HomeMy WebLinkAbout09-2168IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
U.S. BANK N.A., N.D.,
Plaintiff,
vs.
LEE C. HALL and
M. HOPE HALL,
Defendants.
CIVIL DIVISION
NO.: CA- clto$
?iv i Lorin
TYPE OF PLEADING
CIVIL ACTION-COMPLAINT
IN MORTGAGE FORECLOSURE
TO DEFENDANTS
You are hereby notified to plead to the ENCLOSED
COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF
AfTORNEY FOR PLAINTIFF
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
205 West 4`h Street
Suite 500
Cincinnati, OH 45202
AND THE DEFENDANTS IS:
Lee C. Hope
175 Fisher Road
Etters, PA 17319
M. Hope Hall
4613 N. Clearview
Camp Hill, PA 17011
?..
X/46
/efrORNE'7-FOR LAINTIFF
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
355 St. Johns Dr., Hampden Township
(CITY, BORO, TOWNSHIP,WARD)
FILED ON BEHALF OF PLAINTIFF:
U.S. Bank N.A., N.D.
COUNSEL OF RECORD FOR THIS
PARTY:
Brian B. Dutton, Esquire
Pa. I.D. #81953
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
ORNEY"FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
U.S. BANK N.A., N.D., CIVIL DIVISION
Plaintiff,
vs.
LEE C. HALL and
M. HOPE HALL,
Defendants.
NO..
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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 may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166 or Toll Free (800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
U.S. BANK N.A., N.D., CIVIL DIVISION
Plaintiff,
NO.: 0 9'-
vs.
LEE C. HALL and
M. HOPE HALL,
Defendants.
CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE
U.S. Bank N.A., N.D. by its attorneys, Grenen & Birsic, P.C., files this Complaint ?lin
Mortgage Foreclosure as follows:
1. The Plaintiff is U.S. Bank N.A., N.D., which has its principal place of business at
205 West 4th Street, Suite 500, Cincinnati, Ohio 45202 and is authorized to do business in the
Commonwealth of Pennsylvania.
2. The Defendants, Lee C. Hall and M. Hope Hall, are individuals whose last known
addresses are 175 Fisher Road, Etters, Pennsylvania 17319 and 4613 N. Clearview, Camp Hill,
Pennsylvania 17011, respectively.
3. On or about February 18, 2005, Defendants executed a Note in favor of
Wilmington Finance, a division of AIG Federal Savings Bank in the original principal amount of
$262,000.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and
made a part hereof.
4. On or about February 18, 2005, as security for payment of the aforesaid Note,
Defendants made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as
Nominee for Wilmington Finance, a division of AIG Federal Savings Bank a Mortgage in the
original principal amount of $262,000.00 on the premises hereinafter described, said Mortgage
being recorded in the Office of the Recorder of Deeds of Cumberland County on March 1, 2005
in Mortgage Book Volume 1898, Page 3019. A true and correct copy of said Mortgage,
containing a description of the premises subject to the Mortgage ("Mortgaged Premises"), is
marked Exhibit "B", attached hereto and made a part hereof.
5. On or about November 21, 2005, Mortgage Electronic Registration Systems, Inc.,
as Nominee for Wilmington Finance, a division of AIG Federal Savings Bank assigned all of its
right, title and interest in and to the Mortgage and Note to Plaintiff pursuant to the terms of a
certain Assignment of Mortgage recorded in the Office of the Recorder of Deeds of Cumberland
County at Mortgage Book Volume 722, Page 3190.
6. Defendants are the record and real owners of the aforesaid Mortgaged Premises.
7. Defendants are in default under the terms of the Mortgage and Note for, inter alia,
failure to pay the monthly installments of principal and interest when due. Defendants are due
for the September 1, 2008 payment.
On or about January 22, 2009, Defendants were mailed Notices of Homeowner's
Emergency Mortgage Assistance Act of 1983 ("Act 91 Notices") in compliance with the
Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983, as amended.
9. Plaintiff was not required to send Defendants separate Notices of Intention to
Foreclose Mortgage in compliance with Act 6 of 1974, 41 P.S. § 101, et seq., as a result of
sending the Act 91 Notices.
10. The amount due and owing Plaintiff by Defendants is as follows:
Principal $250,020.66
Interest to 3/9/09 $ 9,379.27
Late Charges to 3/9/09 $ 322.64
Corporate Advances $ 95.00
Attorney's fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $263,617.57
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due
of $263,617.57 with interest thereon at the rate of $42.81 per diem from March 9, 2009, and
additional late charges, additional reasonable and actually incurred attorney's fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the Mortgaged
Premises.
GRENEN & BIRSIC, P.C.
BY: AX'000?111
Brian B. Dutton, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
i??I'T ???,??
at
Ey
SEE *PREPAYMENT RIDER TO NOTE' ATTACHED HERETO AND MADEA PART HEREOF.
NOTE
FE WARY 18, 2005
[Date]
CAMP HILL
[City]
355 SAINT JOHNS DRIVE, CAMP HILL, PA 17011
[Property Address]
LOAN NO.: A05020302
PENNSYLVANIA
[State]
1. BORROWER' S PROMISE TO PAY
In return for a loan that I have received, I promise to pay U.S. $ 262,000.00 (this amount is called "Principal"),
plus interest, to the order of the Lender. The Lender is
Wilmington Finance, a division of AIG Federal Savings Bank
I will make all payments under this Note in the form of cash, check or money order.
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is
entitled to receive payments under this Note is called the "Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly
rate of 6.250 %.
The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B)
of this Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making a payment every month.
I will make my monthly payment on the 1 at day of each month beginning on APRIL, 2005 I will
make these payments every month until I have paid all of the principal and interest and any other charges described below that I
may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest
before Principal. If, on MARCH 01, 2035 , 1 still owe amounts under this Note, I will pay those amounts in full on
that date, which is called the "Maturity Date."
I will make my monthly payments at Wilmington Finance, a division of AIG Federal Savings Bank
PO Box 209, Plymouth Meeting, PA 19482 or at a different place if required by the Note Holder.
(B) Amount of Monthly Payments
My monthly payment will be in the amount of U.S. $ 1,613.18
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a
"Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a
payment as a Prepayment If I have not made all the monthly payments due under the Note.
I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my
Prepayments to reduce they amount of Principal that I owe under this Note. However, the Note Holder may apply my
Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the
Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my
monthly payment unless the Note Holder agrees in writing to those changes.
MULTISTATE FU(® RATE NOTE Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT
In Isis:
Form 3200 1/01
All
VMP-5N (0207) Page 1 or 3 LENDER SUPPORT SYSTEMS, INC. SN.NEW (04103)
5. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other
loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge
shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b). any sums already collected from
me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the
Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated
as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days
after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of
my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.
(C) Notice of Default ,
If I am in default, the ]Vote Holder may send me a written notice telling me that if I do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all
the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or
delivered by other means.
(D) No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described
above, the Note Holder will still have the right to do so if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately In full as described above, the Note Holder will have the right to
be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those
expenses include, for example, reasonable attorneys' fees.
7. GIVING OF NOTICES
Unless applicable law,requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail to me at the Property Address above or at a different address If I give the Note
Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first
class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that
different address.
8. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in
this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is
also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety
or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights
under this Note against each person individually or against all of us together. This means that any one of us may be required to
pay all of the amounts owed, under this. Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor.
"Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the
right to require the Note Holder to give notice to other persons that amounts due have not been paid.
Initials:
VMP-5N (0207) Page 2 of 3 Form 3200 1101
10. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the
Note Holder under this Note, a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), dated the same date as
this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this
Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full
of all amounts I owe under this Note. Some of those conditions are described as follows:
If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is
not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written
consent, Lender may require immediate payment in full of all sums secured by this Security Instrument.
However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall
provide a period of not less than 30 days from the date the notice is given In accordance with Section 15
within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these
sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security
Instrument without'further notice or demand on Borrower.
WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED.
_O? (Seal)
M. HOPE HALL -Borrower
- (Seal)
-Borrower
- (Seal)
-Borrower
- (Seal)
-Borrower
LEE C. HALL (Seal)
-Borrower
- (Seal)
-Borrower
- (Seal)
-Borrower
_ (Seal)
-Borrower
VMPSN (0200 Page 3 of 3 Form 3200 1101
LOAN NO.: A05020362
PREPAYMENT RIDER TO NOTE
The Note dated FEBRUARY 18, 2005 between
Wilmington Finance, a division of AIG Federal Savings Bank
(Lender) and
M. HOPE HALL AND LEE C. HALL
(Borrower or I)
is hereby amended as follows:
1. Additional Covenants. Notwithstanding anything to the contrary set forth in the Note or
Security Instrument, Borrower and Lender covenant, and agree, that the provisions of the section of the
Note entitled "BORROWER'S RIGHT TO PREPAY" or "BORROWER'S PAYMENTS BEFORE THEY
ARE DUE" are amended to read as follows:
Subject to the Prepayment Penalty provided below, I have the right to make payments of Principal
at any time before they are due. A payment of Principal only is known as a "Prepayment." A "Full
Prepayment" is the prepayment of the entire unpaid Principal due under the Note. A payment of only part
of the unpaid Principal is known as a "Partial Prepayment." When I make a Prepayment, I will tell the
Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment If I have not
made all the monthly payments due under the Note.
If, within the 60 month period beginning with the date I execute the Note (the "Penalty
Period"), I make a Full Prepayment, or Partial Prepayment in any twelve (12)-month period that
exceeds IWo of the original Principal loan amount, I will pay a Prepayment charge as consideration
for the Note Holder's acceptance of such Prepayment. The Prepayment charge will equal 5.000 %
of the then Principal balance of the Note. No Prepayment charge will be assessed for any
Prepayment occurring after the Penalty Period.
This Rider will remain in full force and effect unless the Note is transferred by Lender and the
Borrower is notified in writing by the new Note Holder that such Note Holder, at its sole option, has
declared the Rider null and void. If the Rider is declared null and void, the original Note terms shall
remain in full force and effect.
`?' ,
?? U??J' (Seal)
M. HOPE HALL -Borrower LEE C. HALL
- (Seal)
-Borrower
- (Seal)
-Borrower
(Seal)
-Borrower
Lender Support Systems, Inc. FMC-WIL.RDR (07!04)
EXHIBIT "B"
Q?
OQ`?
O
Prepared By:
Wilmington Finance, div. of AIG FSB
401 Plymouth Road, Suite 400
Plymouth Meeting, PA 19462
877-963-4968
Parcel Number:
10-20-1846-178
LOAN NO.: A05020362
DEFINITIONS
MORTGAGE
Words used in multiple sections of this document are defined below and other words are defined in
Sections 3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are
also provided in Section 16.
(A) "Security Instrument" means this document, which is dated
together with all Riders to this document.
(B) "Borrower" is
LEE C. HALL AND M. HOPE HALL
Borrower is the mortgagor under this Security Instrument.
(C) "Lender" is
Wilmington Finance, a division of AIG Federal Savings Bank
FEBRUARY 18, 2005 ,
Lender is a FEDERAL SAVINGS BANK-
organized and existing under the laws of UNITED STATES OF AMERICA
Inftw P1
PENNSYLVANIA - Single Family - Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1101
VMP-6(PA) moos) Page 1 of 16 LENDER SUPPORT SYSTEMS, INC. 6OPA.NEW (10/02)
Return To:
Wilmington Finance, a division of AIG Federal
Savings Bank
401 Plymouth Road, Suite 400
Plymouth Meeting, PA 19462
[Space Above This Line For Recording Data]
Lender's address is
401 Plymouth Road, Suite 400, Plymouth Meeting, PA 19462
Lender is the mortgagee under this Security Instrument.
(D) "Note" means the promissory note signed by Borrower and dated FEBRUARY 18, 2005
The Note states that Borrower owes Lender
TWO HUNDRED SIXTY TWO THOUSAND AND NO/100 X X X X X X X X X X X X X X X X
Dollars
(U.S. $ 262,000.00 ) plus interest. Borrower has promised to pay this debt in regular Periodic
Payments and to pay the debt in full not later than MARCH 01, 2035
(E) "Property" means the property that is described below under the heading "Transfer of Rights in the
Property."
(F) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges
due under the Note, and all sums due under this Security Instrument, plus interest.
(a) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following
Riders are to be executed by Borrower [check box as applicable] :
Q Adjustable Rate Rider Condominium Rider 1-4 Family Rider
Q Graduated Payment Rider Planned Unit Development Rider Q Biweekly Payment Rider
Balloon Rider Q Rate Improvement Rider Second Home Rider
Q Other(s) [specify]
(H) "Applicablel Law" means all controlling applicable federal, state and local statutes, regulations,
ordinances and administrative rules and orders (that have the effect of law) as well as all applicable final,
non-appealable judicial opinions.
(I) "Community'Association Dues, Fees, and Assessments" means all dues, fees, assessments and other
charges that are'timposed on Borrower or the Property by a condominium association, homeowners
association or similar organization.
(J) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by
check, draft, or `similar paper instrument, which is initiated through an electronic terminal, telephonic
instrument, computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit
or credit an accdunt. Such term includes, but is not limited to, point-of-sale transfers, automated teller
machine transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse
transfers.
(K) "Escrow Items" means those items that are described in Section 3.
(L) "Miscellaneous Proceeds" means any compensation, settlement, award of damages,, or proceeds paid
by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (1)
damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the
Property; (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the
value and/or condition of the Property.
(M) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on,
the Loan.
VMP-6(PA) (oom) Page 2 or 16 Form 3039 1/01
(l) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the
Note, plus (ii) any amounts under Section 3 of this Security Instrument.
(O) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its
implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to
time, or any additional or successor legislation or regulation that governs the same subject matter. As used
in this Security Instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard
to a "federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage
loan" under RESPA.
(P) "Successor in Interest of Borrower" means any party that has taken title to the Property, whether or
not that party has assumed Borrower's obligations under the Note and/or this Security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: (1) the repayment of the Loan, and all renewals, extensions and
modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this
Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to
Lender the following described property located in the COUNTY
[Type of Recording Jurisdiction] of CUMBERLAND [Name of Recording Jurisdiction]:
SEE COMPLETE LEGAL DESCRIPTION DESCRIBED IN EXHIBIT "A" ATTACHED HERETO AND MADE A
PART HEREOF ;
which currently Has the address of
("Property Address") :
355 SAINT JOHNS DRIVE
[City] , Pennsylvania
[Street]
17011 [Zip Code]
CAMP HILL
TOGETHER WITH all the improvements now or hereafter erected on the property, and all
easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and
additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this
Security Instrument as the "Property."
VMP-6(PA) (oooe) page 3 of 16 Form 3039 1/01
EXHIBIT "A"
ALL :THOSE TWO (2) CERTAIN tracts or parcels of land situate in
Hampden Township, Cumberland County, Pennsylvania, bounded and described
as follows, to wit:
TRACT NO. 1: BEGINNING at a point on the eastern side of St. John's
Drive (formerly Point Ridge Drive) which point is at the dividing line between
property herein conveyed and property now or late of Wood Realty Company;
thence along the easterly side of St. John's Drive, North 00 degrees 45 minutes
East, 63.25 feet to a point; thence continuing along the easterly side of St. John's
Drive by an arc of a circle curving to the left having a radius of 397.85 feet, the arc
distance of 109.13 feet to a point; thence North 66 degrees 44 minutes East,
204.99 feet to a point; thence South 11 degrees 02 minutes East, 108 feet to a
point, the pr6perty, now or late of Wood Realty Company; thence along property
now or late df Wood Realty Company, South 52 degrees 24 minutes West, 243.46
feet to a point at the easterly side of St. John's Drive, the place of BEGINNING.
TRACT NO. 2: BEGINNING at a point at the southeasterly comer of
other lands now or formerly of Warren G. Watts and Myrtle K. Watts, his wife,
which point is 243.46 feet, northeastwardly from St. John's Drive (formerly Point
Ridge Drive) as measured along the southerly line of other lands now or formerly
of Warren G: Watts and Myrtle K. Watts, his wife; thence along the eastern line of
other lands now or formerly of Warren G. Watts and Myrtle K. Watts, his wife,
North 11 degrees 02 minutes West, 108 feet to a point; thence North 66 degrees 44
minutes East; 25.01 feet to a point at line of lands, now or late of Barbara W.
Rogers; thence along the line now or formerly of Barbara W. Rogers, South 18
degrees 53 minutes East, 95.44 feet to a point; thence South 52 degrees 24 minutes
West, 41.92 feet to a point, the place of BEGINNING.
HAVING THEREON ERECTED a dwelling house known and numbered
as 355 St. John's Drive, Camp Hill, Pennsylvania.
BEING THE SAME PRENUSES which Christopher T. Kelley, a single
person, and Audrey L. Kelley, now known as Audrey L. Englehart, a single
person, by Deed dated June 20, 2002 and recorded June 25, 2002 in the Office of
the Recorder bf Deeds in and for Cumberland County, Pennsylvania, in Book 252,
Page 1649, granted and conveyed unto Lee C. Hall and . H p all, his wife.
Lee C. Hall
C '(I.BiQ, f-I,L0
M. Hope Hall
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has
the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all
claims and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform
covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real
property.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges.
Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and any
prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items
pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in U.S.
currency. However, if any check or other instrument received by Lender as payment under the Note or this
Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments
due under the Note and this Security Instrument be made in one or more of the following forms, as
selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or
cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a
federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location designated in the Note or at
such other location as may be designated by Lender in accordance with the notice provisions in Section 15.
Lender may return any payment or partial payment if the payment or partial payments are insufficient to
bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan
current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial
payments in the future, but Lender is not obligated to apply such payments at the time such payments are
accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay
interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring
the Loan current.; If Borrower does not do so within a reasonable period of time, Lender shall either apply
such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding
principal balance. under the Note immediately prior to foreclosure. No offset or claim which Borrower
might have now or in the future against Lender shall relieve Borrower from making payments due under
the Note and this; Security Instrument or performing the covenants and agreements secured by this Security
Instrument.
2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all
payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest
due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments
shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts
shall be applied first to late charges, second to any other amounts due under this Security Instrument, and
then to reduce thg principal balance of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a
sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and
the late charge. it more than one Periodic Payment is outstanding, Lender may apply any payment received
from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be
VMP-6(PA) (owe) rage 4 of 16 Form 3039 1/01
paid in full. To the extent that any excess exists after the payment is applied to the full payment of one or
more Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall
be applied first to any prepayment charges and then as described in the Note.
Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under
the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments.
3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due
under the Note, until the Note is paid in full, a sum (the "Funds") to provide for payment of amounts due
for: (a) taxes and assessments and other items which can attain priority over this Security Instrument as a
lien or encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (c)
premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance
premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage
Insurance premiums in accordance with the provisions of Section 10. These items are called "Escrow
Items. At origination or at any time during the term of the Loan, Lender may require that Community
Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and
assessments shall1be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to
be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives
Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's
obligation to pay,,to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be
in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts
due for any Escrow Items for which payment of Funds has been waived by Lender and, if Lender requires,
shall furnish to Lender receipts evidencing such payment within such time period as Lender may require.
Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to
be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement"
is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and
Borrower fails to, pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9
and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such
amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in
accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in
such amounts, that are then required under this Section 3.
Lender may.; at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply
the Funds at the.-time specified under RESPA, and (b) not to exceed the maximum amount a lender can
require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and
reasonable estimates of expenditures of future Escrow.Items or otherwise in accordance with Applicable
Law.
The Funds ' shall be held in an institution whose deposits are insured by a federal agency,
instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) or in
any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time
specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually
analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the
Funds and Applicable Law permits Lender to make such a charge. Unless an agreement is made in writing
or Applicable Law requires interest to be paid on the Funds, Lender shall not be required to pay Borrower
any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest
VMP-6(PA) pooe) Page 6 or 16 Form 3039 1/01
shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the
Funds as required by RESPA.
If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to
Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow,
as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to
Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12
monthly payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall
notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make
up the deficiency in accordance with RESPA, but in no more than 12 monthly payments.
Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund
to Borrower any Funds held by Lender.
4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines, and impositions
attributable to the Property which can attain priority over this Security Instrument, leasehold payments or
ground rents on the Property, if any, and Community Association Dues, Fees, and Assessments, if any. To
the extent that these items are Escrow Items, Borrower shall pay them in the manner provided in Section 3.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable
to Lender, but only so long as Borrower is performing such agreement; (b) contests the lien in good faith
by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to
prevent the enforcement of the lien while those proceedings are pending, but only until such proceedings
are concluded; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating
the lien to this Security Instrument. If Lender determines that any part of the Property is subject to alien
which can attain priority over this Security Instrument, Lender may give Borrower a notice identifying the
lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or
more of the actions set forth above in this Section 4.
Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or
reporting service'used by Lender in connection with this Loan.
5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on
the Property insured against loss by fire, hazards included within the term "extended coverage," and any
other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance.
This insurance shall be maintained in the amounts (including deductible levels) and for the periods that
Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of
the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's
right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may
require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood zone
determination, certification and tracking services; or (b) a one-time charge for flood zone determination
and certification services and subsequent charges each time remappings or similar changes occur which
reasonably might affect such determination or certification. Borrower shall also be responsible for the
payment of any -fees imposed by the Federal Emergency Management Agency in connection with the
review of any flood zone determination resulting from an objection by Borrower.
)ewe
VMP-6(PA) rove) Page 6 or 16 Form 3039 1101
If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance
coverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any
particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might
not protect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk,
hazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower
acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of
insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall
become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest
at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from
Lender to Borrower requesting payment.
All insurance policies required by Lender and renewals of such policies shall be subject to Lender's
right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as
mortgagee and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal
certificates. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and
renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Lender,
for damage to, or destruction of, the Property, such policy shall include a standard mortgage clause and
shall name Lender as mortgagee and/or as an additional loss payee.
In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender
may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower' otherwise agree
in writing, any insurance proceeds, whether or not the underlying insurance was required by Lender, shall
be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and
Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to
hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the
work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken
promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series
of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law
requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower any
interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by
Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If
the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance
proceeds shall be, applied to the sums secured by this Security Instrument, whether or not then due, with
the excess, if any, paid to Borrower. Such insurance proceeds shall be applied in the order provided for in
Section 2.
If Borrower, abandons the Property, Lender may file, negotiate and settle any available insurance
claim and related. matters. If Borrower does not respond within 30 days to a notice from Lender that the
insurance carrier'has offered to settle a claim, then Lender may negotiate and settle the claim. The 30-day
period will begin when the notice is given. In either event, or if Lender acquires the Property under
Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance
proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and
(b) any other of 'Borrower's rights (other than the right to any refund of unearned premiums paid by
Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the
coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or
to pay amounts unpaid under the Note or this Security Instrument, whether or not then due,.
(rdlw• YX
VMP-6(PA) (oooa) Page 7 of 16 Form 3039 1101
6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal
residence within 60 days after the execution of this Security Instrument and shall continue to occupy the
Property as Borrower's principal residence for at least one year after the date of occupan cy, unless Lender
otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating
circumstances exist which are beyond Borrower's control.
7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not
destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the
Property. Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in
order to prevent the Property from deteriorating or decreasing in value due to its condition. Unless it is
determined pursuant to Section 5 that repair or restoration is not economically feasible, Borrower shall
promptly repair the Property if damaged to avoid further deterioration or damage. If insurance or
condemnation proceeds are paid in connection with damage to, or the taking of, the Property, Borrower
shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such
purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of
progress payments as the work is completed. If the insurance or condemnation proceeds are not sufficient
to repair or restore the Property, Borrower is not relieved of Borrower's obligation for the completion of
such repair or restoration.
Lender or its agent may make reasonable entries upon and inspections of the Property. If it has
reasonable cause; Lender may inspect the interior of the improvements on the Property. Lender shall give
Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause.
8. Borrower's Loan Application. Borrower shall be in default if, during the Loan application
process, Borrower or any persons or entities acting at the direction of Borrower or with Borrower's
knowledge or consent gave materially false, misleading, or inaccurate information or statements to Lender
(or failed to provide Lender with material information) in connection with the loan. Material
representations include, but are not limited to, representations concerning Borrower's occupancy of the
Property as Borrower's principal residence.
9. Protection of Lender's Interest in the Property and Rights Under this Security Instrument. If
(a) Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b) there
is a legal proceeding that might significantly affect Lender's interest in the Property and/or rights under
this Security Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for
enforcement of alien which may attain priority over this Security Instrument or to enforce laws or
regulations), or (c) Borrower has abandoned the Property, then Lender may do and pay for whatever is
reasonable or appropriate to protect Lender's interest in the Property and rights under this Security
Instrument, including protecting and/or assessing the value of the Property, and securing and/or repairing
the Property. Lender's actions can include, but are not limited to: (a) paying any sums secured by a lien
which has priority over this Security Instrument; (b) appearing in court; and (c) paying reasonable
attorneys' fees to,protect its interest in the Property and/or rights under this Security Instrument, including
its secured position in a bankruptcy proceeding. Securing the Property includes, but is not limited to,
entering the Property to make repairs, change locks, replace or board up doors and windows, drain water
from pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned
on or off. Although Lender may take action under this Section 9, Lender does not have to do so and is not
under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all
actions authorized under this Section 9.
VMP-6(PA) roooa) Page 8 of 16 Porn 3039 1/01
Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower
secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of
disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting
payment.
If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the
lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless
Lender agrees to the merger in writing.
10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan,
Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. If, for any reason,
the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that
previously provided such insurance and Borrower was required to make separately designated payments
toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain
coverage substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially
equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate
mortgage insurer selected by Lender. If substantially equivalent Mortgage Insurance coverage is not
available, Borrover shall continue to pay to Lender the amount of the separately designated payments that
were due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these
payments as a non-refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be
non-refundable, notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall not be
required to pay Borrower any interest or earnings on such loss reserve. Lender can no longer require loss
reserve payments if Mortgage Insurance coverage (in the amount and for the period that Lender requires)
provided by an insurer selected by Lender again becomes available, is obtained, and Lender requires
separately designated payments toward the premiums for Mortgage Insurance. If Lender required Mortgage
Insurance as a condition of making the Loan and Borrower was required to make separately designated
payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to
maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until Lender's
requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and
Lender providing for such termination or until termination is required by Applicable Law. Nothing in this
Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note.
Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it
may incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage
Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may
enter into agreements with other parties that share or modify their risk, or reduce losses. These agreements
are on terms and .conditions that are satisfactory to the mortgage insurer and the other party (or parties) to
these agreements, These agreements may require the mortgage insurer to make payments using any source
of funds that the mortgage insurer may have available (which may include funds obtained from Mortgage
Insurance premiums).
As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinsurer,
any other entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that
derive from (or might be characterized as) a portion of Borrower's payments for Mortgage Insurance, in
exchange for sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement
provides that an, affiliate of Lender takes a share of the insurer's risk in exchange for a share of the
premiums paid to. the insurer, the arrangement is often termed "captive reinsurance." Further:
(a) Any such agreements will not affect the amounts that Borrower has agreed to pay for
Mortgage Insurance, or any other terms of the Loan. Such agreements will not increase the amount
Borrower will owe for Mortgage Insurance, and they will not entitle Borrower to any refund.
1nnw.: A4
VMP-6(PA) (ooo9) Page 9 of 16 Form 3039 1/01
(b) Any such agreements will not affect the rights Borrower has - if any - with respect to the
Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights
may include the right to receive certain disclosures, to request and obtain cancellation of the
Mortgage Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a
refund of any Mortgage Insurance premiums that were unearned at the time of such cancellation or
termination.
11. Assignment of Miscellaneous Proceeds, Forfeiture. All Miscellaneous Proceeds are hereby
assigned to and shall be paid to Lender.
If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of
the Property, if the restoration or repair is economically feasible and Lender's security is not lessened.
During such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds
until Lender has had an opportunity to inspect such Property to ensure the work has been completed to
Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may pay for the
repairs and restoration in a single disbursement or in a series of progress payments as the work is
completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such
Miscellaneous Proceeds, Lender shall not be required to pay Borrower any interest or earnings on such
Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security would
be lessened, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument,
whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be
applied in the order provided for in Section 2.
In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous
Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with
the excess, if any, paid to Borrower.
In the eventof a partial taking, destruction, or loss in value of the Property in which the fair market
value of the Property immediately before the partial taking, destruction, or loss in value Is equal to or
greater than the amount of the sums secured by this Security Instrument immediately before the partial
taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the sums
secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds
multiplied by the following fraction: (a) the total amount of the sums secured immediately before the
partial taking, destruction, or loss in value divided by (b) the fair market value of the Property immediately
before the partial taking, destruction, or loss in value. Any balance shall be paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market
value of the Property immediately before the partial taking, destruction, or loss In value is less than the
amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless
Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums
secured by this Security Instrument whether or not the sums are then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the
Opposing Party (as defined in the next sentence) offers to make an award to settle a claim for damages,
Borrower fails to.respond to Lender within 30 days after the date the notice is given, Lender is authorized
to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the
sums secured by this Security Instrument, whether or not then due. "Opposing Party" means the third party
that owes Borrower Miscellaneous Proceeds or the party against whom Borrower has a right of action in
regard to Miscellaneous Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in
Lender's judgment, could result in forfeiture of the Property or other material impairment of Lender's
interest in the Property or rights under this Security Instrument. Borrower can cure such a default and, if
acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be VMP-6(PA) (ooos) Page to of 16 Form 3039 1/01
dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or other material
impairment of Lender's interest in the Property or rights under this Security Instrument, The proceeds of
any award or claim for damages that are attributable to the impairment of Lender's interest in the Property
are hereby assigned and shall be paid to Lender.
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be
applied in the order provided for in Section 2.
12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for
payment or modification of amortization of the sums secured by this Security Instrument granted by Lender
to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower
or any Successors in Interest of Borrower. Lender shall not be required to commence proceedings against
any Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify
amortization of the sums secured by this Security Instrument by reason of any demand made by the original
Borrower or any Successors in Interest of Borrower. Any forbearance by Lender in exercising any right or
remedy including, without limitation, Lender's acceptance of payments from third persons, entities or
Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or
preclude the exercise of any right or remedy.
13. Joint and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants
and agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who
co-signs this Security Instrument but does not execute the Note (a "co-signer") : (a) is co-signing this
Security Instrument only to mortgage, grant and convey the co-signer's interest in the Property under the
terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security
Instrument; and (c) agrees that Lender and any other Borrower can agree to extend, modify, forbear or
make any accommodations with regard to the terms of this Security Instrument or the Note without the
co-signer's consent.
Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes
Borrower's obligations under this Security Instrument in writing, and is approved by Lender, shall obtain
all of Borrower's rights and benefits under this Security Instrument. Borrower shall not be released from
Borrower's obligations and liability under this Security Instrument unless Lender a ees to such release in
writing. The covenants and agreements of this Security Instrument shall bind except as provided in
Section 20) and benefit the successors and assigns of Lender.
14. Loan Charges. Lender may charge Borrower fees for services performed in connection with
Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this
Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees.
In regard to any other fees, the absence of express authority in this Security Instrument to charge a specific
fee to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may not charge
fees that are expressly prohibited by this Security Instrument or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so
that the interest or other loan charges collected or to be collected in connection with the Loan exceed the
permitted limits,,then: (a) any such loan charge shall be reduced by the amount necessary to reduce the
charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted
limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal
owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the
reduction will be treated as a partial prepayment without any prepayment charge (Whether or not a
prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made by
direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out
of such overcharge.
15. Notices. All notices given by Borrower or Lender in connection with this Security Instrument
must be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to
VM"(PA) (coos) Page 11 of 16
Form 3039 1101
have been given to Borrower when mailed by first class mail or when actually delivered to Borrower's
notice address if sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers
unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address
unless Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptly
notify Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's
change of address, then Borrower shall only report a charge of address through that specified procedure.
There may be only one designated notice address under this Security Instrument at any one time. Any
notice to Lender shall be given by delivering it or by mailing it by first class mail to Lender's address
stated herein unless Lender has designated another address by notice to Borrower. Any notice in
connection with this Security Instrument shall not be deemed to have been given to Lender until actually
received by Lender. If any notice required by this Security Instrument is also required under Applicable
Law, the Applicable Law requirement will satisfy the corresponding requirement under this Security
Instrument.
16. Governing Law; Severability; Rules of Construction. This Security Instrument shall be
governed by federal law and the law of the jurisdiction in which the Property is located. All rights and
obligations contained in this Security Instrument are subject to any requirements and limitations of
Applicable Law. Applicable Law might explicitly or implicitly allow the parties to agree by contract or it
might be silent, but such silence shall not be construed as a prohibition against agreement by contract. In
the event that any provision or clause of this Security Instrument or the Note conflicts with Applicable
Law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be
given effect without the conflicting provision.
As used inthis Security Instrument: (a) words of the masculine gender shall mean and include
corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and
include the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to
take any action.
17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument.
18. Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18,
"Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited
to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or
escrow agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser.
If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower
is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior
written consent, Lender may require immediate payment in full of all sums secured by this Security
Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by
Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall
provide a period'of not less than 30 days from the date the notice is given in accordance with Section 15
within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay
these sums prior, to the expiration of this period, Lender may invoke any remedies permitted by this
Security Instrument without further notice or demand on Borrower.
19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions,
Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time
prior to the earliest of: (a) five days before sale of the Property pursuant to any power of sale contained in
this Security Instrument; (b) such other period as Applicable Law might specify for the termination of
Borrower's right: to reinstate; or (c) entry of a judgment enforcing this Security Instrument. Those
conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security
Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or
mewa:_`-
VMFk-6(PA) (oow) Page 12 of 16 Form 3039 1101
agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited
to, reasonable attorneys' fees, property inspection and valuation fees, and other fees incurred for the
purpose of protecting Lender's interest in the Property and rights under this Security Instrument; and (d)
takes such action as Lender may reasonably require to assure that Lender's interest in the Property and
rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this Security
Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement sums and
expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c)
certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon
an institution whose deposits are insured by a federal agency, instrumentality or entity; or (d) Electronic
Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby
shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not
apply in the case of acceleration under Section 18.
20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in
the Note (together with this Security Instrument) can be sold one or more times without prior notice to
Borrower. A sale might result in a change in the entity (known as the "Loan Servicer") that collects
Periodic Payments due under the Note and this Security Instrument and performs other mortgage loan
servicing obligations under the Note, this Security Instrument, and Applicable Law. There also might be
one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan
Servicer, Borrower will be given written notice of the change which will state the name and address of the
new Loan Servicer, the address to which payments should be made and any other information RESPA
requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the Loan is
serviced by a Loan Servicer other than the purchaser of the Note, the mortgage loan servicing obligations
to Borrower will oremain with the Loan Servicer or be transferred to a successor Loan Servicer and are not
assumed by the Note purchaser unless otherwise provided by the Note purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an
individual litigant or the member of a class) that arises from the other party's actions pursuant to this
Security Instrument or that alleges that the other party has breached any provision of, or any duty owed by
reason of, this Security Instrument, until such Borrower or Lender has notified the other' party (with such
notice given in compliance with the requirements of Section 15) of such alleged breach and afforded the
other party hereto a reasonable period after the giving of such notice to take corrective action. If
Applicable Law provides a time period which must elapse before certain action can be taken, that time
period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and
opportunity to care given to Borrower pursuant to Section 22 and the notice of acceleration given to
Borrower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective
action provisions Hof this Section 20.
21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those
substances defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the
following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides
and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials;
(b) "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that
relate to health, 'safety or environmental protection; (c) "Environmental Cleanup" includes any response
action, remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental
Condition" means a condition that can cause, contribute to, or otherwise trigger an Environmental
Cleanup.
VMP-8(PA) (oooe) Page 13 or 16 Form 3039 1/01
Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous
Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do,
nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental
Law, (b) which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a
Hazardous Substance, creates a condition that adversely affects the value of the Property. The preceding
two sentences shall not apply to the presence, use, or storage on the Property of small quantities of
Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to
maintenance of the Property (including, but not limited to, hazardous substances in consumer products).
Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit
or other action by any governmental or regulatory agency or private party involving the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any
Environmental Condition, including but not limited to, any spilling, leaking, discharge, release or threat of
release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a
Hazardous Substance which adversely affects the value of the Property. If Borrower learns, or is notified
by any governmental or regulatory authority, or any private party, that any removal or other remediation
of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary
remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation on
Lender for an Environmental Cleanup.
NON-UNIFbRM COVENANTS. Borrower and Lender further covenant and agree as follows:
22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following
Borrower's breach of any covenant or agreement in this Security Instrument (lint not prior to
acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify
Borrower of, amlong other things: (a) the default; (b) the action required to cure the default; (c) when
the default must be cured; and (d) that failure to cure the default as specified may result in
acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and
sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration
and the right to assert in the foreclosure proceeding the non-existence of a default or any other
defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at
its option may require immediate payment in full of all sums secured by this Security Instrument
without further demand and may foreclose this Security Instrument by judicial proceeding. Lender
shall be entitled to collect all expenses incurred in pursuing the remedies provided in this Section 22,
including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by
Applicable Law:
23. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument
and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge
and satisfy this 'Security Instrument. Borrower shall pay any recordation costs. Lender may charge
Borrower a fee for releasing this Security Instrument, 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.
24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or
defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or
future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale,
and homestead exemption.
25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one
hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security
Instrument.
26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to
Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time
under the Note.
' Inttlals.
VMP-B(PA) (0008) Page 14 of 16 Form 3039 1/01
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this
Security Instrument and in any Rider executed by Borrower and recorded with it.
Witnesse .
-Witness
-Witness
A Z/
(Seal) Seal)
l.A&cLL -Borrower LEE C. HALL -Borrower
(Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
VMP-S(PA) (ooos) Page 16 of 16 Form 3039 1/01
Certificate of Residence
I `x??? , do hereby certify that
the correct a dress of the wiWin-name ortgagee is
401 Plymouth Road, Suite 400, Plymo .hh Meeting, PA 19462
Witness my hand this ay of
ddb
Agent of Mortgagee
COMMONWEALTH OF PFNNSYLN
County ss:
On this, the day of ,before me, the
undersigned officer, personally a eared 49,
M. HOPE HALL AND LEE C. H L d
}
dX..
known to me (or
satisfactorily proven) be the person(s) who??s_6 name(s) is/are subscribed to the within instrument and
acknowledged that she/they executed the Tame for the purposes herein contained.
IN WTTNES WHEREOF, I
My Commission ires:
Noww Seal
Dpi G Det ook Notary Pul
i--.-d A. in AN
,K.r_ Psnnsviver" Assoaatlon C
set my hand and official seal.
P ( I.
Title of Officer
VMRB(PA) (oooel . Page 16 or 16
InRlda. 4W
Form 3039 1/01
VERIFICATION
Sandra Elder, Foreclosure Supervisor, and duly authorized representative of U.S. Bank
N.A., N.D., deposes and says subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn
falsification to authorities that the facts set forth in the foregoing Complaint are true and correct
to her information and belief.
Sandra Elder
Foreclosure Supervisor
U.S. Bank N.A., N.D.
n :V? ,_.n.t'4v
OF THE
2 0 0 9 A P, R -' PEE 3: 1
C
'4"l8 .'so p o ATE
co lolQio$
.193Ss3
Sheriffs Office of Cumberland County
R Thomas Klineour?ty of 4u,r4brf?? Edward L Schorpp
Sheri Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy OrFICE ` HE MFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/09/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Lee C. Hall, but was unable to locate him in his
bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the
defendant Lee C. Hall. On April 9, 2009 the defendants address located at 355 St. John's Drive Camp
Hill, Cumberland County, Pennsylvania 17011 was found vacant. The Camp Hill postmaster has
forwarded the defendants mail to a new address of 175 Fisher Road Etters, York County, Pennsylvania
17319.
04/13/2009 08:40 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 9, 200
at 2040 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within
named defendant, to wit: M. Hope Hall, by making known unto herself personally, defendant at 4613 N.
Clearview Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing
to her personally the said true and correct copy of the same.
SHERIFF COST: $74.20 SO ANSWERS,
April 16, 2009
2009-2168
U.S. BANK NA
VS
LEE C. HALL
R THOMAS KLINE, SHERIFF
By-
Deputy Sheriff
OF THE_ PRTC-="P' ' NOT PY
2Q09 APR 21 A 8: 30
1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
U.S. BANK N.A., N.D., CIVIL DIVISION
Plaintiff,
vs.
LEE C. HALL and
M. HOPE HALL,
Defendants.
NO.: 09-2168 Civil Term
TYPE, OF PLEADING
Praecipe to Reinstate Civil Action -
Complaint in Mortgage Foreclosure
FILED ON BEHALF OF PLAINTIFF:
U.S. Bank N.A., N.D.
COUNSEL OF RECORD FOR THIS
PARTY:
Brian B. Dutton, Esquire
Pa. I.D. #81953
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
U.S. BANK N.A., N.D., CIVIL DIVISION
Plaintiff,
vs.
LEE C. HALL and
M. HOPE HALL,
Defendants.
NO.: 09-2168 Civil Term
PRAECIPE TO REINSTATE CIVIL ACTION -
COMPLAINT IN MORTGAGE FORECLOSURE
TO:PROTHONOTARY
SIR:
Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the
above-referenced matter and mark the docket accordingly.
GRENEN & BIRSIC, P.C.
BY:
B B. Dutto squire
Attorneys for Plaintiff
'HI
r* t7
2009 MAY -I Fr 1: t17
cu
a4(!01 1 a
a ?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
U.S. BANK N.A., N.D.,
Plaintiff,
vs.
LEE C. HALL and
M. HOPE HALL,
PRAECIPE FOR DEFAULT JUDGMENT
Defendants. AS TO M. HOPE HALL ONLY
(Mortgage Foreclosure)
FILED ON BEHALF OF PLAINTIFF:
I hereby certify that the
address of Plaintiff is:
205 West 4th Street
Suite 500
Cincinnati, OH 45202
CIVIL DIVISION
NO.: 09-2168 Civil Term
TYPE OF PLEADING
U.S. Bank N.A., N.D.
COUNSEL, OF RECORD FOR THIS
PARTY:
the last known address of
Defendant, M. Hope Hall, is:
4613 N. Clearview
Camp Hill, PA 17011
GRENEN & BIRSIC, P.C.
"- - 1-1-4- - ?-- - -
Attorneys for Plaintiff
Brian B. Dutton, Esquire
Pa. I.D. 481953
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
U.S. BANK N.A., N.D.,
Plaintiff,
vs.
LEE C. HALL and
M. HOPE HALL,
Defendants.
TO: PROTHONOTARY
CIVIL DIVISION
NO.: 09-2168 Civil Term
PRAECIPE FOR DEFAULT JUDGMENT
SIR:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendant, M. Hope Hall, ONLY, in the amount of $266,647.16, which is itemized as
follows:
Principal $250,020.66
Interest to 5/15/09 $ 12,247.54
Late Charges to 5/15/09 $ 483.96
Corporate Advances $ 95.00
Attorney's fees $ 1,300.00
Title Search, Foreclosure and
Execution Costs $ 2,500.00
TOTAL $266,647.16
with interest on the principal sum at the rate of 542.81 per diem from May 15, 2009, and
additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged
premises.
GRENEN & BIRSIC, P.C.
BY:
rian B. Dutton, Esquire
Attorneys for Plaintiff
f
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATE OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Brian B. Dutton, Esquire, attorney for and authorized
representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendant, M. Hope Hall, was not in the military service of the United States of America to the
best of his knowledge, information and belief and certifies that the Notices of Intent to take
Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached
copy.
Sworn to and subscribed before me
this _J __day of , 2009.
Notary Public
6 S NIA
otriai
PeWp A. T"w #Mno, N@Viy R*j a
4 MM?rph AUgh*nY 4our?r
n durst # 40 11
r, ann an s n NOW
0
IN TIIE C OURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
U.S. 13ANK N.A., N.D.,
Plaintiff,
CIVIL DIVISION
N0.:09-2168 Civil Tenn
vs.
LEE C. HALL and
M. HOPE HALL,
Defendants.
TO: M. Hope Hall
4613 N. Clearview
Camp Hill, PA 17011
DATE OF NOTICE: April 30, 2009
IMPORTANT NOTICE
YOU ARE. IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR 13Y ATTORNEY AND FILL? IN WRITING WITH '1111: COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITI(IN TEN DAYS FROM TIIE DAME OF THIS NOTICE, A JUDGMENT MAY 131.,
I:N'I'I?RFD AGAINST YOU WITHOUT A Ill:ARING AND YOU MAY LOST: YOUR PROPERTY OR
OTI E'R IMPORTANT RIGHTS.
YOU SIiOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, GO TO OR `I'EI_EPHONE "1'HE 01-'FICE SET FORTH BELOW. THIS OFFICE, CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166 or 'Toll Free (800) 990-9108
FIRST CLASS MAIL, POSTAGE PREPAID
GRE'NEN & BIRSIC, P.C.
By: Zorlormc Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
rti
T t7 ?iEC,- I ?
1
2 f I A Y 22 F,".i i%: a
+14-cc PO "TT""
CIO tdq Ul
OW aas s?9
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
U.S. BANK N.A., N.D., CIVIL DIVISION
Plaintiff,
vs.
LEE C. HALL and
M. HOPE HALL,
NO.: 09-2168 Civil Term
Defendants.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: M. Hope Hall
4613 N. Clearview
Camp Hill, PA 17011
( ) Plaintiff
(XX) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or
Judgment was entered in the above captioned proceeding
on
( ) A copy of the Order or Decree is enclosed,
or
(XX) The judgment is as follows: $266,647.16
with interest on the principal sum at the rate of $42.81 per diem from May 15, 2009, and
additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs
(including increases in escrow deficiency) and for foreclosure and sale of the mortgaged
premises.
Sheriffs Office of Cumberland County
,tir of 4? ?nbrr Edward L Schorpp
R Thomas Kline Solicitor
Sheriff Cf ,,
3 i r Y
Jody S Smith
Ronny R Anderson
Chief Deputy OFFI4E 0 t s" :aiFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
05/04/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and
inquiry for the within named defendant, to wit: Lee C. Hall, but was unable to locate him in his bailiwick.
He therefore deputized the Sheriff of York County, PA to serve the within Complaint In Mortgage
Foreclosure according to law.
05/12/2009 09:20 AM - York County Return: And now May 12, 2009 at 0920 hours I, Richard P. Keuerleber, Sheriff o1
York County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in
Mortgage Foreclosure, upon the within named defendant, to wit: Lee C. Hall by making known unto
himself personally, defendant at 175 Fisher Road Etters, Pennsylvania 17319 its contents and at the same
time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $37.00
May 28, 2009
2009-2168
U.S. Bank, N.A.
VS
Lee C. Hall
SO ANSWERS,
R THOMAS KLINE, SHERIFF
i
- t'a
?z
COUNTY OF YORK
OFFICE OF THE SHERIFF
45 N. GEORGE ST., YORK, PA 17401
SHERIFF SERVICE
PROCESS RECEIPT and AFFIDAVIT OF RETURN
1 PLAINTIFF/SI
U.S. Bank N.A., N.D.
3. DEFENDANT/S/
_11 _a M -a... Ha11
4. TYPE OF WRIT OR COMPLAINT
?MF r NCYPICE
Cmplt in Mtg Forec
.nrn nr7er•.NGn OR SOLD
Lee \,. •Las.i ...,.... --- ---. ., ----.
SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DES
Lee C. Hall
6. ADDRESS (STREET OR RFO WITH BOX NUMBER. APT NO, CITY, BORO. TWP .STATE AND ZIP CODE)
AT 175 Fisher Road, Etters, PA 17319 CERT MAIL 1ST CLASS MAIL 0 POSTED ? OTHER
7. INDICATE SERVICE O PERSONAL PERSON IN CHARGE 0 DEPUTIZE OUNTY PA o hereby de Utlz the sheriff of
MAY 1 '2009 20 I, SHERIF ur cording
NOW
COUNTY to execute t
YORK , to law. This deputization being made at the request and risk of the plaintiff. SHERIFF OF YORK coUNTY
6. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING ,tnvn.c
ADV FEE PAID BY ATTY.
OUT OF CO CUMBERLAND
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same
sheriffs sale thereof person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff
without a watchman, in custody of whomever is fou fd in possbefore ession.
herein for any loss, destruction. or removal of any prop" 10. TELEPHONE NUMBER 17. DATE FILED
9. TYPE NAME and ADD Sot RNE f ORIGIN TOR and SIGNATURE (412) 281-7650-1-2009
12. SEND NOT 40FSERIVI C Y TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed) C? CO SHERIFF
9th Floor, Pittsburgh,
Brian B. Dutton, Esquire, One Gateway Center,
SPACE BELOW FOR USE OF THE StERFF - DO NOT 1NRITE BELOW THIS LM
14. DATE RECEIVED 15 Expiration/Hearing Date
13. I acknowledge receipt of the writ 5-6-20 -31-2009
or complaint as indicated above. MCGILL YCSO OTHER ( ) SEE REMARKS BELOW
RESIDENCE ( ) POSTED( ) POE ( ) SHERIFF'S OFFICE
16. HOW SERVED: PERSONAL
t7 D I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc named above. (See remarks be19w')Date of Service 20 Time of Serv18. AND IT F IVIDSIAL SERVE / DDRESS HERE IF NOT SHOWN ABOVE (Relati onship to Defendant)
2t. ATTEMPTS Date Timgg Miles lnt a ime Miles Int. ate Time Mites Int. Dale Time Miles Int. Date Time Miles Int. Oale Time Miles Int.
22
23. Advance Costs 24. Service Costs 25. N/F 26 Mileage 27 Postage 28. SSjub Total
$100.00 ?? ` d ?'+?
Costs 36 Serv ice Costs 37 Notary Cert. ?38.
34. ForWgn County Costs 35. Advance
INSTRUCTIONS
PLEASE TYPE ONLY LINE 1 THRU 12
DO NOT DETACH ANY COPIES
PNotary 31. Surchg. 32. Tot. Costs 33 Costs Due elund
.„arPneuaeJNot Found 39. Total Costs 40 Costs Due or
21st
41. AFFIRMED and subscribed to befo me this 44, Signature of
e
42 day of MDy 20. 0943! p. Sheriff
PR04+rf I NOTARY 46. Signature of York r
County Sherill K J
RICHARD P .
N1Y 46 Signature of Foreign
County Sheriff
SO.OF AUTHORIZED ACKNOWLEDGE ISSUING AUTHORITY AND TTRETURN SIGNATURE
1. WHITE -issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sherdfs Office
OUR MBER
2 T
c09 -21N8 Civil Term (Cumberland)
SERVICE CALL.
(717) 771-9601
445
E-2009
E
51 DATE RECEIVED
1 ?
LJ 't7
f r-rl