HomeMy WebLinkAbout09-2416
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
RICHARD L. ERICKSON and
CHRISTINE M. ERICKSON
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: Oq - Atfl(p CiVc 1 (errs
: 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 WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20) days after this
Complaint and Notice are served by entering a written appearance personally or by
attorney and filing in writing your defenses or objections to the claims set forth against
you. You are warned that if you fail to do so, the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money
claimed in the Complaint or for any other claims or relief requested by the Plaintiff. You
may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
NOTICIA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas
demandas expuestas en las pagmas siguientes, usted tiene viente (20) dias de plazo al
partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o
sus objections a las demandas en contra suya.
Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar
una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que
es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
LISTED 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 17070-0173
(717) 938-6929
MEMBERS 1 IT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
Vs. NO.: 0 9- a Y14 /Z'
RICHARD L. ERICKSON and
CHRISTINE M. ERICKSON
DEFENDANTS : CIVIL ACTION-LAW-MORTGAGE
:FORECLOSURE
COMPLAINT
AND NOW, comes Members 1St 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 1St Federal Credit Union ("Members 1 `v), is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
2. Defendant, Christine M. Erickson, is an adult individual having a last known
address of 2 Mooreland Avenue, Mount Holly Springs, PA 17065.
3. Defendant, Richard L. Erickson, is an adult individual having a last known
address of 334 North Bedford Street, Carlisle, PA 17013. Richard L. Erickson
and Christine M. Erickson are referred to herein collectively as "Defendants."
4. On or about September 5, 2006, Defendants borrowed from and agreed to
repay to Members 1St FORTY-SIX THOUSAND AND 00/100 ($46,000.00)
dollars (the "Loan"). The Loan is evidenced by a Closed-End Note,
Disclosure, Loan and Security Agreement dated September 5, 2006 (the
"Note") executed and delivered to Members 1St by Defendants. A copy of the
Note is attached hereto as Exhibit "A" and made part hereof.
5. As security for the Loan, Defendants executed and delivered to Members 1St a
mortgage ("Mortgage") on all that certain real estate and improvements
erected thereon situate in Borough of Mount Holly Springs, Cumberland
County, Pennsylvania, known and numbered as 2 Mooreland Avenue, Mount
Holly Springs, PA 17065 (the "Property"). At all times relevant hereto,
Defendants have been and continue to be the record and sole owners of the
Property. A description of the Property is attached hereto as Exhibit "B" and
made part hereof.
2
6. On or about September 29, 2006, the Mortgage was recorded in the
Cumberland County Recorder of Deeds Office at Mortgage Book 1967, Page
3658. A true and correct copy of the Mortgage is attached hereto as Exhibit
"C" and made part hereof.
7. The Mortgage has never been assigned by Members 1St and is still held by it
as a valid and subsisting obligation of Defendants.
8. Pursuant to the terms and conditions of the Note, Defendants agreed to pay to
Members 1St bi-weekly installments of principal and interest in the amount of
at least $174.06 each, which bi-weekly payments were subsequently adjusted
to $172.01 each, beginning on October 12, 2006 and continuing every two (2)
weeks thereafter.
9. Defendants are in default of Defendants' obligations under the Note and the
Mortgage as a result of Defendants' failure to make the bi-weekly payments
due to Plaintiff as set forth therein in the amount of $172.01 each for July 24,
2008 and every two (2) weeks thereafter through the date of this complaint as
more particularly described in the Act 91 Notice attached hereto as exhibit
"D" and made part hereof.
10. 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. M., and in
particular section 403 thereof, and of Defendants' 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
October 22, 2008, addressed to Defendants via certified mail, return receipt
3
requested. A copy of the said notice is attached hereto as Exhibit "D" and
11.
12.
13
made part hereof.
US Postal form 3877 evidencing the mailing of said Notices is attached hereto
as Exhibit "E" and made part hereof.
Simultaneously, Members 1 St forwarded to Defendants the same Notices as
set forth in paragraph 10 above addressed to Defendants by United States
mail, first class, postage prepaid, bearing the return address of Members 1St
The Notices forwarded to Defendants in said manner have not been returned
to the offices of Members 1St as undeliverable or otherwise.
As of April 17, 2009, Defendant is indebted to Members 0 in the amount of
FORTY-EIGHT THOUSAND FIVE HUNDRED AND 80/100 ($48,500.80)
dollars itemized as follows:
a. Outstanding principal $42,092.24
b. Interest to April 17, 2009 3,865.56
c. Late fees 43.00
d. Attorney's fees 2,500.00
f. Total due to Members 1 st as of 4/17/2009 $48,500.80
The above attorney's fees are estimated through sheriff sale and are in
accordance with Defendants' agreements as set forth in the underlying
Mortgage and the Note. Defendants will be responsible for actual reasonable
legal fees incurred by Members 1' in this matter subject to any limitation
contained in the Note.
4
14. Defendants also agreed under the terms and conditions of the Note that in the
event of default there under Defendants would pay, in addition to the amounts
set forth in paragraph 13 above, costs incurred by Members 1St as a result of
the institution and prosecution of these legal proceedings.
15. The obligation owed to Members 1St continues to accrue interest at the rate of
$15.2109 per day, through the date of payment and continues to accrue
attorney's fees and costs.
16. As set forth above, Members 1 st has made demand upon Defendants to cure
the default under the Mortgage and the Note. However, as of the date hereof,
Defendants continue to fail and refuse to cure the default.
WHEREFORE, Plaintiff, Members 1 st Federal Credit Union, demands judgment
against Richard L. Erickson and Christine M. Erickson, in the amount of FORTY-EIGHT
THOUSAND FIVE HUNDRED AND 80/100 ($48,500.80) DOLLARS plus interest at
the rate of $15.2109 per day, through the date of judgment entered on this complaint and
at the legal rate thereafter until the date of payment, additional attorney's fees and costs
of suit and for foreclosure and sale of the mortgaged property.
Date: *13,09
Karl M. Ledebohm, Esq.
Supreme Court ID # : 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Respectfully submitted,
14St
MEMBERS It
.0o n etr•nr
5000 Louise Drive. P.O. Box 40
Mechanicabuig, PA 17055
CLOSED-END
BORRONERS NAME AM ADDRESS
CHRISTINE M ERICKSON
FDIEO L.f VARIABLE
ANNUAL PERCENTAGE FINANCE CHARGE' Amount Financed: The amount of Total of Payments: The amount
RATE: The cost of your credit as a The dollar amount the credit will credit provided to you or on your you will have paid alter you have
yearly rate.' cost you. behalf. made all payments as scheduled.
13.44 % t $ 38,687,90 t $ 46,000.00 a $ 8 5, 697. 90
Variable Rats: If your ban has a volatile rate as Indicated above the Annual Percentage Rate may Inerear during On term of this transaction if the (index) dhntles. The
credit union w6'aold a margin of to the Index vokte. The rate will change monthly on the twill day of the month. The rate will now be NOW than are maximum rata Nbwed by
law, and it will never be leas tun . • Any Interest ride Increart will result In more payments at the Sam amount. For Example, H yaw bon urea for $5,000 at 15% for 43
months and the AMwd Percentage Rate Increased by 2% after one yea, the term of your low would Increase by two months
Preferred Raft: H chucked. On lodowling applies to your loan: p asp paymen you
TM ANJIML WPERCEMXGE RATE 6adordnibwe in the ANNUAL PERGENTAOEismh
minis ps
dh
b
20%
ali
C
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A
?
1 y
MTE M
have a
en
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.
a
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ou
ANNUAL
the Aubnletkc Paymmnt DieOmahlad Rant. The rata,vs frncrsate by .207. H You war th aublMk paymnl elran0aneld aid fall to maeW n tuMdant funds In ydur arcatxl to
cover the aubmslic paymerms. In ahldt • aid, ohs effed ef the Nhcleasa wlM W b tiled Ilhe Inn d Inn. Fa rampb, t Your AtAOmeOe Payment Diamwletl Role it 10%
on • 15.000.00 Inn bid 80 months ant you ear ris aubnMb paynant amlgansm, yet rate wW Inchaase b 70.20%, raaultlnp In 7 additonel Payment,
VariaRaa Pretemed lam. t Inn ts • voriade rate Inn and you o"' a rata, your dbeotad M ftken af tie Ihle you lake out your ban. This
Inn W _.I.- d ANNUAL PERCENTAGE RATE wit tan vary aeeordbq to tlanpes In tat Index (r dtsdosed above). For example. If a vartsMe hale ben'S hnalel ANNUAL
im"d
PERCENTAGE RATE is 12% at the if_ you take the an your InIW prtderted ANNUAL PERCENTAGE RATE will be WAX. Your initial preferred ANNUAL PERCENTAGE
RATE will tlten very etxcrdbp W the Index, r dluloeed in Ilro'Vamabb Rafa" prdvblon above.
it Rea heftmd Loam, it you Ian I. • Bxed rate Ian and you WAY a preferred rata, your ANNIMIL PERCENTAGE RATE will be the preferred ANNUAL
PERCENTAGE RATE dwdosed shore for m bong as your preerted status rameInS in eeeel.
Number of Payments Amount of Payments PaymentFratiueluY when Payments Are Due Property Insurance: You may obtain property
insurance from anyone you want that is acceptable to
ITyou pet the Insurance from the
the credit union
Y
.
me 519 174.06 Weekly - Beginning 10/1212008
ur credit ur lon you will pay
amo
am1 172,10 Final Due • On 0912212016 $ WA
,All m: a:
Security: Collateral securing other bans with the craft union the goods or Property Other
will also secure INS bar. You we giving a security Interest in being purchased. ?(Describe):
d
i
i
:
t un
on, an
your shares and/or deposit in the cred
Lab Charye: 11 ¦ armath Is IMO by 10 days or more You we Required Dsposlt Balance: The Annual Perantaga Rats dal Flling Fees: Non-Filling Insurance:
be charged a Lae Ns o(5% of your scheduled payment. nip toka INo account your required deposit balance. H ray. $ NIA $ NIA
p Par on vau nq n•v m P•Y • yN Wedded dose =Pn 111.it mamas and 0awar, nPnP•P^•nh, GVKK any mosymerv In full before
ITEMIZATION OF
AMOUNT,FINANCED $ 46,000.00 Amount Paid to others on your behalf (Describe)
YOU DIRECTLY S
T G
VEN T 079
17
2 $ o'OD To Mbvwrts td• $ lo.m.oo To;SEARS CRE CA
I
AMOUN
O ,
. $0.00 To karealaLee $ To
AMOUNT PAID ON YOUR ACCOUNTS 20,335.91 $6.129.58 To JCPENNEYST S To.
$ 4,766.36 To SEARS $ 0.00 To IF-
PREPAID FINANCE CHARGE $ 0.00 j To Aned 50w" $ To Aaed Solukooo
SECURITY INFORMATION
MAKE MODEL YEAR I.D. NUMBER TYPE VALUE
OTHER (Describe): 2 MOORELAND AVE MT HOLLY SPRINGS, PA 17065
and/or Deposits of I j I ll 1
You ages that file terms and conditions in the disclosure statement and the loan and Sawrly agreements looted an papa 2 of No document Shea apply to this Ian. If there Is more
than ens borrower. we agree that all the condllban of the Inn and security agreements governing this ban Sate apply to both )okmly and severely. You acknowledge that you have
received a copy of the ban and realty agreements and disclosure siaamsM. Co-signer If you are signing as co-signer, you acknowledge receipt of the notice to co-signer
comakled on pogo 2.
R 'S 61 NATl6i DATE CO-MAKER ?'OTHER R ? "CO-SIGNER DATE
(SEAL) , _L1i X (SEAL)
CO-MAKER ?'OTHEROWNER ?''CO-SIGNER DATE CO-MAKER ?'OTHEROWNER ? "COSIGNER DATE
X (SEAL) X (SEAL)
? CO-MAKER ? 'OTHER OWNER ? "CO-SIGNER DATE ? CO-MAKER ? 'OTHER OWNER ? "CO-SIGNER DATE
X (SEAL) X (SEAL)
'aMr owNrA:IM tlw,.r.als Ice. Psprlrrr,rl Ndw..rlr.,wr w Ir•,rl r ow.k.,, irse,r,.rrrw.ter hw•.lb whir rmw.rM,,. our • w+rer. w M Narb4r /Mob d,K kul.rlaw,lew, art
,r,M 1rIrN, •,.rwap ke.rrl r o. rdrr.w r rebkwa rawlr,.myAtlwrr4 •'CDadNl11: ale: •mral ace.r.s1 w,kw nil rN krnr•wr Mpr.ra hwrew err.IVr M rry one Y warYwewrwl.Irr
pw+r:Wrw,w MreurwMd,b.l .lid rw4.wwMr brNW MIIW. I
I w. .r. Yl.l w.,.?.. ??......-?.. .. ...?.-?... r ...
Mel mry ternirlate M et airy one. (wet t.ldsWrr tltel o pint N• irtevartae UCANT, we
I we ulran net tle purtlleooot ooh htaalaa 1• vecnarN end nn In arras m abuin IaedL a Mail
ANT
moot to joiay and •Idnielehy Boole under to ben. end ehr ellsgqners am t7uerambM es not egiee ter Insurance. Alf No CPEAgPP NO NT
The Ied=gwargn.,1 end 2, our as rewwed W daamirw my l?l NlplMah Ice tnlrorww: ? r y 7 ?
1. (APOW M. te H. alelnaltre wwapr wdy) Are ybuuldw ap 7D m too Mel LJ
2. (APOW bl m dSebMl;:mp ord.) Ale yyoucu Ilndw age dot r fide date ANOre vats PeweywoftV O ? a ?
auldde yar honefar. a prowl rot 30 hellsamoreperweak erdhonebenwwalegfur30dapw nicrobetawtlesdell?
In .601100. h Yowler °ecrdl S 24,dr w the Ienewing queWOn mast dea be rwwered in grow to deamdn• ePglbWty. .
3. Ccrllaale, ACgllnd bulYle DMld pIaeq n•Mr kq yeen. twye ypu tier nedu& or %i d a art•d yid CMIOSt n ea.a or Mall•ly •n•rY Deers. stoke,
s1+grOm• (A El a ? I]
anq ADS RWed ConPlp (Ar1C)1
Mit fYg (acelanewan to to ego,o ¦ lea b onYm que bent M mid our) mwwtedge asp ho1M. N :4:g I anaww'NO" to tprooon 1 w2, w undorM•nd that Ohl. Fenian is nor Mbmle, for nourenra and
w raw b° h-.d. It my cant or 1 wrwwW 'V.oadon ?. von uM•roarr aW w w r IIY•atlte p to on arrwe not prerdlrq St.00 I
TM.INea,e date of my low) kewerlce oil be t ys 00.0 W.•ppqreo, Any person whe I m angly rd with Intrlt to dMnud any Inr nuicS eemrn w •aw Paton Igor r Min IP tewrance
w stsumms of cWlg camomingany lomoiaa1W. Irdoml•Uan oreenerN for one =so ofmi l•edng IM0,08bn concomng• let rrrriallheroWurgeahauOiMmlrarueeL
w44ch l • wine eat -4-ts-sh mn.r to erbotrel rd d0il pensates. Do reel Ngn tl6o •ppmWr if ay aleaflaebin *owes ars Mart. The eppgcelbn WI at b. w°d In ertrr N al @;pN la
stank pate have not boon competed, the debtor has not a*" and aided the applk+rbn and t On ppgeatlon kits not been wtneerd.
THIS INSURANCE CONTAINS LIMITATIONS/EXCLUSIONS PERTAINING TO BENEFITS PAYABLE.
CREDIT INSURANCE APPLIED FOR: NOTE: ONLY ONE APPLICANT MAY APPLY FOR DISABILITY COVERAGE.
? Yes No Single Credit Life Total Premium Q Yes ? No Credit Disabilty Total Premium
? Yes ® No Joint Credit Life'
Indicate which appicanl(s): ? APO- ? CO-Applicant $ 0.00 Indicate which applicant(s): ? Applic vit ? Co-App6wnt ; S 4,811.34
You W Cowed ley mid one typoo of rrreraga fwwhkh • charge Is ndOt•d ruin pplwWn
APPLI TS SIGMA DATE OF BIRTH DATE 0- PLI SIGNATURE TE OF BIRTH DATE
V-7 I f.
EWMINESS DATE SECONDARY BENEFICIARY ( PPLICANT) SECONDARY BENEFICIARY (C0- ANT)
MHC•984386.37 A
WIC-97111100.37 LASERA,ORD F. 43789 R•r Val uorl Cwnparvr. I- All nghUntserv.d
I
Exhibit "A"
BORRONERS NAME LOAN NUMBER ACCOUNT NUMBER DATE OF LOW
CHRISTINE M ERICKSON 186828 33087 17 09/0512006
IN 1MI ESSACEMENTRSg1THE WORDS 'CREDIT UNION' MEANS MEMBERS 1ST FEDERAL CREDIT UNION. THE WORDS 'YOU.' 'YOUR' AND 'YOURS" MEAN THOSE
LOAN AGREEMENT
PsymentolFinence Charges: For value received, you promise to pay, at
the Credit Union's office. all amounts due. All payments shall be made
pursuant to the disclosure statement on age 1 of this document. You
understand that the finance charge and total of age manta shown on papa 1
of this document we based on the assumption That all installment peyMonts
will be made on the scheduled due dates, and . If you have qualified for
preferred rate that you crrntimre to sandy the conditions of that preferred
rate. It you fail( to ay any installment by Dha time it is due, you will pay
addtional interest on fits overdue amount.
Allocatlon of Payments and Additional Payments: Payments and
c:redita shall be applied in the following order: any amounts past due; any
tees or charges owing, including any insurance premiums; accrued interest
or finance charges; outstanding principal. Payments made in addition to
regularly scheduled payments shall be applied in the some order.
Preferred Rate: If you qualify for a preferred rate as disclosed on pace 1 of
this document or In a separate preferred rate addendum, you understand
that you must meet the conditions disclosed to you M order to quality for the
preferred rate and rival continue to meet those conditions In order to keep
your preferred rate. It you fall to meet those conditions, your rate will
increase, thereby extending the terms of your loan. Yau promise to continue
making Ipayyments ndlto meet arllloob eigations under this Agreement even if
you no onger receive Late Charges: If you make a late paYmment, you agree to pay a late charge
if one is disposed on page 1 of this aocumenl.
Property Insurance: If you obtain a ban seared by a motor vehicle or
other tangible p you must obtain insurance which protects the credit
union from tkwncial "leis. The amount and coverage of the property
Insurance must be acceptable to the credit union. Such a policy must
rovide at least fire. theft, combined additional coverages and collision
Pnaurance. It must contain a Lou Payable douse endorsement naming the
credit union as lien holder. You may obtain this insurance from any agent of
your choice and direct the agent to send the credit union a copy of the
policy.
Debtor Responsibility: You promise to notify credit union of any change in
your name address or emp1grrit. You promise not to apply for a ban if
you know Attie is a reasonab p?robabil, Olaf you will be unable to repay
t obligation according to she tams o 1 She credit extension. You promise
to inform credit union of any new Information which relates to your ability to
repay your obligation. You promise not to submit toles or inaccurate
in repay your or wilIfully conceal information regarding your creditworthiness,
credit standing, or credit capacity.
SECURITY AGREEMENT
1. To aecur? opemYY'ort It Ihls loan and all expenditures Incurred by the credit
unbn In ednneeUon with tbls loan, or n ma}I:irlg on a aeeuriry leremt You
any
pro s f Doran ne -p?urcMie
pWin 'ho win a aI d moil requfrwiNnts are a
Money gaols.
2. Your real ?iryplns Icsaon a, salt or transfer the collateral unless you have
J. You nt that cept?eW gli the rad4?Unioo WW *Xad 7h r any of as wount n h of Via aindkrcapp su owner of 4. doss It Pty a ed ta¦u, agar sum ord and p the ? ia pts or aattttra?cchdeod to the pr pea y
ssuuitasble shot nYdw a1 to execute fna? fimanto and sectry
e?akul atlvera s Ilik .01: der udon'sretlwK and will defend I he property
S. You will mmnNNan insurance to cover airy wihMe or other in Which the
acredit MnsadAaclory s btneyaeadaesuniori. Vnsw=I arsaupwoYkr n a f wdon wph proof
a cods Insurance until ad come o agd m wmn inn aearN cry thb
party are reoNit. t % to masdebi such Inwnrioe. cock water may but
?nol required bm oh41n Insurance of our own and so the cost at such to the
sums owed. This cost will bear Interest at the contract rile Was paW. You Nnher
assign to the crodh union the it to receive the proceeds of ny Insurance on
n
on?You Iltnodi tit U Nell to ?one?y roccheck eeeds«dSe?et to credit
as
the proceeds of such ineunna, and apply those prooseds to d. wAr owed to
the credit union
You hmhw authorize the credit union to provide your, nswr,e. Service Center
with the necessary information for verificcation of adequate coverage.
you isclin gg% is 1 eaow be that to yyoou in ividunally wt i:tO extension lott tlre?'prolaction of the
6. Sheub tlhs credit union leaf a any time that the seauitry orwnrW has
dlmlNshetl In value, or for any reason mil Vol oddkfonef liam?y a miadmd, ou
addsbnN seWGlry
agree assiun ooM le gn td trade union within ;%(,1.0 o ca cr do
unbn ve wha0ever d
teal abdh necessary to g
e sgakat paslDls
7. V a Oef" me donned in the Loan Aorislnanl should occur, the credit union has
the authorhv. upon such defws. to seas and .sit a. rDsm-1 M i. .i
s and
h. It
may
a. The Credit union is hereby appoMed as your Aaornw Ir?Fed m Worm any
Ms Na wdv union fools are necessary to pr Mae colWeral and the
wm? y kdersst which ads agreement creates
9. R India is more than oru borrower,gir obfgabons under this agreement are
joint a?several. each being aquany responsible Io NMI the terms of this
10. This security agreement not any binds you, but your executors, administrators,
hairs, and assigns.
Statutory Lien: If you are In default, federal low gives the credit union the
right to tip y the balance of shares and/or dividends in your account(s) at
the time o default to satisfy this loan. Once you are in delaul , the cre dit
union may exercise this right without further notice to you.
Delay in Enforcement: Credit Union may delay enforcing any of the credit
union rights under this agreement without losing them.
Irregular Paynwnts: The credit union may accept late payments or partial
payments, even though marked "payment in full, without losing any of the
credit unbn fights under this agreement.
Co maker; If you are signing title agreement as a co-maker, you agree to
be equaliv responsible w It the borrower, but the credit union may sue
either or both of you. The credit union does not haw to notify you that this
agreement has not been paid. The credit union may extend the terms of
payment and release any security without notifying or releasing you from
responsibility on this agreement.
Contractual Pledge of shams: You pledge all your shuns and deposits In the
credit union, Including future addition*, me security for this loan. In case you
default, the credit union may appy time shares and depos=tap
ayment
of au wms due etthe stirs of dskulk hncWding comb of wld
reasonable atbraay's fen, that the credit union may Incur, up to 20% of the
unpaid principal and Interest No Ilan or right to Impma a Ron on shares and
deposits shall apply to arty of your shares which may be held In an 'Indivldwl
Retirement Account" or' oogh Plan."
6100 2166
NOTICE TO CO-SIGNER
You are being asked to guarantee this debt. Think carefully before you do. If the borrower doesn't pay the debt, you will have to. Be sure you can afford to
pay If you have to, and that you want to accept this responsibility.
You may have to pay up to the full amount of the debt If the borrower does not pay. You may also have to pay late fees or collection costs, which increase this
amount.
I The creditor can tolled this debt from you without first trying to collect from the borrower. The creditor can use the some collection methods against you that
can be used against the borrower, such as suing you, garnishing your wages, etc. If this debt is ever in default, that fad may become a part of your credit
I record. This notice Is not the contract that makes you liable for the debt.
F. 43789 1102
APPRO 6y-o. Inc- 7241078
Page 2 of 2
ALL THAT CERTAIN lot of ground situate in the Borough of Mount
Cumberland County, .Pennsylvania, bounded and described as follows:
BEGNNNING at a point at the intersection of West Pine) Street and Mooreland Avenue,
thence along Mooreland Avenue, North one-fourth (1/4) degree East, a distance of one hundred
twenty-five (125) feet, more or less, to a point (iron pin), in line of lands now or formerly of
Christian Otto; thence by land now or formerly of the said Christian Otto, South eighty-nine and
three-fourths (89-3/4) degrees East, a distance of one hundred fifty (150) feet to a point (iron pin)
in line of other lands now or formerly of Emeiyn Moore Trine; thence along other lands now or
formerly of the said Emelyn Moore Trine, South one-fourth (1/4) degree West, a distance of one
hundred forty-one (141) feet, more or less, to a point (iron pin),;m the Northern line of West Pine
Street; thence along the Northern line of the said West Pine Street, North eight-four and one-
fourth (84-1/4) degrees West, a distance of one hundred fifty-one l(151) feet to a point, the place
of BEGINNING.
BEING known and numbered as 2 Mooreland Avenue
BEING the same premises which Thomas E. Clement and Yvonne D. Clement,
husband and wife, by their deed dated July 5, 2002 and recorded July 16, 2002 in
Cumberland County Deed Book 252, page 3531, granted and conveyed unto Richard L.
Erickson and Christine M. Erickson, husband and wife, the mortgagors herein.
Exhibit "B"
Prepared By: Members I st FCU
5000 Louise Drive
Mechanicsburg, PA 17055
Return To: Members Ist FCU
Real Estate Department
5000 Louise Drive
Mechanicsburg, PA 17055
(717)-795-6026
MORTGAGE
Made 09/05/2006
Between
RICHARD L ERICKSON AND CHRI STINE M ERICKSON
(hereinafter called "Mortgagor
And
MEMBERS 1 sr 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
$ 46,000.00 , 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 securityl 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, V
All that certain property of the Mortgagor located in MT HOLLY SPRINGS
BOROUGH , Cumberland County, Pennsylvania
DEED DATED JULY 5, 2002
BOOK 252
PAGE 3531
SEE EXHIBIT "A"
which currently has the address of 2 MOORELAND AVE
[Street]
MT HOLLY SPRINGS Pennsylvania
[City]
Acct No 33087
App1D 166626
17065
[Zip Code]
Page 1 of 4
Exhibit "C"
Together with the buildings and improvements erected thereon, the appurtenances thereunto
belonging and the reversions, remainders, rents, issues and profits thereof. I
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 shalt: (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 necessaryi 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 33087 AppID 166626 Page 2 of 4
(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 33087 AppiD 166626 Page 3 of 4
EXHIBIT "A"
LEGAL DESCRIPTION
A PARCEL OF LAND SITUATED IN THE STATE OF PENNSYLVANIA, COUNTY OF
CUMBERLAND, WITH A STREET LOCATION ADDRESS OF 2 MOORELAND AVE;
MOUNT HOLLY SPRINGS, PA 17065-1105 CURRENTLY OWNED BY RICHARD L
ERICKSON AND CHRISTINE M ERICKSON HAVING A TAX IDENTIFICATION
NUMBER OF 32-2336-0187-0000000-23 AND FURTHER DESCRIBED AS LAND
LESS THAN 1 ACRE .
32-2336-0187-0000000-23
2 MOORELAND AVE; MOUNT HOLLY SPRINGS, PA 17065-1105
159803
Witness the due execution hereof the day and year first above written.
RICHARD L ERICKSON
CHRISTINE M ERICKS N
Commonwealth of Pennsylvania
County of CLMEgLANp
ss:
On this, the 5th day of SePtember _,2006 , before me,
Eric Hess , the undersigned officer, personally appeared
RICHARD L ERICKSON AND CHRISTINE M ERICKSON
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:
Certificate of Residence of Mortgagee
Members IsT Federal Credit Union, Mortgagee within named, hereby certifies that its residence
is 5000 Louise Drive, Mechanicsburg, PA 17055.
By
Acct No 33087 ApplD 166626 Page 4 of 4
Date: October 22, 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. Speck information about the nature of the default is
provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be
able to help to save your home. This Notice explains how the program works
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE.
Take this Notice with you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies
serving your County are listed at the end of this Notice. If you have any
questions, you may call the Pennsylvania Housing Finance Agency toll free at
1-800-342-2397.(Persons with impaired hearing can call (717) 780-1869)
Exhibit "D"
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help
explain it. You may also want to contact an attorney in your area. The local bar
association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES 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:
CHRISTINE M ERICKSON
RICHARD L ERICKSON
2 MOORELAND AVENUE
MT HOLLY SPRINGS, PA 17065
33087-17
Members 1st Federal Credit Union
Members 18t Federal Credit Union
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU
MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN
CAUSED BY
CIRCUMSTANCES BEYOND
YOUR CONTROL,
IF YOU HAVE A REASONABLE
PROSPECT OF BEING ABLE
TO PAY YOUR MORTGAGE
PAYMENTS, AND
IF YOU MEET OTHER
ELIGIBILITY REQUIREMENTS
ESTABLISHED BY THE
PENNSYLVANIA HOUSING
FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a
temporary stay of foreclosure on your mortgage for thirty (30) days from the date
of this Notice. During that time you must arrange and attend a "face-to-face"
meeting with one of the consumer credit counseling agencies listed at the end of
this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF
YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU
MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE
CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW
TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the
consumer credit counseling agency listed at the end of this notice, the lender
may NOT take action against you for thirty (30) days after the date of this
meeting. The names, addresses and telephone numbers of designated
consumer credit counseling agencies for the county in which the property is
located are set forth at the end of this Notice. It is only necessary to schedule
one face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for specific
information about the nature of your default.) If you have tried and are unable to
resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To
do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency.
Your application MUST be filed or postmarked within thirty (30) days of your
face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO
OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN
THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE
WILL BE DENIED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are
very limited. They will be disbursed by the Agency under the eligibility criteria
established by the Act. The Pennsylvania Housing Finance Agency has sixty (60)
days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania
Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A
PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS
FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage
Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to
date).
NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender
on your property located at: 2 MOORELAND AVENUE, MT HOLLY SPRINGS,
PA 17065
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MORTGAGE PAYMENTS for the following weekly installments and the
following amounts are now past due: $37.99 due on 07/24/2008, $172.01 due on 07/31/2008, $172.01 due
on 08/07/2008, $172.01 due on 08/14/2008, $172.01 due on 08/21/2008, $172.01 due on 08/28/2008,
$172.01 due on 09/04/2008, $172.01 due on 09/ 11 /2008, $172.01 due on 09/18/2008, $172.01 due on
09/25/2008, $172.01 due on 10/02/2008, $172.01 due on 10/09/2008, $172.01 due on 10/16/2008.
plus weekly payments of $172.01 due on 10/23/2008, 10/30/2008, 11/06/2008,
11/13/2008, 11/20/2008, totaling $860.05
TOTAL AMOUNT PAST DUE: $2,102.11 + TOTAL AMOUNT COMING DUE $860.05 = $2,962.16
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable):
HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30)
DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER, WHICH IS $2,102.11, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD, WHICH IS $860.05. TOTAL AMOUNT DUE $2,932.16. Payments must
be made either by cash, cashier's check, certified check or money order made
payable and sent to:
Members 18t Federal Credit Union, 5000 Louise Drive, Mechanicsburg,
PA
17055, Attention: Arlanda Dintaman, Collections Department
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 Weekly 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, 2 MOORELAND AVENUE, MT HOLLY SPRINGS, PA 17065
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be
sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to
its attorneys, but you cure the delinquency before the lender begins legal
proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However, if legal
proceedings are started against you, you will have to pay all reasonable
attorney's fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount you owe the lender, which may also
include other reasonable costs. If you cure the default within the THIRTY (30)
DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have
not cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, you still have the right to cure the default and prevent
the sale at any time up to one hour before the Sheriffs Sale. You may do so by
paying the total amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure sale and
any other costs connected with the Sheriffs Sale as specified in writing by the
lender and by performing any other requirements under the mortgage. Curing
your default in the manner set forth in this notice will restore your mortgage to the
same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest
date that such a Sheriffs Sale of the mortgaged property could be held would be
approximately Three(3) months from the date of this Notice. A notice of the
actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You may
find out at any time exactly what the required payment or action will be by
contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Members 1$? Federal Credit Union
Address: 5000 Louise Drive, Mechanicsburg, PA 17055
Phone Number: (717) 795-6031 or (800) 283-2328 Ext. 6031
Fax Number: (717) 795-5207
Contact Person: Arlanda Dintaman
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 # 91 7108 2133 3935 9807 0184
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 # 91 7108 2133 3935 9807 0177
Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565
Relief Act and Urban Development (exp 4/30/2007)
Notice Disclosure Office of Housing
Legal Rights and Protections Under the SCRA
Servicemembers on "active duty" or "active service," or a dependent of such a
servicemember may be entitled to certain legal protections and debt relief pursuant to the
Servicemembers Civil Relief Act (50 USC App. §§ 501-596) (SCRA).
Who May Be Entitled to Legal Protections Under the SCRA?
• Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard,
and active service National Guard;
• Active service members of the commissioned corps of the National Oceanic and
Atmospheric Administration;
• Active service members of the commissioned corps of the Public Health Service;
• United States citizens serving with the armed forces of a nation with which the United
States is allied in the prosecution of a war or military action; and
• Their spouses.
What Legal Protections Are Servicemembers Entitled To Under the SCRA?
The SCRA states that a debt incurred by a servicemember, or servicemember and spouse
jointly, prior to entering military service shall not bear interest at a rate above 6 percent
during the period of military service.
The SCRA states that in a legal action to enforce a debt against real estate that is filed
during, or within 90 days after the servicemember's military service, a court may stop the
proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or
seizure of real estate shall not be valid if it occurs during, or within 90 days after the
servicemember's military service unless the creditor has obtained a court order approving
the sale, foreclosure, or seizure of the real estate.
The SCRA contains many other protections besides those applicable to home loans.
How Does A Servicemember or Dependent Request Relief Under the SCRA?
• In order to request relief under the SCRA, a servicemember or spouse, or both, must
provide a written request to the lender, together with a copy of servicemember's military
orders. The Lender providing this Notice is Members I" Federal Credit Union, ATTN:
Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The
phone number is toll free (800) 283-2328.
How Does a Servicemember or Dependent Obtain Information About the SCRA?
• The U. S. Department of Defense's information resource is "Military OneSource".
Website: http://www.militaaonesource.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:Hiegalassistance.Iaw.af.miI/content/locator pup
form HUD-92070
(2/2007)
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
Mailer's Name and Address:
Members 1 st Federal Credit Union
5000 Louise Dr
MECHANICSBURG, PA 17055
Pc ID #/
Article #
Addressee Name
Delivery Address
Form 3877
Permit Number:
9223844001
Sequence Number:
0000084
Postage ES ES
Type Fee
Pagel
SendSuite - MAC v5.02.5.02.1
Insured Due Total
Value ;ender Charge
Z900000004405 Christine M. Erickson 0.590 C 2.700 0.00 4.290
91 710821 333935980701 77 2 Mooreland Avenue ERR 1.000
Mount Holly Springs, PA 17065-
Z900000004407 Richard L. Erickson 0.590 C 2.700 0.00 4.290
91 710821 333935980701 84 334 North Bedford Street ERR 1.000
Carlisle, PA 17013-1909
?s
4 `^
i
Page Totals: 7
Cum Totals: 7 3.450
3.450 25.900
25.900 29.350
29.350
USPS CERTIFICATION
Total Number of Pieces Received:
4
Si,-mature of Re,S?ivinL, Employee
lit-J' ?s..
D
Form 3877 (Facsimile) SendSuite - MAC v5 Exhibit "E"
Form 3877
Mailer's Name and Address:
Members 1 st Federal Credit Union
5000 Louise Dr
MECHANICSBURG, PA 17055
Pc ID #/ Addressee Name
Article # Delivery Address
Permit Number:
9223844001
Sequence Number:
0000084
Postage ES ES
Type Fee
Pagel
MAC Cert. Ver. Num.
SendSuite - MAC v5.02.5.02.1
Insured Due Total
Value ;ender Charge
,Z90000000440'5,'- '`. Christine M. Erickson-' 0.590 C 2.700
0.00 4.290
91710821333935980b]77 2 Mooreland Avenue ERR 1.000
Mount Holly Springs, PA 1 7065-
Z900000004407. , Richard L Erickson 0.590 C 2.700 0.00 4.290
91 71 082 1 33393598d701 84' 334 North Bedford Street ERR 1.000
Carlisle, PA 17013 -1909
a JAG Pk ?D
s
11W
US
Page Totals: 7 3.450 25.900 29.350
Cum Totals: 7 3.450 25.900 29.350
USPS CERTIFICATION
Total Number of Pieces Received:
z1;,
F H •'+? . ?L 4f
Signature of R iv in, Employee
i D_ -
Form 3877 (Facsimile) SendSuite - MAC v5.02.5.02.1
MEMBERS PT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
RICHARD L. MUCKSON and
CHRISTINE M. ERICKSON
Dh'! ENDANTS
: IN THE COURT OF COMMON PLEAS
: CUM IERLAND COUNTY,
: PENNSYLVANIA
NO..
CIVIL ACTION-LAW-MORTGAGE
:FORECLOSURE
VERMCATION
I, Arlanda Dintaman, Collateral Liquidation Specialist for Members 13'Federal
Credit Union. being authorized to do so on behalf of Members 1 a Federal Credit Union,
hereby verify that the statements madc in the foregoing pleading are true and correct to
the best of my information knowledge and belief I tmda stand that false std are
made subject to the penalties of I$ Pa. C.S.A. Section 4904, relating to unworn
falsification to authorities.
Members 1" Federal Credit Union
By.
Z?e
Arlanda Dintaman, Collateral
Liquidadoa Specialist
6
F' E y, -
2009 APR 16 2• a
CI,PN? -
,r
*78. So Po ATrY
Cr.`a' 3a?1
Pa'I? aa3s43
Sheriffs Office of Cumberland County
R Thomas Kline fl`oIt, at ciflubr y? Edward L Schorpp
Sheri i Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy PCE $-ERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/18/2009 04:00 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 18,
2009 at 1600 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Christine M. Erickson, by making known unto Christine M. Erickson
personally, at 2 Mooreland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065, its
contents and at the same time handing to her personally the said true and correct copy of the same.
04/20/2009 04:00 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on April 20,
2009 at 1600 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Richard L. Erickson, by making known unto Richard L. Erickson
personally, at 2 Mooreland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065, its
contents and at the same time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $49.82
April 21, 2009
Docket No. 2009-2416
Members 1st v Richard Rxickson
SO ANSWERS,
R THOMAS KLINE, SHERIFF
Deputf Sheriff/
-0 -n
r10
--.J t_7
?. P.... _.,ti- j L.!
Karl K Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)93&929
MEMBERS 151 FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
RICHARD L. ERICKSON and
CHRISTINE M. ERICKSON
DEFENDANTS
TO THE PROTHONOTARY:
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO.: 09-2416 Civil Term
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
PRAECIPE
Please enter judgment in the above captioned proceeding in favor of Members 1"
Federal Credit Union, Plaintiff, and against the Defendants, Richard L. Erickson and
Christine M. Erickson, in the amount of FORTY-NINE THOUSAND ONE HUNDRED
THIRTY-NINE AND 66/100 ($49,139.66) plus interest at the legal rate on and after
entry of judgment until the date of payment, additional attorney's fees and costs of suit
and for foreclosure and sale of the mortgaged property. Judgment is entered pursuant to
Pa. R.C.P. 3031 for failure to file an Answer on behalf of Defendants, Richard L.
Erickson and Christine M. Erickson, to Plaintiff's Complaint within twenty (20) days of
service thereof and after a 10-day Notice was sent.
Respectfully submitted,
Date: May 29, 2009
1
Karl M. Ledeboluri, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
I hereby certify that notices of intent to take default judgment were forwarded to
Richard L. Erickson and Christine M. Erickson by United States Mail, first class, postage
prepaid on May 13, 2009. The aforesaid notices were each contained within an envelope
bearing the return address of the undersigned. The notices have not been returned to the
undersigned as undeliverable or otherwise. A copy of the notice and Postal Forms 3817
are attached hereto and marked Exhibit "A".
M. Ledebohm, Esquire
Karl A Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
RICHARD L. ERICKSON and
CHRISTINE M. ERICKSON
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 09-2416 Civil Term
: CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
IMPORTANT NOTICE
TO: Richard L. Erickson
Christine M. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
Richard L. Erickson
334 North Bedford Street
Carlisle, PA 17013
THIS NOTICE IS FROM A DEBT COLLECTOR PURSUANT TO THE FAIR
DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU
THAT THIS NOTICE AND ANY SUBSEQUENT CORRESPONDENCE OR
COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST
YOU WITHOUT A HEARING, AND YOU MAY LOSE PROPERTY OR OTHER
IMPORTANT RIGHTS. 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.
Exhibit "A"
Date: May 13, 2009
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
Respect By submitted,
Karl M. ed hm, sq.
tSupreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
A •
?' cate Of ? Yx? ¢5
This form may be of .M Certifi
sYirf11pQ provides evi
This fenn may
uaed ldr.domeatlC denc mdlhas been presented to
. er# e that i ,, , C 4F
From: intarnatbnot mail USPS®'
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- Karl M. Ledebohm, Esq.
- P.O. Box 173
- New Cumberland, PA 17070-0173
_ Z
To: ( J m
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PS Form 3817, Apra 2007 PSN 7530-02-000.8065 a
C'emeate Of Ma UM:
This Certificate of Meiling pra?ides evidence that mail has been presented to USP?for M664;
This form mey be used for domestic end intemstional mail. O
From:
- Karl M. Ledebohm, Esq. !l
- P.O. Box 173???'
- New Cumberland, PA 1707d``t? :. -
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From: - Karl M. Ledebohm, Esq. M
P.O. Box 173
- New Cumberland, PA 17070-
RLED-FY
OF THE r
2C0 7il "I 111 3:01
*44_ Po AT
OV,V 4
04 *Vn
Karl K Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Vs.
RICHARD L. ERICKSON and
CHRISTINE M. ERICKSON
DEFENDANTS
: NO.: 09-2416 Civil Term
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
NOTICE OF JUDGMENT
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I
AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY
SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN
ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE
TO: Richard L. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
Christine M. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
Richard L. Erickson
334 North Bedford Street
Carlisle, PA 17013
You are hereby notified that on Qum (s" , 2009 the following
judgment has been entered against you in the above captioned case:
Judgment in the amount of FORTY-NINE THOUSAND ONE HUNDRED
THIRTY-NINE AND 66/100 ($49,139.66) plus interest at the legal rate on and after
entry of judgment until the date of payment, additional attorney's fees and costs of suit
and for foreclosure and sale of the mortgaged property. Judgment is entered pursuant to
s ,
Pa. R.C.P. 3031 for failure to file an Answer on behalf of Defendants, Richard L.
Erickson and Christine M. Erickson, to Plaintiffs Complaint within twenty (20) days of
service thereof and after a 10-day Notice was sent.
Dated:
Ptothonotary
I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236
is: Richard L. Erickson Richard L. Erickson
2 Mooreland Avenue 334 North Bedford Street
Mt. Holly Springs, PA 17065 Carlisle, PA 17013
Christine M. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
A: Richard L. Erickson and Christine M. Erickson
Por este medio se le esta notificando que el de
2009 el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso
mencionado en el epigrafe.
Fecha:
Protonotario
Certifico que la siguiente direccion as la del defendido/a segue indicada en el certificado
de residencia:
Richard L. Erickson Richard L. Erickson
Christine M. Erickson 334 North Bedford Street
2 Mooreland Avenue Carlisle, PA 17013
Mt. Holly Springs, PA 17065
Date: May 29, 2009
Carl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938--9?3?9?1
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. SECTION 101 TO SECTION 149 ETC.
MEMBERS I ST FEDERAL : IN THE COURT OF COMMON PLEAS
CREDIT UNION : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
09-2416 Civil Term
VS. : Amount Due: $49,139.66
Interest from: 6/2/09 at the legal rate
RICHARD L. ERICKSON and
CHRISTINE M. ERICKSON
Defendants
: Attorney's fees: To be added
COSTS TO BE ADDED
TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE
MATTER,
(1) Directed to the Sheriff of Cumberland County, Pennsylvania;
(2) against Richard L. Erickson, 2 Mooreland Avenue, Mt. Holly Springs, PA 17065,
Defendant;
(3) against Christine M. Erickson, 2 Mooreland Avenue, Mt. Holly Springs, PA
17065, Defendant;
(4) and against N/A Garnishee (s);
(5) and index this writ against Richard L. Erickson, 2 Mooreland Avenue, Mt. Holly
Springs, PA 17065, Defendant;
(6) and index this writ against Christine M. Erickson, 2 Mooreland Avenue, Mt. Holly
Springs, PA 17065, Defendant;
(a) against N/A Garnishee (s),
and levy upon and seize the following real property of Defendants and index this
writ against the following real property of Defendants as a lis pendens:
All that certain real estate and improvements erected thereon situate in the
Borough of Mount Holly Springs, Cumberland County, Pennsylvania, known and
numbered as 2 Mooreland Avenue, Mount Holly Springs, PA 17065 and as more
particularly set forth and described on Exhibit "A" attached hereto and made part hereof
by reference.
(b) Exemption has (not) been waived.
Dated: June 29, 2009
) P'??
K 1 M. Le ebohm, Esquire
S reme C urt ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue,
thence along Mooreland Avenue, North one-fourth ( 1/4) degree East, a distance of one
hundred twenty-five (125) feet, more or less, to a point (iron pin), in line of lands now or
formerly of Christian Otto; thence by land now or formerly of the said Christian Otto,
South eighty-nine and three-fourths (89 %) degrees East, a distance of one hundred fifty
(150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moore
Trine, thence along other lands now or formerly of the said Emelyn Moore Trine, South
one-fourth ( 1/4) degree West, a distance of one hundred forty-one (141) feet, more or
less, to a point (iron pin), in the Northern line of West Pine Street; thence along the
Northern line of the said West Pine Street, North eighty-four and one-fourth (84 '/4)
degrees West, a distance of one hundred fifty-one (151) feet to a point, the place of
BEGINNING.
HAVING thereon erected a residence known and numbered as 2 Mooreland Avenue.
BEING the same premises which Thomas E. Clement and Yvonne D. Clement, husband
and wife, by their deed dated July 5, 2002 and recorded July 16, 2002 in Cumberland
County Deed Book 252, page 3531, granted and conveyed unto Richard L. Erickson and
Christine M. Erickson, husband and wife.
EXHBIIT "A"
FILED -CF'l-!011---
i ar TH, :07"Ry
2009 JUL -2 AM 1 ! '. 5"
,'a,51. Op ?j gAA&f
4q. s a C Br
'78 . so
14. oo ••
a. so
-%t [08 •Sa - PD ATTI
41.00 Q?eCo
..SO
c.?
c---g 333L
Rte, ,??7st
!c-u-L es4
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
Vs.
RICHARD L. ERICKSON and
CHRISTINE M. ERICKSON
DEFENDANTS
: NO.: 09-2416 Civil Term
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Members 1St Federal Credit Union, plaintiff in the above action, set forth as of the date
the praecipe for the writ of execution was filed the following information concerning the real
property located in Mount Holly Springs Borough, Cumberland County, Pennsylvania, known
and numbered as 2 Mooreland Avenue, Mt. Holly Springs, PA 17065:
1. Name and address of owner(s) or reputed owner(s):
Richard L. Erickson
Christine M. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
2. Name and address of defendant(s) in the judgment:
Richard L. Erickson
Christine M. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Members 1St Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
4. Name and address of the last recorded holder of every mortgage of record:
Members 1St Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
Nationwide Advantage Mortgage Company
805 Estelle Drive, Suite 101
Lancaster, PA 17604-4454
Nationwide Advantage Mortgage Company
7760 Office Plaza. Drive South
West Des Moines, IA 50266
Nationwide Advantage Mortgage Company
c/o Martha E. Von Rosenstiel, Esquire
649 South Avenue, Unit 7
P.O. Box 307
Secane, PA 19018
5. Name and address of every other person who has any record lien on the property:
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Tenant/Occupant
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
James C. Costopoulos
13 South Hanover Street
Carlisle, PA 17013
Capital One Bank
15000 Capital One Drive
Richmond, VA 23238
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
Date: June 29, 2009
sari M. Ledebohm, Esq.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
OF THE
2009 JAL -2 H I I : 52
cl ill h,:, .. '.??`Y i f
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 s FEDERAL
CREDIT UNION
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Vs.
RICHARD L. ERICKSON and
: NO.: 09-2416 Civil Term
CHRISTINE M. ERICKSON CIVIL ACTION-LAW
DEFENDANTS MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
To: Richard L. Erickson
Christine M. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR PURSUANT
TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO
INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
Your house (real estate) at 2 Mooreland Avenue, Mt. Hollly Springs, PA 17065
as more particularly set forth and described on Exhibit "A" attached hereto and made
part hereof, is scheduled to be sold at Sheriff s Sale on December 9, 2009 at 10:00
a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover
Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of
$49,139.66 plus interest at the legal rate, additional attorney's fees and costs of suit
obtained by the above named Plaintiff against you. In the event the sale is continued,
an announcement will be made at said sale in compliance with Pa.R.C.P. Rule
3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
I . The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the
amount necessary to bring current the mortgage obligation evidenced by the
judgment plus costs and reasonable attorney's fees. To find out how much
you must pay, you may call Karl M. Ledebohm, Esquire, at (717)938-6929.
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also
ask the Court to postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings. You may
need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice below to find out how
to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price bid by calling the Sheriff at the County
Courthouse.
2. You may be able to petition the Court to set aside the sale if the bid price was
grossly inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due
in the sale. To find out if this has happened, you may call the Sheriff at the
County Courthouse, which number is listed below.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to
the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the
Sheriff on January 8, 2010 (within thirty (30) days after the Sheriff Sale).
This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the
proposed distribution is wrong) are filed with the Sheriff within ten (10) days
after the schedule of distribution is filed by the Sheriff.
7. You may also have other rights and defenses, or ways of getting your house
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717)249-3166 or (800)990-9108
The Sheriffs phone number is: (717)240-6390.
marl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue,
thence along Mooreland Avenue, North one-fourth 1/4)
hundred twenty-five (125) feet, more or less, to a point IOdeg ee East, a distance of one pin), in line of lands now
formerly of Christian Otto; thence by land now or formerly of the said Christian Otto, or
South eighty-nine and three-fourths 89 3/4
(150) feet to a point (iron pin) in line of other lands now,orformerl of
Emelmned fifty Moore
Trine, thence along other lands now or formerly of the said Emelyn Moore Trine, South
one-fourth ( 1/4 ) degree West, a distance of one hundred forty-one (141) feet, more or
less, to a point (iron pin), in the Northern line of West Pine Street; thence along the
Northern line of the said West Pine Street, North eighty-four and one-fourth (84 '/4)
degrees West, a distance of one hundred fifty-one (151) feet to a point, the place of
BEGINNING.
HAVING thereon erected a residence known and numbered as 2 Mooreland Avenue
BEING the same premises which Thomas E. Clement and Yvonne D. Clement, husband
and wife, by their deed dated July 5, 2002 and recorded July 16, 2002 in Cumberland
County Deed Book 252, page 3531, granted and conveyed unto Richard L. Erickson and
Christine M. Erickson, husband and wife.
EXHBIIT "A"
RLED
OF THE F,
2 0 0 9 %;';JL -2 ANI 11: 5Z
t ?' 11
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-2416 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION,
Plaintiff (s)
From RICHARD L. ERICKSON and CHRISTINE M. ERICKSON
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $49,139.66 L.L. $.50
Interest from 6/2/09 at the legal rate
Atty's Comm %to be added Due Prothy $2.00
Atty Paid $168.82 Other Costs to be added
Plaintiff Paid
Date: 7/02/09
(Seal)
Curtis R.
Long, P onotary
By:
REQUESTING PARTY: Deputy
Name: KARL M. LEDEBOHM, ESQUIRE
Address: PO BOX 173
NEW CUMBERLAND, PA 17070
Attorney for: PLAINTIFF
Telephone: 717-938-6929
Supreme Court ID No. 59012
'SHE~tIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
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Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
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?^ ~ „ ' 9
Members 1st FCU
vs.
Richard L. Erickson (et al.)
SHERIFF'S RETURN OF SERVICE
Case Number
2009-2416
10/02/2009 12:50 PM -Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09
at 1246 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the
above entitled action, upon the property of Richard L. Erickson and Christine M. Erickson, located a 2
Mooreland Avenue, Mount Holly Springs, Cumberland County, Pennsylvania according to law.
10/02/2009 Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 1246
hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled
action, upon the within named defendant, to wit: Richard L. Erickson, by making known unto, Christine M.
Erickson, wife, at 2 Mooreland Avenue, Mount Holly Springs, Cumberland County, Pennsylvania its
contents and at the same time handing to her personally the said true and correct copy of the same.
10/02/2009 12:50 PM -Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09
at 1246 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above
entitled action, upon the within named defendant, to wit: Christine M. Erickson, by making known unto,
Christine M. Erickson, personally, at 2 Mooreland Avenue, Mount Holly Springs, Cumberland County,
Pennsylvania its contents and at the same time handing to her personally the said true and correct copy o1
the same.
1 2/0 812 0 0 9 Property sale postponed to 3/3/2010.
03/02/2010 Property sale postponed to 4/7/2010.
04/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned
STAYED, per letter of instruction from Attorney Ledebohm on 4/5/10
SHERIFF COST: $767.96 SO ANSWERS,
April 06, 2010 RON r R ANDERSON, SHERIFF
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Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)93 8-6929
MEMBERS 1 ~ ` FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
RICHARD L. ERICKSON and
CHRISTINE M. ERICKSON
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 09-2416 Civil Term
CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Members 1 S` Federal Credit Union, plaintiff in the above action, set forth as of the date
the praecipe for the writ of execution was filed the following information concerning the real
property located in Mount Holly Springs Borough, Cumberland County, Pennsylvania, known
and numbered as 2 Mooreland Avenue, Mt. Holly Springs, PA 17065:
1. Name and address of owner(s) or reputed owner(s):
Richard L. Erickson
Christine M. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
2. Name and address of defendant(s) in the judgment:
Richard L. Erickson
Christine M. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
C~Op~
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Members 1St Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
4. Name and address of the last recorded holder of every mortgage of record:
Members 1St Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
Nationwide Advantage Mortgage Company
805 Estelle Drive, Suite 101
Lancaster, PA 17604-4454
Nationwide Advantage Mortgage Company
7760 Office Plaza Drive South
West Des Moines, IA 50266
Nationwide Advantage Mortgage Company
c/o Martha E. Von Rosenstiel, Esquire
649 South Avenue, Unit 7
P.O. Box 307
Secane, PA 19018
5. Name and address of every other person who has any record lien on the property:
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
TenanUOccupant
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
James C. Costopoulos
13 South Hanover Street
Carlisle, PA 17013
Capital One Bank
15000 Capital One Drive
Richmond , VA 23238
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
Date: June 29, 2009
Respectful) submitted,
earl M. Ledebohm, Esq.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(7] 7)938-6929
Attorney for Plaintiff
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)93 8-6929
MEMBERS 1J' FEDERAL
CREDIT UNION
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
Vs.
RICHARD L. ERICKSON and
CHRISTINE M. ERICKSON
DEFENDANTS
NO.: 09-2416 Civil Term
CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
To: Richard L. Erickson
Christine M. Erickson
2 Mooreland Avenue
Mt. Holly Springs, PA 17065
THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT
TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO
INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT
CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
Your house (real estate) at 2 Mooreland Avenue, Mt. Hollly Springs, PA 17065
as more particularly set forth and described on Exhibit "A" attached hereto and made
part hereof, is scheduled to be sold at Sheriff's Sale on December 9, 2009 at 10:00
a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover
Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of
$49,139.66 plus interest at the legal rate, additional attorney's fees and costs of suit
obtained by the above named Plaintiff against you. In the event the sale is continued,
an announcement will be made at said sale in compliance with Pa.R.C.P. Rule
3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the
amount necessary to bring current the mortgage obligation evidenced by the
judgment plus costs and reasonable attorney's fees. To find out how much
you must pay, you may call Karl M. Ledebohm, Esquire, at (717)938-6929.
2. You may be able to stop the sale by filing a petition asking the Court to strike
or open the judgment, if the judgment was improperly entered. You may also
ask the Court to postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings. You may
need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice below to find out how
to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
If the Sheriff's Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price bid by calling the Sheriff at the County
Courthouse.
2. You may be able to petition the Court to set aside the sale if the bid price was
grossly inadequate compared to the value of your property.
The sale will go through only if the buyer pays the Sheriff the full amount due
in the sale. To find out if this has happened, you may call the Sheriff at the
County Courthouse, which number is listed below.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to
the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the
Sheriff on January 8, 2010 (within thirty (30) days after the Sheriff Sale).
This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the
proposed distribution is wrong) are filed with the Sheriff within ten (10) days
after the schedule of distribution is filed by the Sheriff.
7. You may also have other rights and defenses, or ways of getting your house
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717)249-3166 or (800)990-9108
The Sheriff s phone number is: (717)240-6390.
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earl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALL THAT CERTAIN lot of ground situate in the Borough of Mount Holly Springs,
Cumberland County, Pennsylvania, bounded and described as follows:
BEGINNING at a point at the intersection of West Pine Street and Mooreland Avenue,
thence along Mooreland Avenue, North one-fourth ('/4) degree East, a distance of one
hundred twenty-five (125) feet, more or less, to a point (iron pin), in line of lands now or
formerly of Christian Otto; thence by land now or formerly of the said Christian Otto,
South eighty-nine and three-fourths (89 3/4) degrees East, a distance of one hundred fifty
(150) feet to a point (iron pin) in line of other lands now or formerly of Emelyn Moore
Trine, thence along other lands now or formerly of the said Emelyn Moore Trine, South
one-fourth ('/4) degree West, a distance of one hundred forty-one (141) feet, more or
less, to a point (iron pin), in the Northern line of West Pine Street; thence along the
Northern line of the said West Pine Street, North eighty-four and one-fourth (84 '/4)
degrees West, a distance of one hundred fifty-one (151) feet to a point, the place of
BEGINNING.
HAVING thereon erected a residence known and numbered as 2 Mooreland Avenue.
BEING the same premises which Thomas E. Clement and Yvonne D. Clement, husband
and wife, by their deed dated July 5, 2002 and recorded July 16, 2002 in Cumberland
County Deed Book 252, page 3531, granted and conveyed unto Richard L. Erickson and
Christine M. Erickson, husband and wife.
EXHBIIT "A"
• ~ WRIT OF EXECUTION and/or ATTACHMENT
COI~iMONWEALTH OF PENNSYLVANIA) NO 09-2416 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION,
Plaintiff (s)
From RICHARD L. ERICKSON and CHRISTINE M. ERICKSON
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $49,139.66
Interest from 6/2/09 at the legal rate
Atty's Comm %to be added
L.L. $.50
Due Prothy $2.00
Atty Paid $168.82
Plaintiff Paid
Date: 7/02/09
(Seal)
Other Costs to be added
Curtis R. Long, Protho otar
By:
Deputy
REQUESTING PARTY:
wrame: KARL M. LEDEBOHM, ESQUIRE
Address: PO BOX 173
NEW CUMBERLAND, PA 17070
Attorney for: PLAINTIFF
Telephone: 717-938-6929
Supreme Court ID No. 59012
Real Estate Sale #
On August 19, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
Borough of Mount Holly Springs, Cumberland County, PA
Known and numbered as, 2 Mooreland Avenue,
Mount Holly Springs, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: August 19, 2009
By:
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 23, October 30 and November 6, 2009
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
~-
sa Marie Coyne, Ed' or
SWORN TO AND SUBSCRIBED before me this
6 day of November, 2009.
~~ ,lid ,~ L`--~, /~'~~.u.~~
Notary _____
~~-~N07ARIAL SEAL
DEBORAH A COLLINS
~iotary Public
CARLISLE BORO, CUMBERLAND COUPJN
My Commiss!on Expires Apr 28, 2010
Writ No. 2009-2416 Civil
Members ls~ Federal Credit Union
vs.
Richard L. Erickson
Christine M, Erickson
Atty: Karl M. Ledebohm
ALL THAT CERTAIN lot of ground
situate in the Borough of Mount Holly
Springs, Cumberland County, Penn-
sylvania, bounded and described as
follows:
BEGINNING at a point at the
intersection of West Pine Street and
Mooreland Avenue, thence along
Mooreland Avenue, North one-fourth
(1/4) degree East, a distance of one
hundred twenty-five (125) feet, more
or less, to a point (iron pin), in line
of lands now or formerly of Christian
Otto; thence by land now or formerly
of the said Christian Otto, South
eighty-nine and three-fourths (89
3/4) degrees East, a distance of one
hundred fifty (150) feet to a point
(iron pin) in line of other lands now
or formerly of Emelyn Moore Trine,
thence along other lands now or
formerly of the said Emelyn Moore
Trine, South one-fourth (V4) degree
West, a distance of one hundred
forty-one (141) feet, more or less, to
a point (iron pin), in the Northern
line of West Pine Street; thence along
the Northern line of the said West
Pine Street, North eighty-four and
one-fourth (84 '/4) degrees West, a
distance of one hundred fifty-one
(151) feet to a point, the place of
BEGINNING.
HAVING thereon erected a resi-
dence known and numbered as 2
Mooreland Avenue.
BEING the same premises which
Thomas E. Clement and Yvonne D.
Clement, husband and wife, by their
deed dated July 5, 2002 and recorded
July 16, 2002 in Cumberland County
Deed Book 252, page 3531, granted
and conveyed unto Richard L. Er-
ickson and Christine M. Erickson,
husband and wife.
she Patriot-News Co.
812 Market St.•
Harrisburg, PA 17101
Inquiries - 717-255-8213
c~he ~latriot-News
Now you know
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Leslie Kramer, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is
interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time,
place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
i
.*
`Sworn to and subscribed before me this 16 d o~ovember, 2009 A.D.
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Notary Public
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_ Ex,~;t No+r. 26, 2011
SOCI~'i~t'Sf~i of ~O`t8ff@~
10/23/09
10/30/09
11 !06109
Writ No. 2009-2416 Civil Term
Members 1st Federal Credit
Union
Vs
Richard L. Erickson
Christine M. Erickson
Arty: Karl M. Ledebohm
ALL THAT CERTAIN lot of ground situate in
the Borough of Mount Holly Springs,
Cumberland County, Pennsylvania, bounded and
described as follows:
BEGINNING at a point at the intersection of
West Pine Street and Mooreland Avenue, thence
along Mooreland Avenue, North one-fourth (1/4
)degree East, a distance of one hundred twenty-
five (125) feet, more or less, to a point (iron
pin), in line of lands now or formerly of
Christian Otto; thence by land now or formerly
of the said Christian Otto, South eighty-nine and
three-fourths (89 3!4) degrees East, a distance of
one hundred fifty (150) feet to a point (iron pin)
in line of other lands now or formerly of Emelyn
Moore Trine, thence along other lands now or
formerly of the said Emelyn Moore Trine, South
one-fourth (V4) degree West, a distance of one
hundred fogy-one (141) feet, mote or less, to a
point. (iron pin), id the Northam line of West
Pine Street; thence along the NorWem line or
tlx said West Pine Street, North eighty-fow and
one-fourth (84 `l4) degrees West, a distance of
one hundred fifty-one (151) feet to a point, the
place of BEGINNING.
HAVING thereon erected a residence known and
numbered as 2 Mooreland Avenue.
BEING the same ,premises which Thomas E.
Clement and Yvonne D. Clement, husband
and wife, by their deed dated July 5, 2002 and
recorded July 16, 2002in Cumberland
County Deed Book 252, page 3531, granted and
conveyed unto Richard L. Erickson and
Christine M. Erickson, husband and wife.