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HomeMy WebLinkAbout09-28100/ McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 /)E=DWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania 961 Weigel Drive Elmhurst, Illinois 60126 V. Jason P. Rhoads 1058 Centerville Road Newville, Pennsylvania 17241 Jennifer R. Rhoads 1058 Centerville Road Newville, Pennsylvania 17241 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 04' a7 l d pi-VI, T-1 rm CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 CIVIL ACTION/MORTGAGE FORECLOSURE Plaintiff is Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Jason P. Rhoads, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 1058 Centerville Road, Newville, Pennsylvania 17241. 3. The Defendant is Jennifer R. Rhoads, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 1058 Centerville Road, Newville, Pennsylvania 17241. 4. On December 26, 2006, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1977, Page 3796. 5. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 1058 Centerville Road, Newville, Pennsylvania 17241. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due November 1, 2008 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance $ 114,036.30 Interest through April 30, 2009 $ 6,953.60 (Plus $32.80 per diem thereafter) Attorney's Fee $ 1,250.00 Late Charges $ 686.47 Corporate Advance $ 12.50 GRAND TOTAL $ 122,938.87 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $122,938.87, together with interest at the rate of $32.80 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CC@T;Vj-A*y.C. BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiff, who is not available to sign this, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEIS_BFgG AND CON3KI ,Y,P.C. BY: Attorneys`Ibr Plaintiff TERRENCE J. McCABE, ESQUII MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUII MARGARET GAIRO, ESQUIRE This instrument was prepared by: NANCY J DITZEL (Name) 419 VILLAGE DR STE 2 CARLISLE, PA. 17015 (Address) Return To: Records Processing Services 577 Lamont Road Elmhumt,IL 60126 (800) 547-8776 UPl # 31-38-2618-004 .7!ES't.-R E 2%. E ZW6 MIC 29 AM to Os 711715 MORTGAGE IF BOX IS CHECKED, THIS MORTGAGE IS AN OPEN-END MORTGAGE AND SECURES FUTURE ADVANCES. THIS MORTGAGE is made this day 28TH of DECEM13M 2006 , between the Mortgagor, JASON P. RHOADS AND JEW I FER I DS , BENEFICIAL WATBAOE CO 418 VILLAGE DRIVE, SUITE 2, CARLISLE, PA TI Brain The following paragraph preceded by a checked box is applicable. X WHEREAS, Borrower is indebted to Lender in the principal sum of $ - 11f; M-97 evidenced by Borrowers Loan Repayment and Security Agreement or gage Loan Agreement dated nECEMSM 24- and any extensions or renewals thereof (herein "Note"), providing or monthly installments o pri c al and interest, including any adjustments to the amount of payments or the contract rate if that rate is variable, with the balance of the indebtedness, if not sooner paid, due and payable on nFea g 9a 2= WHEREAS, Borrower is indebted to Lender in the principal sum of S or so much thereof as may be advanced pursuant to Borrower's Revolving-T.oanment and extensions and renewals thereof (herein "Note"), providing for mon y i ments, an ,merest at the rate and under the terms specified in the Note, including any adjustments in the interest rate if that rate is variable, and providing for a credit limit stated in the principal sum above and an initial advance of $ TO SECURE to Lender the repayment of (1) the indebtedness evidenced by the Note, with interest thereon, including any increases if the contract rate is variable; (2) future advances under any Revolving Loan Agreement; (3) the payment of all other sums, with interest thereon, advanced in accordance herewith to protect the security of this Mortgage; and (4) the performance of the covenants and agreements of Borrower herein contained, Borrower does hereby mortgage, grant and convey to Lender and Lender's successors and assigns the following described property located in the County of CUMBERLAND Commonwealth of Pennsylvania: SEE EXHIBIT A-LEGAL DESCRIPTION "R651C98P5A93MT08000PA001301W"HOAM M ORIWAL 11-11-05 MTG PA001301 BIB 1977PG3796 Exhibit A -2- TOGETHER with all the improvements now or hereafter erected on the property, and all easements, rights, appurtenances and rents, all of which shall be deemed to be and remain a part of the property covered by this Mortgage; and all of the foregoing, together with said property (or the leasehold estate if this Mortgage is on a leasehold) are hereinafter referred to as the *Property.* Borrower covenants that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property, and that the property is unencumbered, except for encumbrances of record. Borrower covenants that Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to encumbrances of record. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower shall pay when due the principal of, and interest (including any variations in interest resulting from changes in the Contract Rate that may be specified in the Note) on, the debt evidenced by the Note and any prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due under the Note and this Security Instrument shall be made in U.S. currency. However, if any check or other instrument received by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender. (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 12. Lender may return any payment or partial payment if the payment or partial payments are insufficient to bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not applied artier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2 or as may be required by the Note and/or applicable law, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment 11-11-05 MTG "RGSiCSSF5A83WrG$000PA00130200M*i 110S ¦ ORIGINAL PA001302 BKI977PG3797 -3- and the late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in full. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic payments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day Peridic Payments are due under the Note, until the Note is paid in full, a sum (the "Funds") to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Lender under Section S; and (d) Mortgage Insurance premiums, if any. These items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association Dues, Fees, and Amsessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be doomed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is used in Section 7. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 7 and pay such amount and Borrower shall then be obligated under Section 7 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 12 and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are then required under this Section 3. Lander may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et.seq.) and its implementing regulation, Regulation X (24 C.P.R. Part 33000, as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this security instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage loan" even if the loan does not qualify as a "federally related mortgage loan" under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) 11-11-05 MTG "R551C98F5A93WFGS000PA0013030mRHOA03 ORIGINAL PA001303 BK1977PG3798 ` :', -4- or in any Federal Home Loan Bank. Lender shill apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow amount, or verifying the Escrow Items, unless Lander pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds u required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in a corda= with RESPA. If there is a shortage of Funds held in eser»w, as defined under RESPA, Lowder shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Prior Mortpges and Deed of Trust; Charges; Liens. Borrower shall perform all of Borrower's obligations under any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage, including Borrower's covenants to make payments when due. Borrower shall pay or cause to be paid all taxes, awasernents and other charges, fines and impositions attributable to the Property which may attain a priority over this Mortgage, and lessehold payments or ground rents, if any. 5. Hazard Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and such other hazards as Lender may require. The insurance carrier providing the insurance shall be chosen by the Borrower subject to approval by Lender; provided, that such approval shall not be unreasonably withheld. All insurance policies and renewals thereof shall be in a form acceptable to Lender and shall include a standard mortgage clause in favor of and in a form acceptable to Lender. Lender shall have the right to hold the policies and renewals thereof, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage. In the event of loss. Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loos if not made promptly by Borrower. If the Property is abandoned by Borrower, or if Borrower fails to respond to Lender within 30 days from the date notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for insurance benefits, Loader is authorized to collect and apply the insurance proceeds at Lender's option either to restoration or repair of the Property or to the sums secured by this Mortgage. 6. Preservation and Maintenance of Property; Leaseholds; Condominiums; Planned Unit Developments. Borrower shall keep the Property in good repair and shall not commit waste or permit impairment or deterioration of the Property and shall comply with the provisions of any lase if this Mortgage is on a leasehold. If this Mortgage is on a unit in a condominium or a planned unit development, Borrower shall perform all of Borrower's obligations under the declaration or covenants creating or 11-11-05 MTG PA001304 NRO51COIFSA93ROI000PAO013040mgN* W " ORIGINAL BK 1977PG3799 governing the condominium or planned unit development, the by-laws and regulations of the condominium or planned unit development, and constituent documents 7. Protection of Leader's security. H Borrower fails to perform the covenants and agreements contained in this Mortgage, or if any action or proceeding is commer"d which materially affecta Lender's interest in the Property, then Lender, at Lender's option, upon notice to Borrower, may mate such appearances, disburse such sums, including reasonable attorneys' fens, and takesuch action as is necessary to protect Lender's interest. Any amounts disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the contract rate, shall become additional indebtedness of Borrower secured by this Nbrtgage. Unless Borrower and Lender agree to other terms of payment, such amounts shall be payable upon notice from Lender to Borrower requesting payment thereof. Nothing contained in this paragraph 7 shall require Lender to incur any expense or take any action hereunder. 8. Inspection. Lender may take or cause to be made reasonable entries upon and inspections of the property, provided that Lender shall give Borrower notice prior to any such inspection specifying reasonable cause therefor related to Lender's interest in the Property. 9. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in lieu of condemnation, are herby assigned and atoll be paid to Lender, subject to the terms of any mortgage, deed of trust or other security agreement with s lien which has priority over this Mortgage. 10. Borrower Not Released; Forbearance By Leader Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Mortgage granted by Lender to any successor in interest of Borrower shall not operate to reuse. in any manner, the liability of the original Borrower and Borrower's succemors in interest. Lender shall not be required to commence proceedings against such successor or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Mortgage by reason of any demand made by the original Borrower and Borrower's si1c00MMOre in interest. Any forbearance by Lender in exercising any right or remedy hereunder, or otherwise afforded by applicable law, shall not be a waiverof or preclude the ezercise of any such right or remedy. 11. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements herein contained shall bind, and the rights hereunder shall inure to, the respective successors and assign a of Lender and Borrower, subject to the provisions of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and several. Any Borrower who co-signs this Mortgage, but does not execute the Note, (a) is co-signing this Mortgage only to mortgage, grant and convey that Borrower's interest in the Property to Lender under the terms of this Mortgage, (b) is not personally liable on the Note or under this Mortgage, and (c) agrees that Lender and any other Borrower hereunder may agree to extend, modify, forbear, or make any other accommodations with regard to the terms of this Mortgage or the Note without that Borrower's consent and without releasing that Borrower or modifying this Mortgage as to that Borrower's interest in the Property. 12. Notice. Except for any notice required under applicable law to be given in another manner, (a) any notice to Borrower provided for in this Mortgage shall be given by delivering it or by mailing such notice by certified mail addressed to Borrower at the Property Address or at such other address as Borrower may designate by notice to Lender as provided herein, and (b) any notice to Lender shall be gives by certified mail to Lender's address stated herein or to such other address as Leader may designate by notice to Borrower as provided herein. Any notice provided f or in this Mortgage shall be deemed to have been given to Borrower or Lender when given in the manner designated herein. 13. Governing Low; Sevaability. The applicable law contained in the Note shall control. Where no applicable law is contained therein, the state and local laws applicable to this Mortgage shall be the laws of the jurisdiction icability 11-11-05 -S- Bi 1977PG3800 (i NR651COIFSA83MTGSOOBPA0013050muRN0ADS " ORIOIML of Federal law to this Mortgage. In the event that any provision or clause of this Mortgage or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Mortgage or the Note which can be given effect without the conflicting provision, and to this and the provisions of this Mortgage and the Note are declared to be severable. As used herein, "costa," "expenses" and "attorneys' fees" include all sums to the extent not prohibited by applicable law or limited herein. 14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this Mortgage at the time of execution or after recordation hereof. 1 S. Rehabilitation Loss Agreement. Borrower shall fulfill all of Borrower's obligations under any home rehabilitation. improvement, repair, or other loan agreement which Borrower enters into with Lender. Lender, at Lender's option, may require Borrower to execute and deliver to Lender, in a form acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against parties who supply labor, materials or services in connection with improvements made to the Property. 16. Transfer of the Property. If Borrower sells or transfers all or any part of the Property or an interest therein, excluding (a) the creation of a lien or encumbrance subordinate to this Mortgage, (b) a transfer by devise, descent, or by operation of law upon the death of a joint tenant, (c) the grant of any leasehold interest of three years or lees not containing an option to purchase, (d) the creation of a purchase money security interest for household appliances, (e) a transfer to a relative resulting from the death of a Borrower, (f) a transfer where the spouse or children of the Borrower become an owner of the property, (g) a transfer resulting from a decree of dissolution of marriage, legal separation agreement, or from an incidental property settlement agreement, by which the spouse of the Borrower becomes an owner of the property, (h) a transfer into an inter vivos trust in which the Borrower is and remains a beneficiary and which does not slate to a transfer of rights of occupancy in the property, or (i) any other transfer or disposition described in regulations prescribed by the Federal Home Loan Bank Board, Borrower shall cause to be submitted information required by Lender to evaluate the tramteree as if a new loan were being made to the transferee. Borrower will continue to be obligated under the Note and this Mortgage unless Lender releases Borrower in writing. If Lender does not agree to such sale or transfer, Lender may declare all of the sums secured by this Mortgage to be immediately due and payable. If Lender exercises such option to accelerate, Lender shall mail Borrower notice of acceleration in accordance with paragraph 12 hereof. Such notice shall provide a period of not less than 30 days from the date the notice is mailed or delivered within which Borrower may pay the sums declared due. If Borrower fails to pay such sums prior to the expiration of such period, Lander may, without further notice or demand on Borrower, invoke any remedies permitted by paragraph 17 hereof. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Acceleration; Remedies. Except as provided in paragraph 16 hereof, upon Borrower's breach of any covenant or agreement of Borrower in this Mortgage, including the covenants to pay when due any sums secured by this Mortpge, Lender prior to acceleration shall give notice to Borrower as provided in paragraph 12 hereof specifying: (1) the breach; (2) the action required to can such breach; (3) a date, not less than 30 days from the date the notice is mailed to Borrower, by which such breach must be cored; and (4) that failure to corn such breach on or before the date specified in the notice may molt in acceleration of the sums secured by this Mortgage, foreclosure by judicial proceeding, and sale of the Property. The 11-11-06 MTG mR651C98F5A93MTOODOOPA0013050xMR MM " ORIGIM 8t 1977PG380 I PA001306 -7- notice shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the nonexistence of a default or any other defense of Borrower to acceleration and foreclosure. U the breach is not cured on or before the date specified in the notice, Lender, at Leader's option, may declare all of the sums secured by this Mortgage to be immediately due and payable without further demand and may foreclose this Mortgage by judicial proceeding. Lender shall be entitled to collect in such proceeding all expenses of foreclosure, including, but not limited to, reasonable attorneys' fees and costs of documentary evidence, abstracts and title reports. 18. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums by this Mortgage due to Borrower's breech, Borrower shall have the right to have any proceedings begun by Lender to enforce this Mortgage discontinued at any time prior to entry of a judgment enforcing this Mortgage if: (a) Borrower pays Leader all sums which would be then due under this Mortgage and the Note had no acceleration occurred; (b) Borrower cures all breaches of any other covenants or agreements of Borrower contained in this Mortgage; (c) Borrower pays all reasonable ezp mm incurred by Lender in enforcing the covenants and agreements of Borrower contained in this Mortgage, and in enforcing Lender's remedies as provided in paragraph 17 hereof, including, but not limited to, reasonable attorneys' loos; and (d) Borrower takes such action as Loader may reasonably require to assure that the lien of this Mortgage, Lender's interest in the Property and Borrower's obligation to pay the sums secured by this Mortgage shall continue unimpaired. Upon such payment and cure by Borrower, this Mortgage and the obligations secured hereby shall remain in full force and effect as if no acceleration had occurred. 19. Assignment of Rents; Appointment of Receiver. As additional security hereunder, Borrower hereby assigns to Lender the rents of the Property, provided that Borrower shall, prior to acceleration under paragraph 17 hereof, in abandonment of the Property, have the right to collect and retain such rents as they become due and payable.. Upon acceleration under paragraph 7 hereof or abandonment of the Property, Leader shall be entitlod to have a receiver appointed by it court to enter upon, take possession of and manage the Property and to collect the rents of the•'Property including those past due. All rents collected by the receiver shall be applied first to plymedt of. the costs of management of the Property and collection of rents, including, but not limited to, receiver's fees, premiums on receiver's bonds and reasonable attorneys' fees, and then to the sums secured by this Mortgage. The receiver shall be liable to account only for those rents actually received. 20. Release. Upon payment of all sums secured by this Mortgage, Leader shall release this Mortgage without charge to Borrower. Borrower shall pay all costa of recordation, if any. 21. Waiver of Homestead. Borrower hereby waives all right of homestead exemption in the Property under state or Federal law. 22. Interest Rate After Judgment. Borrower agrees the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate stated in the Note. 23. Arbitration Rider to Note. The Arbitration Rider attached to and made a part of the Note is hereby incorporated by reference and made a part of this Mortgage. 11-11-05 afro PA001307 ¦RIS1COOFSA93MT000OOPA0019010"NRNOADS ORIGINAL BKI977PG3802 J . . -8- REQUEST FOR NOTICE OF DEFAULT AND FORECLOSURE UNDER SUPERIOR MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a lien which has priority over this Mortgage to give Notice to Leader, at Lender's address at forth on page one of this Mortgage, of any default under the superior encumbrame and of any sale or other foreclosure action. JASON P RHOADS - Borrower ENI!fI R RHOADS -Borrower I hereby certify that the precise address of the Lender (Mortgagee) is: 419 VILLAGE DRI SUIT 2 E PA. 17015 On behalf of the Lender. By: NANCY DITZEL Title: S.A. COMMONWEALTH OF PEANS*VANI10 CUK$BLAIM Count' am 11 FLORA M VOGT a Notary Public in and for said county and state, do hereby corn y t t JASON P RHOAD AND J IF R RHOADS personally known to me or proven Batt soon y to be the same parent s wbose namets) ARE subscribed to the foregoing instrument, appeared before me this day in person, and acknow t The Y signed and delivered the said instrument as THEIR free voluntary ac7t or tge uses and purposes therein set forth. Given under my hand and official seal, this 26TH day of DECEMMR ?_SZfL• My Commission expires: N0100 92d Flora K V09, NaW- jr Pd ft Nofi MaMl W Twp., GW*ft %l AAll CormtwWn eon Mr/ 21. 210 M VOGT Men* r. PNnlaovanW Assodow of Notada COMMONWEALTH OF PENNSYLVANIA, County ss: I, a Notary Public in and for said county and state, do hereby certa y at personally known to me or proven sa actors y to the same person(s) whose name e subscribed to the foregoing instrurent, appeared before me this day in person, and acknow ge t at he signed and delivered the said instrument as free voluntary act, Tor the Rases and purposes therein set forth. Given under my hand and official seal, this day of , M-. My Commission expires: Notary Public PA001309 11-11-05 MTG ¦R651C$BF5A93MT06000PA0013060NMO OM M ORIGIM 8K 1977PG3803 9- (Specs Below This Line Reserved Por Lender and Recorder) 11-11-05 MTG PA001309 KRO51C9/F5A83 rOE000PA001909OmIF4i AQS M ORIOIW4L Ov 1977PG3804 EXHIBIT A (PAGE 1) ALL THAT CERTAIN PROPERTY SITUATED IN THET0111IN9HIP OF PENN IN THE COUNTY OF CUMBERLAND AND C0114011111EALTH OF PEN SYLVAN I A. BEING MORE FULLY DESCRIBED IN A DEED DATED 07/30/2004 AND RECORDED 08/04/2004, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN DEED VOLUME 284 AND PAGE 2868. TAX MAP OR PARCEL ID NO.: 31-38-2818-004 (71 ry this to be recorded l_jrnberland County PA - Recorder of Deeds "R651C99F5A93AR09000FA0013000mq*GADS ¦ ORIGINAL 8KI977PG3805 OF -HE't -?CTARY 21A9 MAY -5 AM II * 33 want c #- M)[--?6 /-? fick 4alo-N Sheriffs Office of Cumberland County R Thomas Kline ?'J" 0 ?Inflb"r" Edward L Schorpp Sheriff$ Solicitor Ronny R Anderson Jody S Smith Chief Deputy C!IF2C? 7HE S,-EP'Fr Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/29/2009 05:15 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on May 29, 2009 at 1715 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jason P. Rhoads, by making known unto Jennifer R. Rhoads, wife of defendant at 1058 Centerville Road Newville, Cumberland County, Pennsylvania 17241 its contents and a the same time handing to her personally the said true and correct copy of the same. 05/29/2009 05:15 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on May 29, 2009 at 1715 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jennifer R. Rhoads, by making known unto herself personally, defendant at 1058 Centerville Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. SO ANSWERS, SHERIFF COST: $54.80 June 01, 2009 "4 R TH FIIN',SHERIFF c De S 2009-2810 Beneficial Consumer Discount V Jason & Jennifer Rhoads F