn IMnY
anMnX
f lutep NrO6rYa?Ya ton w tar my
a1..i ?• tam am a
ra9rney! rapr? an P+ or r1m.; e?iiee
y?e?h1orW=-Om
?aaaIWM M1a 0oWrY UIMat YOY kava
2. abrar
Mw"j o odor
a. Y?ea? { rlaaany
a. `oovAl!aaalpln papV
die
o Tot a 110,
but
peas bi bath 9e 9arar
to
weu Ow rimve of Canon
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Y ?sir91N b you fndINNVMyaMe IS WYnrlYaOp/ Nor l?yp I.M. an L
a• udon Isd M jka hu
taraab e?xaln ayyar p
p M M°a o Nn?mraiaMan?Pa"Y
6100 2ps
Can4/epal Pledge o/6han.: V" pledge all yew aharM led Aaapalb in dw
credl rerbq kkkrdlad W Wn add ana, as aatwdy pr dW ban, In ew you
dapuR, Ne Cradlr rnllan raty ypy peas shares and Nyosks b dN pymanl
of N sum due M on tbee of fa14161n l daq coop of eolpoooo arm
naaanaab tlpawyrs boa. that are credit union may Incur, up to 211% of pa
u%MM nd M*-L Nor %m or daht b tmpnss • Nen en atone and
dapoalp HI apply tb ley of your Wnres which ewy be held In alr "Individual
RalkarserN ActourW or'Keaph Pbm-
Yrwdwe u heMketl b pwreniM ttlb dW Thbk carefully before you db. 11 the ixKrower doesn't PaY Ya her b. end t11a1 you want to accept Ws responNbiny. WY Me dabC You W haw to. Be aura you can rbnd b
Yet have to pay W to the hNl arnount of the tlabl N etc borrower does not pay. You racy aim how b pay late IM Or Collection costa. which V aeaM Wa
The aadpr can aNted this dW Rom ypu without Ent 0*10 b 001W from the borrower. The meow am use pre aarrn odNC6on melho0a app you d1M
OW be used you ks aal?7yeeiInsl Ihs borrowr, such M suite'M You.bbIpr rrWo aur
record This rlblicp 11 nd , slc. N this debt In ever In d~, that fad may becarrp a part of"yaeCredit
. d1s conlrarY that makbt
F. •3769 1102
APM S"W-. lnc, 224.1079
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vrY,'"ear7r aNro1ewarwrliy°"rrs.b heMrNn Nmaa'o?'rs
rs
. aIWdM,efaaa1" rot only bird. you. tM Yaw aa.paon, aftilnl aloM
ALL THOSE CERTAIN three USCM, pieces or parcels of land situate in East
Pennsboro Township, Cumberland County, Pennsylvania, bounded and desa bed as
follows:
BEGINNING at the southeast comer of Fourth and Wayne Streets, on the
heneinaft mentioned Plan; dMce eastwardly along the southern line of Wayne Street, 160
feet to a 16 foot wide alley; thence southwardly along the western line of said alley 41 Feet,
more or IM to the nordmst corner of Lot No. 101; thence westwardly along the narthem
line of Lot No. 101, a distance of 160 feet to Fourth Street; thence northwardly alarhg the
eastern line of Fourth Street, a distance of 41 Poet, more or less, to a point, the plaice of
BEGINNING.
BEING Lot No. 102, Section "A", in the Plan of Summerdale, as recorded in the
Ofik a of the Recorder of Deeds in and lbr said County of Cumberland in Plan gook 1, Page
44, and being improved with a two4tory kame dwelling, formerly known as 119 Fourth
Street, now known as 208 Fourth Street, Summerdaie, Pennsylvania.
MAaM
BOUNDED on the west by Fourth Street; on the North by Lot No. 102, on the But
by an agcy and on the South by Lot No. 100, having a frontage of 30 fleet on Fourth Sheet
and a depth of 160 feet.
BEING Lot No. 101, Block "A" in the Plan of Sun merdale, as recorded in the
Ollie of the Recorder of Deeds aforesaid in Plan Book 1, Page 44.
BACU.
BOUNDED on the West by Fourth Street, on the North by Lot No. 101, on the Last
by an a ley and on the South by Lot No. 99, having a frontage of 30 feet on Fourth Street
and a depth of 160 fret.
BEINC3 Lot NO- 100, Block "A" in the Plan of Sumer( le as recorded in the Office
of the Recorder of Deeds aforesaid in Plan Book 1, Page 44.
Being the same premises which Louree B. Blaine by her deed doted April 14, 2005 and
recorded in the Cumberland County Recorder of Deeds Office at Deed Book 268, Page
2170, granted and conveyed onto Jack V. Coble, Jr.
Exhibit "B"
?SII
Prepared By: Members 1 st FCU
5000 Louise Drive
Mechanicsburg, PA 17055
When recorded mail to:
Return To: FIRST AMERICAN TITLE INSURANCE
LENDERSADVANTAGE
1228 EUCLID AVENUE, SUITE 400
CLEVELAND, OHIO 44115
ATTN. NATIONAL RECORDINGS
9F? P. 2006 JUL 19 HM 10 00
Po f opi 4f MORTGAGE
Made 06/22/2006
a C t 9 L Between
JACK V COBLE JR
(hereinafter ca 1 "Mortgagor")
And
MEMBERS 1ST FEDERAL CREDIT UNION (hereinafter called "Mortgagee")
Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter
called the "Note") of even date herewith, payable to the order of Mortgagee in the principal sum of
$ 30,000.00 lawful money of the United States of America, and has provided therein
for payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with
interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and
containing certain other terms and conditions, all of which are specifically incorporated herein by
reference;
Now, Therefore, Mortgagor, in consideration of said debt or principal sum and as security for the
payment of the same and interest as aforesaid, together with all other sums payable hereunder or under
the terms of the Note, does grant and convey unto Mortgagee,
All that certain property of the Mortgagor located in EAST PENNSBORO
TOWNSHIP , Cumberland County, Pennsylvania
SEE EXHIBIT "A"
which currently has the address of 208 4TH STREET
SUMME [Street]
RDALE Pennsylvania
[City]
Acct No 246855-04
AppID 158192
17093
[Zip Code]
Page 10f4
SK 19 5 8 FG 2 7 7 8 Exhibit "C"
Together with the buildings and improvements erected thereon, the appurtenances thereunto
belonging and the reversions, remainders, rents, issues and profits thereof.
To Have and To Hold the same unto Mortgagee, its successors and assigns, forever.
Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum,
including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder
and under the terms of the Note, together with interest thereon, and shall keep and perform each of the
other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby
granted and conveyed shall become void.
This Mortgage is executed and delivered subject to the following covenants, conditions and
agreements:
(1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any
future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and
intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall
be added to the principal debt.
(2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and
discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water
rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt
secured hereby, (b) pay all ground rents reserved from the mortgaged premises and pay and discharge all
mechanics' liens which may be filed against said premises and which shall or might have priority in lien
or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax,
including interest and penalties thereon, if any, now or hereafter becoming payable on the Note
evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums
and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time
require upon the buildings and improvements now or hereafter erected upon the mortgaged premises,
with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear,
and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing
charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge
the foregoing charges be paid in installments to Mortgagee.
(3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and
substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the
mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair
of the buildings and improvements erected thereon.
Acct No 246855-04 AppID 158192 Page 2 of 4
BK1958PG2779"
(4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fails to
maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the
principal debt secured hereby, and collect the same as a part of said principal debt.
(5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the
mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this
Mortgage.
(6) In case default be made for the space of thirty (30) days in the payment of any installment of
principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the
other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum, additional
loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this
Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice
become immediately due and payable, and foreclosure proceedings may be brought forthwith on this
Mortgage and prosecuted to judgment, execution and sale for the collection of the same, together with
costs of suit and an attorney's commission for collection of five percent (5%) of the total indebtedness or
$200, whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said
proceedings, waives stay of execution, the right of inquisition and extension of time of payment, agrees
to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions
from levy and sale of any property that now is or hereafter may be exempted by law.
(7) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall
terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage.
Mortgagor shall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing this
Mortgage, but only if the fee is paid to a third party for services rendered and the charging of the fee is
permitted under Applicable Law.
The covenants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall
inure to, the respective parties hereto and their respective heirs, executors, administrators, successors and
assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each
shall be joint and several.
Acct No 246855-04 AppID 158192
Page 3 of 4
BKI958PG278Q
Witness the due execution hereof the day and year first above written.
JACK V OBLE A
Commonwealth of Pennsylvania
County of Cumberland ss:
Me l i s is a 2W d aY e ay of June 9 2006 , before me,
the undersigned officer, personally appeared
Jack V- Co e Jr satisfactorily proven to
me to be the person(s) whose name(s) is/are subscribed to the within Mortgage, and acknowledged that
he/she executed the same for the purposes therein contained.
In Witness Whereof, I hereunto set my hand and official seal.
My commission expires:
/ COMMON ALTH OF PENNSYLVANIA
Notarial Seal
Melissa Moore, Notary Public
East Pennsboro Twp., Cumberland County
My Commission Expires Aug. 12, 2009
Member, Pennsylvania Association of Notaries
Certificate of Reaiden of Mortgagg?
Members 1ST Federal Credit Union, Mortgagee within named, hereby certifies that its residence
is 5000 Louise Drive, Mechanicsburg, PA 17055.
By
Acct No 246855-04 AppID 158192 Page 4 of 4
8K 1 958PG278 I
EXHIBIT "A"
LEGAL DESCRIPTION
A PARCEL OF LAND SITUATED IN THE STATE OF PENNSYLVANIA, COUNTY OF
CUMBERLAND, WITH A STREET LOCATION ADDRESS OF 208 4TH ST;
SUM4ERDALE, PA 17093 CURRENTLY OWNED BY JACK V. COBLE JR HAVING A
TAX IDENTIFICATION NUMBER OF 09122994049 AND FURTHER DESCRIBED AS
LOTS 100 THRU 103 BLK A PB 1 P RESIDENTIAL BUILDING.
09122994049
208 4TH ST; SUM4ERDALE, PA 17093
158192 IIIJIMINMIUCOBLE JR
9746911
29023280/f/or FIRST AMERICAN LENDERS ADVANTAGE
MORTGAGE
1111111 IN I IIIINI IlNilllllll IIII h III I III I III
I Certify this to be recorded
In Cumberland County PA.
t?,?
,pit
R_(-s.-,order of Deed
BK 1958PG2782
Date: December 19, 2008
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE*
This is an official notice that the mortgage on your home is in default, and the
lender intends to foreclose. Specific information about the nature of the default is
provided in the attached pages
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be
able to help to save your home This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS nF THP neTC nr TulO
Take this Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice If you have any
questions, you may call the Pennsylvania Housing Finance A envy toll free at
1-800-342-2397.(Persons with impaired hearing can call (717) 780-1869).
Exhibit "D"
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help
explain it. You may also want to contact an attorney in your area. The local bar
association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA
(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.
PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
JACK V COBLE JR
208 4TH STREET
SUMMERDALE, PA 17093
246855 - 04
Members 1st Federal Credit Union
Members 19t Federal Credit Union
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU
MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN
CAUSED BY
CIRCUMSTANCES BEYOND
YOUR CONTROL,
IF YOU HAVE A REASONABLE
PROSPECT OF BEING ABLE
TO PAY YOUR MORTGAGE
PAYMENTS, AND
i 9
IF YOU MEET OTHER
ELIGIBILITY REQUIREMENTS
ESTABLISHED BY THE
PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a
temporary stay of foreclosure on your mortgage for thirty (30) days from the date
of this Notice. During that time you must arrange and attend a "face-to-face"
meeting with one of the consumer credit counseling agencies listed at the end of
this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS IF
YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU
MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE
CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW
TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the
consumer credit counseling agency listed at the end of this notice, the lender
may NOT take action against you for thirty (30) days after the date of this
meeting. The names, addresses and telephone numbers of designated
consumer credit counseling agencies for the county in which the property is
located are set forth at the end of this Notice. It is only necessary to schedule
one face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for specific
information about the nature of your default.) If you have tried and are unable to
resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To
do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your
face-to-face meeting.
1 1
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN
THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE
WILL BE DENIED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are
very limited. They will be disbursed by the Agency under the eligibility criteria
established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A
PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS
FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage
Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to
date .
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender
on your property located at: 208 4TH STREET, SUMMERDALE, PA 17093
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MORTGAGE PAYMENTS for the following monthly installments and the
following amounts are now past due: $307.87 for 10-16-08, $307.87 for 11-16-08 and $307.87 for 12-16-
08.
Other charges (explain/itemize):
TOTAL AMOUNT PAST DUE: $923.61
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
a licable):
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30)
DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER, WHICH IS $923.61, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check certified
check or money order made payable and sent to:
Members lot Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA
17055, Attention: Dave Thomas
You can cure any other default by taking the following action within THIRTY (30)
DAYS of the date of this letter: (Do not use if not applicable )
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within
THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its
rights to accelerate the mortgage debt. This means that the entire outstanding
balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in Monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends
to instruct its attorneys to start legal action to foreclose upon your mortgaged
property, 208 4TH STREET, SUMMERDALE, PA 17093
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be
sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to
its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However, if legal
a
proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount you owe the lender, which may also
include other reasonable costs. If you cure the default within the THIRTY (30)
DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have
not cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default and prevent
the sale at any time up to one hour before the Sheriffs Sale. You may do so by
paying the total amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure sale and
any other costs connected with the Sheriffs Sale as specified in writing by the
lender and by performing any other requirements under the mortgage. Curing
your default in the manner set forth in this notice will restore your mortgage to the
same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest
date that such a Sheriffs Sale of the mortgaged property could be held would be
approximately Three(3) months from the date of this Notice. A notice of the
actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You may
find out at any time exactly what the required payment or action will be by
contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Members 18t Federal Credit Union
Address: 5000 Louise Drive, Mechanicsburg, PA 17055
Phone Number: (717) 795-5133 or (800) 283-2328 Ext 5133
Fax Number: (717) 795-5207
Contact Person: Dave Thomas
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end
your ownership of the mortgaged property and your right to occupy it. If you
continue to live in the property after the Sheriffs Sale, a lawsuit to remove you
and your furnishings and other belongings could be started by the lender at any
time.
ASSUMPTION OF MORTGAGE -- You may not sell or transfer your home to a
buyer or transferee who will assume the mortgage debt, provided that all the
outstanding payments, charges and attorney's fees and costs are paid prior to or
at the sale and that the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF
THE MORTGAGE DEBT OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME
POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU
CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE
TIMES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY
FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY
HAVE TO SUCH ACTION BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL
BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
Certified Mail # 9171082133393597229125
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated: 10/15/2007 10:03:08 AM
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
. •Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565
Relief Act and Urban Development
Notice Disclosure (exp 4/30/2007)
Office of Housing
Legal Rights and Protections Under the SCRA
Servicemembers on "active duty" or "active service," or a dependent of such a
servicemember may be entitled to certain legal protections and debt relief pursuant to the
Servicemembers Civil Relief Act (50 USC App. §§ 501-596) (SCRA).
Who May Be Entitled to Legal Protections Under the SCRA?
• Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard,
and active service National Guard;
• Active service members of the commissioned corps of the National Oceanic and
Atmospheric Administration;
• Active service members of the commissioned corps of the Public Health Service;
• United States citizens serving with the armed forces of a nation with which the United
States is allied in the prosecution of a war or military action; and
• Their spouses.
What Legal Protections Are Service embers Entitled To Under the SCRA?
The SCRA states that a debt incurred by a servicemember, or servicemember and spouse
jointly, prior to entering military service shall not bear interest at a rate above 6 percent
during the period of military service.
The SCRA states that in a legal action to enforce a debt against real estate that is filed
during, or within 90 days after the servicemember's military service, a court may stop the
proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or
seizure of real estate shall not be valid if it occurs during, or within 90 days after the
servicemember's military service unless the creditor has obtained a court order approving
the sale, foreclosure, or seizure of the real estate.
The SCRA contains many other protections besides those applicable to home loans.
How Does A Servicemember or De ndent Request Relief Under the SCRA?
• In order to request relief under the SCRA, a servicemember or spouse, or both, must
provide a written request to the lender, together with a copy of servicemember's military
orders. The Lender providing this Notice is Members I" Federal Credit Union, ATTN:
Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The
phone number is toll free (800) 283-2328.
How Does a Servicemember or Dependent Obtain Information About the SCRA?
• The U. S. Department of Defense's information resource is "Military OneSource".
Website: http://www.milit4aonesource.com
The toll free telephone number for Military OneSource are:
o From the United States: 1-800-342-9647
o From outside the United States (with applicable access code): 800-3429-6477
o International Collect (through long distance operator): 1-484-530-5908
• Servicemembers and dependents with questions about the SCRA should contact their
unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal
assistance office locator for all branches of the Armed Forces is available at
http://Ieszalassistance law of mil/content/liocator nhn
form HUD-92070
(2/2007)
M.AR-04-2009 WED M:25 PM MEMBERS 1ST FCU
CUSPS - Track & Confirm
FAX NO. 7177955207 P. 01
Page 1 of 1
C vO
Track EAO
Tracer & Confirm
Sewch PA"ll is
a ab*UR@cW Number. F771 GM 33339 3W 2M 35
SUAW' Oelivared
Yqw mm was deNvwW at 10:36 am on December 31, 200B in
BtSII MERQAL6, PA 17093. A red of delvm remd may be available
VMWO yow kcal Poet OMM fcw a fee.
Additional btfaatlatkn fiat #0 item is SWMI in See ofllitw.
? t DOW #so3<i ; ,'l?aanl tb it eeailllrAr s
EW Number.
;•8sa?
8dr MAp i;nnW 1!r FOA" Ow 4-490 JOIN pnvo4 pow TOM O Urf t is PfMti+lr.APW4"19
Copyftph* M94 W USPS. AN Rigb% RaMrwtl. No FEAR ACt EEO Dala FOIA # : `: ::.•; .. ;'; • •?.; ;
Exhibit "E"
http:/Arkenfiml.smi.usM.comr igTrackNtu-9171.., 31912009
- I. 0
HERS Or FEDERAL
CREDIT UNION
: IN THE COURT OF COMMON PIXAS
CUMBERLAND COUNTY,
: PEWSYLVANIA
PLAINTIFF .
Vs. NO.:
JACK V. COBLE. RL
DEFENDANT : CIVIC ACTION-LAW
: MORTGAGE FORECLOSURE
VERIFICATION
I. Arlm& Dintsman, Colla mul Liquidation Specialist for Me mbem 1 a FedeW
Cm & Union. being authorized to do so on behalf of Mmbe m 1 It Federal Credit Union,
herby verify that the SNUMOM made in the foregoing pleading are true; and coma to
the beet of my information imowlodge and, be3fef I understnd that false stag we
made subject to the pcnaltias of IS Pa. C.S.A. Section 4904, relating to maworn
fads &Adon to authorities.
Members I" Federal Credit Union
Arlan& Dkftnam, Collateral
Liquidation Specialist
6
l
77
?iI
Sheriffs Office of Cumberland County
R Thomas Kline 00 `IAWGPr ? -_ _ - Solicitor
Sheriff
1
Jody S Smith
Ronny R Anderson
Chief Deputy OFFICE of THE SHERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
03/13/2009 05:49 PM - Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on March
13, 2009 at 1749 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Louree B. Blaine by making known unto Louree Blaine personally, at 208 4th Street,
Summerdale, Cumberland County, Pennsylvania its contents and at the same time handing to her
personally the said true and correct copy of the same.
03/13/2009 05:49 PM - Kenneth Gossert, Deputy Sheriff, who being duly swom according to law, states that on March
13, 2009 at 1749 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Jack V. Coble, Jr. , by making known unto Louree Blaine, grandmother of defendant, at
208 4th Street, Summerdale, Cumberland County, Pennsylvania its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $58.82 (PAID) S
March 17, 2009
R THOMAS KLINE, SHERIFF
Docket No. 2009-1464
Members list Credit Union v Jack V. Coble, Jr.
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Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
JACK V. COBLE, JR.
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
: NO.: 09-1464
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
PRAECIPE TO SETTLE, DISCONTINUE & END
To the Prothonotary:
Please mark the docket in the above captioned matter settled, discontinued and
ended without prejudice.
mespecuu3ky IMLt ,
Date: April 6, 2009 1 , ( 1 M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
FILE?-OI t{;E
OF THE PROTH"IN TARY
2009 APR -8 AM i 1 : 5 1
CUM-, la- .
PENNSYLVANIA