HomeMy WebLinkAbout09-6146Karl M. Ledebohni, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
ROY G. REEDER
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
: PENNSYLVANIA
NO. 09 - (014(0 0'i'V-1 L (P,IrM
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
NOTICE TO DEFEND AND CLAIM RIGHTS
TIES 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 paginas 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 demands. USTED PUEDE PERDER DINERO O OTROS
DERECHOS MORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O
LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166 OR (800)990-9108
Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070
MEMBERS 1 IT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
ROY G. REEDER
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
NO.: 0 9. 4 ? q Cc? K P T?
DEFENDANT : CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
COMPLAINT
AND NOW, comes Members 1" Federal Credit Union, the Plaintiff in the above
captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the
following complaint:
I
1. Plaintiff, Members 1 St Federal Credit Union ("Members 1 St")is a National
Federal Credit Union having a principal address of 5000 Louise Drive,
Mechanicsburg, PA 17055.
2. Roy G. Reeder, ("Defendant'), is an adult individual having a last known
address of 113 Kline Road, Shippensburg, PA 17257.
3. On or about June 6, 2006, Defendant borrowed from and agreed to repay to
Members 1 s' NINETY-FIVE THOUSAND AND 00/100 ($95,000.00) dollars
(the "Loan"). The Loan is evidenced by a Closed-End Note, Disclosure, Loan
and Security Agreement dated June 6, 2006 (the "Note") executed and
delivered to Members 1St by Defendant. A copy of the Note is attached hereto
as Exhibit "A" and made part hereof.
4. As security for the Loan, Defendant executed and delivered to Members 1St a
mortgage ("Mortgage") also dated June 6, 2006, on all that certain real estate
and improvements erected thereon situate in Southampton Township,
Cumberland County, Pennsylvania, known and numbered as 113 Kline Road,
Shippensburg, PA 17257 (the "Property"). At all times relevant hereto,
Defendant has been and continues to be the record and sole owner of the
Property. A description of the Property is attached hereto as Exhibit "B" and
made part hereof.
5. On or about July 7, 2006, the Mortgage was recorded in the Cumberland
County Recorder of Deeds Office at Mortgage Book 1957, Page 2904. A true
and correct copy of the Mortgage is attached hereto as Exhibit "C" and made
part hereof.
2
6. The Note and the Mortgage have never been assigned by Members 1 St and
remain held by it as a valid and subsisting obligation of Defendant.
7. Pursuant to the terms and conditions of the Note, Defendant agreed to pay to
Members 1St monthly installments of principal and interest in the amount of at
least $1,214.07 each, which amount was subsequently adjusted to $1,212.86
each, beginning on July 16, 2006 and continuing on or before the 16th of each
month thereafter.
8. Defendant is in default of Defendant's obligations under the Note as a result
of Defendant's failure to make the monthly payments due to Plaintiff as set
forth in the Note in the amount of $1,212.86 each for the months of May
through August, 2009, as set forth in the Note and as more particularly set
forth and described, in part, in the Act 91 Notice attached hereto as Exhibit
"D" and made part hereof.
9. 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 Defendant's rights in accordance with
the Homeowners' Emergency Mortgage Assistance Act, Act of December 23,
1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. set by letter dated
July 17, 2009, addressed to Defendant via certified mail, return receipt
requested. A copy of the said notice is attached hereto as Exhibit "D" and
made part hereof.
10. US Postal form 3877 evidencing the mailing of said Notices is attached hereto
as Exhibit "B" and made part hereof.
II
12
Simultaneously, Members 1St forwarded to Defendant the same Notices as set
forth in paragraph 9 above addressed to Defendant by United States mail, first
class, postage prepaid, bearing the return address of Members I st. The Notices
forwarded to Defendant in said manner have not been returned to the offices
of Members I St as undeliverable or otherwise.
As of September 8, 2009, Defendant is indebted to Members 1St in the amount
of EIGHTY-THREE THOUSAND THREE HUNDRED TWO and 581100
($83,302.58) dollars itemized as follows:
a. Outstanding principal $77,737.41
b. Interest to September 8, 2009 2,822.61
c. Late fees 242.56
d. Attorney fees 2,500.00
e. Total due to Members 1St as of 9/8/2009 $83,302.58
The above attorney's fees and expenses are estimated through sheriff sale and
are in accordance with Defendants' agreements as set forth in the underlying
Mortgage and the Note. If the Mortgage is reinstated prior to a Sheriff's Sale,
the attorney's fees and expenses set forth above may be less or more than the
amount demanded above based upon work actually performed. Defendants
will be responsible for actual reasonable attorney's fees incurred by Members
1St in this matter subject to any limitation contained in the Note.
4
St 1? A -ll$QYA[.RFFMFNT
5000 Louisa Drive, P.O. Box 40 RO
ROY MRS /MME AND ADDRESS
G REEDE R
Mechanicsburg. PA 17055 11 UNE RD
I
I P
A/7257
MEMBER,S1" ?
?
.x• ,.a - 2 4-01
W ROIREWS NAME
0.14%
.9ii ACAMOUM C08 MROIAERS NAME
VARIABLE
ANNUAL PERCENTAGE FINANCE CHARGE: Amount Finance d: The amount of Total of Payments: The amount
RATE: The cost of your credit as a The dollar amound the credit will credt provided t o you or on your you will have paid star you have
yearly rate. • Coat you. behalf. made all payments as scheduled.
9.14 % s t 50,666.68 • $ 05.000.00 a S 145,686.68
Variable Rate: If your ban lees a vark" cots es Indicated above go Annual PWOW"pe Rata may Increase dtrl o ale tam of this transaction R the (index) changes. The
aedti union will add • margin of to the index valve. The rata will change monthly an the Note day d fM month. T he rata will row be higher than 1M maxknum rate allowed by
law, and k rw never W lass Nan . Any Ieaest rate baeslas willresult b more payments of the wore emoua. dr Example. Y your ban was for $5,000 of 15% for 41
months and be Annual Percentage Rate increesed by 2% alter an year. ale farm of your loon would increase by months
Prelerr.d Rale: m reweke4 tl>t baow'srg appiea n your ban:
m Automatk P,ymerd Dleeounud Ran: BaW es you have apnea b make yw required rrnenth1l'
Aaaxd
Yw+r ANNUAL PERCENTAGE RATE hell Wen dfeaoumad b
YO%
TM ANNWIL PERCENT, RA
through an adornefk deduction mom {roar Checkk115"'I tgs
disclosed son
i
ANN
NT
th
A
P
R
RA
.
y .
.
the Auromrrae Mymlw Dllcotaead Rare, TNa Me will Ytcrea,e by .2f>%N you aw Ann atroeWe.peymeM rvra "
n
TE box is
e
U
L
E
CE
AGE
rperare or tai to maintain sufficient Reads in your account to
over the •uiomalk payrttlrea. In crush ¦ c+ea,1W aced d IW lltaaaes wed W b exWtd tlN tent/ d you ban. F a example, x your Automatic Payment Discounted Roe is 10%
n a 13,000.00 ken fa 60 moMha end you aaw tl+e sutdrWk paymeA anapMbd, yw ran coal tnrnase b t?.20%. mu" In t models" paymanl.
W rIWN Rw Prerpr,d Lorna. 11 r ban is a variable ram loco tiro.yw gLISMY la a Preferred nab, Your prole
held prd•m0 ANNUAL PERCENTAGE RATE ova Nan vary acoordkng b h IM Iont (es dYcbeed .bo Muount is taken at Ns IoM you take Out YOLK ban. This
ys). For example, t a variable rate ban's InIIN ANNUAL
PERCENTAGE RATE le 12% al Iha tlrss you take Iha ball, yw Ylalal pnlenW AWAUAL PERCENTAGE KATIE w10 be WA%, Your initial preferred ANNUAL PERCENTAGE
RATE wiu Nan vary aaardbq h Nat Intlax, as tlhcrosed h en'yarhbh RNs" prevWen .bow.
Flutl R,ss
d
p
y ban
4 a
rap
ban and
you IWdkY lOr a pfslared rah, your ANNUAL P
hag
RCENTAGE RATE will be the preferred ANNUAL
PERCENTAGGE E RA RA
abatfclaed
If Its
e tar
long
as
your
Plefarred
TE u flatus remake Yt shad.
Number d Payments Amount 0t Paymnp Payment Frequency When Payments Are Due Properrt1yy Insurance: You may obtain property
your
" 118 $1214.07 Monthly - Beginning 07118/2008
a Insure fl6a from an core you want that is acceptable to
the credit union. 1
11ou get the Insurance from the
e
soin
ova Is: 1 $1212.35 Final Due - On
06h60078 ,
credit union you wed pay
$ NIA
Security: COMLWW securing crater loans with the credit union tie goods or propMy Other
will efao secure hit ban. You as giving a seemly kdereal In
OW:
vow shares andlor deposit in On credit union ??
l
i
A being purchased.
(Describe):
F-1
. r
t,
L.ta Charye: x a =,4 k lees by t0 d s a mole you coda R and 09p"t BW nce: The Annual PaC" is, Ran does Filing Fees: Non.FWng insunnce:
W carped • late Ned 5% of Your scheduled payment. not plea lift acmuM your nqulW daposil bal
anx , I any. s WA f WA
ti meni• • pay off • . you rid Lew in pal a Poorly. rw
C==dl
Me atl plUeYann/ xM pw
?aa OW nkniVed foptmwM In M w•
AMOUNT FINANCED $ 95,000.00 Amount Paid to others on your behalf ( scribe)
AMOUNT GIVEN TO YOU DIRECTLY $ 95,00.00 $1 To Mi'^iivti Loo S To
sore To Minnesota Las S To
AMOUNT PAID ON YOUR ACCOUNTS $ To S To
$ To $ 0.00 To Fees
PREPAID FINANCE CHAROE $ 0.00 $ To AbOSOAde $ To Aa,e SdLxbnl
OTHER (Describe): 113 KLINE RD SHIPPENSBURG, PA 17257
You Pledge Shares I AMOUNT ACCOUNT NUMBER AMOUNT ACCOUNT NUMBER
and/or Deposits of S $
You some dual the terms and conditions in the disclosure aNement and the ion and securily agnarnnts looted page 2 of ads doramaM a W apply to this loan. I essre 4 more
then one Irwin a, we spree that all go coro0bns or the ion and saeurti)r apreselres governing We lon dull a Y to both lonItly and
recOnd a copy of ON ban and security agreements and discosurs stalemate. Co. r. B you re=4 You sduto to codlel you he"
contained an page 2you signing; as oo.s , you acknowledge receipt of the ndke to txretpnr
SOR "/s IGNA E
X C...iN DATE
(SEAL) O CO-MAKER
X 'OTHER OWNER ''CO'SIGNER DATE
(SEAL)
CO R ? -OTHER OWNER ? "CO-SIGNER DAT ID CO-MAKER 'OTHER OWNER ? "CO•SiGWR GATE
X (SEAL) X (SEAL)
? CO-MAKER ? 'OTHER OWNER ? ''CO-SIGNER DATE ? C"AKER 'OTHER OWNER C] "CO-SIGNER DATE
X (SEAL) X (SEAL)
e.:NM• «MwI,r.AM1'NNn tIM,?ra,wr.,wiN.'wIo.4 Woo- 4..ew oyplr?.l.ra Tor Mr•wN. sYN•N.IWM.N IM
e..w,.1s,Ir aaMwrbtr?rNh eWNrrlr rPNN??NewhMrAM?.rL"CO.eeNe„YPM?,RMSM,wNn, W MJ,,.y llwnM ewM•r •wMY Vwfe b- Tt.~
ewrea. Mss is-W. b.Na I. or d. -Ad shahp w wsw b, low.
APPLICATION FOR GROUP CREDIT INSURANCE
-M as?p1yy?,?pp oowrap•1•)Waded not. " Was les
h ay ar no pin, If pr.*. IIarsnNnd M'IN-Wbpsb ,averktxwsecuon win nis w a
I aLdastrt(aWprdrs,adltkY.trroYw e?
bxa•rl;rtd nelr btin eitlw Yrkr+n IMw>•I•r k.r+mull.l(wq undeslwrd uw lpwwkr C r to sdaow zwdliii
ctc. cos
nsrrl M joAly ardiodi.gay d
"ft 2, wtdlr IN N o on"I l ?pnw red ons" A
nt S{JC?1 QAF NT
inn 2, mud .t1 wsado ddWrdMmy(r1r)daplNlylarokb brre,: 'rFu.{
t. yrrpL;sNgalekwrarxe mwadgy,dryy)VAyou Mundlipd70nMlnsideeWnaugood adyaxb,d7 yw p?. 1( (APOk" 10 b Your ra WVWMP adviduliol
mok "'A' hwe pe
30 nor Inca or inc eel 7x11 wthe idshine b sd;:alktp ld07MM rmdrs?e,nrs ink daN od"
? ? Q
MI talMNrfsaen a,yt aberntrer.db rdrNtMlwrebf ?; R1Yk ? O rlp? a
7.?AOw w k»t?a.e Ya+Wat lndvay I? pyalN or
anon
Oek+«cr•srnan.
(AWg° j «°A°W Rkno i cdrrwt (MGi7
Atr l•?sn.gbM •r,oM erfMbM Wtp myth kroW,pead bld.F wits, wits, r Y +?Y
a.amppl??a?a rlrewer Tie' to 1a2. MLx10elaaM -,-pars...
•oor Wbhvwru en0
N rot W Y+rr.ea a nn m.•ppnnea ar 1 cower ^ru• b Wr.,UOn ], M urd•rtbq dot M N eseen.Nika•artLe aP ion trn101xa Ipl reladNp.1.00
TM a1reNM dw of ay low) kLtLaelte W bee Mass of antap Iron Any prsea WN krgylddy, nand tilt Meed to debaW LUoureen.
sr MMemM d•YlIn comslnN9 arty et•Iwlelly Islas Yllprmllbn,rmmWsforvw F?dpW/el"rNN1dY1g YItMRallMr df?lllp ally Est Nakl NNNa ernlnWa M• Wk,ulea??
when k • Mtn,,n, suyecla suer perebt to erlrlr.l red ell Pon hies. Do nN,Iyi pons bladt. aaccL?
411
bNdl N•cas hew real keen c•mpNl•q the used. lea not egrwd •nd CrtN the tkanan I am%e0atielaM spas N Thal application all not b. used in cenbf M NI eppllrable
app sapac W notaeon'i.dne•eed.
CREDIT INSURANCE APPLIED FOR: NOTE: ONLY ONEiAPPLICANT MAY APPLY FOR DISABILITY COVERAGE.
?nYes No Single-Credit Life Total Premium ? Yes ? No Credit Disabilty Total Premium
? Yes ?X No Joint Credit Life
kl&=O whO applicant(a): ? Applfrant ? Co-Applure ; $0.00 Indicels which wak.mU Appficpni Co-,Pf?r>en ;
: ? C:] s 0.00
rou a oowNd sly la d. 7P•• d ootasae IerwNdt • k brdxalw anai rtpplk,soA
APPLI BIGNAT DATE OF BIRTH DATE-- C PUCANT'S IGNATURE DATE OF BIRTH PATE
F. 43769 Rev 1101
Exhibit "A"
rbr W.pamr. IK At 09-ni od.
ROY GREEDIER
=1f3 1 R?I:EOAIENTISSITME WORDS 'CREDIT UNMAN' MEANS MEMBERS 13T FEDERAL CREDT
LOAN AGREEMENT SECURITY A
PaymenntefFlnantro Charges: For value received, you prordee to pay, of
the Credit Union's office, all smouds due
All payments stall be
d 1. To saw
n
io
I
.
ma
e
pursuant to the disclosure statement on papa 1 of this document. You
urhderelarhd that the finance r 1Nrpe and total of payments shown on page 1
Of this doaanent a
b
d un
n
n
h
right go t
a e o
re
ase
on fie asaumptfon that all will be made on the scheduled due dabs
and
If you have f u e I
,
,
or
preferred rate Qrot you continue to Salkfy the condilbns of ? f pirehamed
rate. If you fall to pay any Installment by time It is due, you iw pi ay
additi
l i
a sae
o
o h?.i b:n
ona
n
nasl on the oveWue amount.
n
Payments and Additional Payments: Payments and
chigo r? r
a
c
w
r
fi be
e
fees s sh ollapplied in this following order. a amounts past due: any
ga owing, Including any insurance premiums; mocrued M
t orrinvi
i
given ard
money n! 6i
eres
or finance charges: outstanding principal. payments made In addition to
scheduled park "be applied In the some order
rogul i 2. You w?l
lino
o e
.
ry
d
Rate: you qual for a prat rred rats as d'isdosacfon e 1 of
this document or in a sego oratsrred rate mddaavhaw m , . r.P . s. You yam
-!?Pt_
making poyrrien? and tosvmoo all ob a altons IC811. You Promise to continue
You no lager reeetve She raAe.
Lao CMrgs: N you make a late pa nt, you some to pay a late charge
If one k tlkClosed on page 1 of tills d ~t.
Property Isureace: If you obtain a ban secured by a motor vehicle or
ofiror Wgible propaAy you must obtain kourence which protects the credit
union from financial less. The amount and a Of 6N propaAy
insurance must be aoceptable to the credit union. a polity must
provide at least fire, Melt, combined additional coverages and collision
m urarrce. it must contain a Loss Payable clause endorsenNnt Iwrdng the
credit union as Ion holder. You may obtain this insurance from any agent of
your choice and direct the agent to send the credit Union a copy of lha
policy.
Debtor ResporalbBlty: You promise to notify credit union of any orange...
your name address or employmasnL ?Youuypromise not to apply far a loan H
you know yen obligation scaxd'amp to he lerma of the cred?d extension. ?laommm
of iMam Credit union of any now Mformagorl which rolalsa to your ability to
sppay your obligation. You promise not to submift fain or Inaccurate
infamatlon or wfifluiy conceal Information regarding your ueditwabhiness,
credit standing, or credit Capacity.
Statutory Lien: H you are In default, federal law gives the credit union tie
night to RrWy the balance of shares and/or Ovldends in ,r acCOUrUr (s) at
the finne o fault to satisfy this loon. Once you are in tfsfsua, the t
union may exercise this right without further notice to you.
Delay In Enforcement: Credit Union may deity enforcing any of the credit
union rights under this agreement without losing clam.
Irregular Payments: The crock union max sgceV late ps Is or partial
payments, even BV.-
this arked'psymant M , withhout foskp any of the
credit union rights agresmenL
Co makere: H you are signk,g this agreement as • rxrlrolcar, you agree to
be equaUv rosponelble with the borrower. but the credit union may sue
either of both of you. The credit union does not have to nogfv you that this
agnrgmert has not boon paid. The credit union may extent (he temp of
Pa ymet a yon taseag eeme bout notifying or releasing you from
COMnotuSl Pledge of Share: You pladga as your shares and ppaks'In the
credit union, InrlWkrg future addWons, as security for this looftL cans YOU
cat the craft union may l1ppppy ease shorn and opposes toNs
of as gums 0w at the amp of dahull, Including comb of COMen:n ."I mgrrt
raaaaable slbrnayy Ms, that the credit union may Incur, up b ae% of the
unpaid Principal and Inbrat No sea or dgM to Impreu s Ibn on share, gad
deposes shall apply to any of your Sharon which may be hop In an IndNdwl
Redromem Account* or'KwVh Plan.'
4.
08/06/2006
WORDS 'YOV 'YOI1R` AND 'YOURS' MEAN THOSE
EA
, sae or eanafor the 0ollnwsl un4n you have
m ofnM
cOn
k tlIN b w wlelsla, mw at so seaMry trrMrasn
awp1iaaandalpnso= agwninn of
lrow?Cilad
'r!!a,lnd Yarn naalnt or gasoline to on wocam,
s
ayal•I7M ad"wra
rjj wan 1oaro r win 681440 phi Property UfVj he.
6. Yitwsl malsain ? galyeowr_np whkN awe M n 6 In wlddh the
or
such this
__ a r6 'o . sum q?k ?
Surma • ,•w ra'0 wd hrhie46ny b MwwA fit M antr6d lib aa1 pale. You k6uw
Wlpfio r6o6M I N pow6nla a on
unki :Yaou I etnYl uses to ? t by a6
Me creel v n • alntl p trove proceeds to Ne elan owed to
it units to proMee your nsuran4 Savio@ Comm
it r'+ n??1r1 Pit fin for vaYla6on of alspub cover"e.
6.
e.
9.
10.
ff4M Your near b PgrtOrhnh
al?ament o b ad 0b rgzm and
borrower
nap egrwy raaioMilNa to MN11M lemu of this
nol only Digs you, the your sxgwlm, semk,,W o s,
atop Las
You are being gaited to guarantee this debt. Think care MY before youn do. fill* borrower down t
Pay H You have to, and tat you want to accept this responatblYty. p.y t is debt, You will have to. Be our you can afford to
You may have b pay up Io the full amount of the debt H the borrower does not pay. You may alto haw
amount. 0 Pay late fees or collection costs. which Increase this
The Creditor scan collect this debt from you without IM trylq to coigd from the borrower. The creditor in use the sans colketlon methods against you that
rcas n b 7u ai uVs nutbor, r Such ass long you p ? ng Ydo?w
t. cif
agss. etc. H finis debt is ever In efouk. that fact may become a pan of your cite the F. 437691/02 Ifs ttN
APPRO Syshau, 1122.1078
Page 2 of 2
ALL that certain real estate lying and being situate in
Southampton Township, Cumberland County, Pennsylvania, more fully
bounded and described as follows:
BEGINNING at an existing parker kalon nail in S.R. 4003,
known as Kline Road, at the corner of lands now or formerly of
Robert. L. Fink; thence along said lands now or formerly of Fink,
North 78 degrees 02 minutes 18 seconds West 600.05 feet to an
existing iron pin at a 40 foot oak; thence along said lands now or
formerly of Fink, South 33 degrees 36 minutes 09 seconds West
649.70 feet to an existing iron pin at lands now or formerly of
'Floyd H. Herr; thence along said lands now or formerly of Herr,
'Mirth 63 degrees 47 minutes 03 seconds West 367.17 feet to an
existing iron pin at lands now or formerly of J. Harold Holtry;
thence along said lands now or formerly of Holtry, North 39
degrees 53 minutes 17 seconds East 384.52 feet to an iron pin at
the corner of Lot No. 2 on the hereinafter described subdivision
plan; thence along Lot No. 2, South 56 degrees 23 minutes 51
seconds East: 222.03 feet to an iron pin; thence along said Lot No.
2, North 60 degrees 10 minutes 4 seconds Bast 111.80 feet to an
iron pin; thence along said Lot go. 2, North 33 degrees 36 minutes
09 seconds East 248.65 feet to an iron pin; thence along said Lot
No. 2, South .76 degrees 02 minutes 18 seconds East 559.31 feet: to
a railroad spike in Kline Road; thence in said Kline Road, South
44 degrees 14 minutes 25 seconds Last 89.89 feet: to an existing
parker kalon nail,. the place of beginning.
CONTAINING a total area of 3.916 acres subject to a dedicated
right of way area of 0.059 acres leaving a let lot area of 3.857
acres and being known as Lot No. 1 on a land subdivision for Sarah
C. Reeder dated April 12, 1995 prepared by Carl D. Bert,
professional land surveyor, and recorded in Cumberland County Plan
Book 70 at page 45.
SUBJECT to building setback lines and notations as set forth
on the above described subdivision plan.
UNDER AND SUBJECT to all restrictions, reservations, rights
of way, conditions, covenants, and easements of prior record.
Being the same premises which Roy G. Reeder and Regina L. Reeder, his wife, by their deed dated
September 18, 2003 and recorded in the Cumberland County Recorder of Deeds Office in Deed Book
260, Page 125 granted and conveyed onto Roy G. Reeder.
Exhibit "B"
cq? I b5
Prepared By: Members 1st FCU
5000 Louise Drive
Mechanicsburg, PA 17055
When recorded mail to:
FIRST AMERICAN TITLE INSURANCE
LENDERSADVANTAGE
1228 EUCLID A VENUE, SUITE 400
CLEVELAND, OHIO 44115
ATTN.• NATIONAL RECORDINGS
17
X006 :COL 7 an 10
2
MORTGAGE U( 7o j
Made 06/06/2006
3011 ao3Q '
14pR? Between
ROY G REEDER
(hereinafter ca a "Mortgagor"
And
MEMBERS 1 IT 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
$ 95,000.00 , lawful money of the United States of America, and has provided therein
for payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with
interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and
containing certain other terms and conditions, all of which are specifically incorporated herein by
reference;
Now, Therefore, Mortgagor, in consideration of said debt or principal sum and as security for the
payment of the same and interest as aforesaid, together with all other sums payable hereunder or under
the terms of the Note, does grant and convey unto Mortgagee,
All that certain property of the Mortgagor located in SOUTHAMPTON
TOWNSHIP , Cumberland County, Pennsylvania
SEE EXHIBIT" A"
which currently has the address of 113 KLINE RD
Sh' b [Street]
1pUens urg Pennsylvania
[City]
Acct No 286724-01
ApplD 155586
Exhibit «C"
17257
[Zip Code]
Page 1 of 4
BKI957PG2904
Together with the buildings and improvements erected thereon, the appurtenances thereunto
belonging and the reversions, remainders, rents, issues and profits thereof.
To Have and To Hold the same unto Mortgagee, its successors and assigns, forever.
Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum,
including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder
and under the terms of the Note, together with interest thereon, and shall keep and perform each of the
other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby
granted and conveyed shall become void.
This Mortgage is executed and delivered subject to the following covenants, conditions and
agreements:
(1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any
future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and
intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall
be added to the principal debt.
(2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and
discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water
rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt
secured hereby, (b) pay all ground rents reserved from the mortgaged premises and pay and discharge all
mechanics' liens which may be filed against said premises and which shall or might have priority in lien
or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax,
including interest and penalties thereon, if any, now or hereafter becoming payable on the Note
evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums
and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time
require upon the buildings and improvements now or hereafter erected upon the mortgaged premises,
with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear,
and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing
charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge
the foregoing charges be paid in installments to Mortgagee.
(3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and
substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the
mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair
of the buildings and improvements erected thereon.
Acct No 286724-01 AppID 155586 Page 2 of 4
BKI957PG2995'
(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 286724-01 AppID 155586
Page 3 of 4
BK1957PG2906
Witness the due execution hereof the day and year first above written.
RO G REEDER
Commonwealth of Pennsylvania
County of Cumberland
ss:
On this, theta day of Tiinp ,2006 , before me, Luanne E. Kyle
not
a r y pu b ?i c , the undersigned officer, personally appeared
Roy G.
P Pr 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 ar
My commission expires:
COMMWEALTH OF PENNSYLVANIA
6--
Notarial Seal
Luanne E. Kyle, Notary Public
pe
nsbury Born, Cumberland County
Coreariissbn E?ires Jan. 20, 2009
Member, Psnnsovanle AISCO dgn of NgWp
Members 1ST Federal Credit Union, Mortgagee within named, hereby certifies that its residence
is 5000 Louise Drive, Mechanicsburg, PA 17055.
13y
Acct No 286724-01 AppID 155586 Page 4 of 4
01119 5 7 PG 2 H 7
EXHIBIT A
All that certain property situated in the Township of
Southampton, in the County of Cumberland, Commonwealth of
Pennsylvania , and being described as follows: 39120324024.
Being more fully described in a deed dated September 18, 2003
and recorded October 24, 2003, among the land records of the
County and State set forth above, in Deed Volume 260 and
Page 125.
Permanent Parcel Number: 39120324024
ROY G. REEDER
113 KLINE ROAD, SHIPPENSBURG PA 17257
Loan Reference Number 155586
First American Order No: 9634769
Identifier: FIRST AMERICAN LENDERS ADVANTAGE
11111111111 M111111,11 REEDER
9634'WW- 4
FIRST AMERICAN LENDERS ADVANTAGE
MORTGAGE
111111111111111 lull 111111111111 HIM
I Certify this to be recorded
In Cumberland County PA
.n
t
Recorder of Deeds
B ! 957PG290
(Rev. 9/2008)
Date: July 17, 2009
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 intgn ds to
foreclose, SDecific information about the nature of the default is provided in the attached W=.
The _H_OM OWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM .HEM A D\
may be able to help to save your home This Notice explains how the program works.
To see if HE AT can help, you must MEET WITH A CONSUMER CREDIT COUNSEL ING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you
when you meet with the Counseling Age!
The name address and phone number of Consume Credit CounselingAgen?iec serving y??r
County are listed at the end of this Notice If you have any questions you may call the
Pennsylvania Housing Finance Aggacy toll free at 1-800-342-2397, (Person with impaired
hearing can ca11(7717_) 789)1.
This Notice contains important legal information. If you have any questions, representatives at
the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE 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.
Exhibit `D9'
HOMEOWNER'S NAME(S): ROY REEDER
PROPERTY ADDRESS: 113 KLINE RD
SHIPPENSBURC,, PA 17257
LOAN ACCT. NO.: 286724 - 01
ORIGINAL LENDER: Members 1" Federal Credit Union
CURRENT LENDER/SERVICER: Members 1" Federal Credit Union
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
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 (plus three (3) days for mailing). 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 MJJST OCCUR WITHIN THIRTY-THREE X331 T A S OF THE DATE F THiS
NOTICE. 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.
CONSiiWR CREDIT COUNSELING A . N ,_M -- 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 coup
in which the nronertv 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 ASSISTANT F _ 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.) 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. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA
and received within thirty (30) days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A
COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION
WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM
STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED
"TEMPORARY STAY OF FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HE MAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE
APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR
APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE
STOPPED.
Page 2 of 5
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 DF.FAUL.T --The MORTGAGE debt held by the above lender on your property located at:
113 KLINE RD
SHIPPENSBURG PA 17257
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due: for 5/16/2009 in the amount of 1210.44, 6/16/2009 in the amount of 1212.86 and 7/16/2009 in
the amount of 1212 86
Other charges (explain/itemize):
TOTAL AMOUNT PAST DUE: $3,636.16
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not ap..Plicable):
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 $ 3,636.16
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and
sent to:
Members 1" Federal Credit Union ATTN• Tracey Mackey
5000 Louise Drive
Mechanicsburg, PA 17055
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.)
Page 3 of 5
IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire
outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged prollCM.
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 ned_jou will
not be required to Da 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' SAL.. 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.
Name of Lender: Members 1" Federal Credit Union
Address: 5000 Louise Drive
Me hani sb urg, PA 17054
Phone Number: 717- 06-Sd3f! nr / 001 293-2328 F_ Y_t 5438
Fax Number: (717) 795-5207
Contact Person: Tracey Mackey
E-Mail Address: mackeytanm .mhersts .org
EFFECT OF SHERIFF' A .F. _ You should realize that a Sheriffs Sale will end your ownership of the mor tgaged
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 or XX may not (CHECK ONE) 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.
Page 4 of 5
• 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.
Certified Mail # 91 7108 2133 3936 2347 5311
Page 5 of 5
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated: 10/15/2007 10:03:08 AM
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Loveship,Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565
Relief Act and Urban Development (exp 4/30/2007)
Notice Disclosure Office of Housing
Legal RightQ and Protections Under the SCgA
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 RA?
• 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 Leval Protection Are 4 rvicemembers ntitled To Under the S RA?
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 Servi m mb r or Dependent Request Relief Under the S['RAr?
• 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 1 a Federal Credit Union, ATTN:
Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The
phone number is toll free (800) 283-2328.
How Does a SerAcemember or D pendent Obtain Information ahout the SCRA?
The U. S. Department of Defense's information resource is "Military OneSource".
Website: http://www.mili!Monesource.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
hLtp:Hlegalassistance law of mil/content/locator php
form HUD-92070
(2/2007)
Form 3877
• 0WN,
a
r„? tiVacwtIES
02 1M ¢ 1.00-
0004250959 JUL17 2009
MAILED FROM ZIPCODE 1 7055
Mailer's Name and Address: Permit Number: MAC Cert. Ver. Num.
Members 1 st Federal Credit Union 9223844001 SendSuite - MAC v6.00.6.01 j
5000 Louise Dr Sequence Number:
MECHANICSBURG, PA 17055 0000278
Pc ID #/ Addressee Name Postage ES ES Insur Due Total
Article # Delivery Address Type Fee ad Sande Charge
'Z900000019827 Roy Reeder 0.610 C 2.800
9171082133393623475311 113 Kline Road ERR 1.100
Shippensburg, PA 17257
Page Totals: 8 4.370 31.200
Cum Totals: 8 4.370 31.200
Total Number of Pieces Received:-
Ttal?,
Signature of Receiving Employee
Exhibit "E"
Page: 1
0.00 4.51.0
35.570
35.570
40
??v pTwcr Kcw?s
02 1M $01-680
_QO04250959 JUL1'1 2009
AILED FROM ZIP CODE 1 ? 055
r-.--... 7077 lc--irniW CPnfi;iiitp - MAC v6.(
MEMBERS 1 ST FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
ROY G. REEDER
DEFENDANT
: IN THE COURT OF COMMON
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.:
: CIVIL, ACTION-LAW
: MORTGAGE FORECLOSURE
VERMCATION
1, Dave Thomas, Lead Collector for Members 1-4 Federal Credit Union, being
authorized to do so on behalf of Members I" Federal Credit Union, hereby verify that th
statements made in the foregoing pleading are taste and correct to the best of my
information knowledge and belief. I understand that false statements are made subject to
the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to
authorities.
Members 1 a Federal Credit Union
Dave Thomas, Lead Collector
6
O
FILIr?:...,?,
OF THE F 'w; fHICNCIARY
20,39 SEP 10 P;i I : S I
cCUWy
C. ?i(V
PENT `O r
ItlLL?6`gA
*q8 . w PD Ar-Y
Ct7 3Hoq
R-Ttol3o41(0
Sheriffs Office of Cumberland County
R Thomas Kline
Sheri
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
??Lti>ttp o! ?i[ttrGirt???
;?,t MY
OM-EGiFt'h:: ??eRIFF
PLED C) I ,"IR
Members 1st FCU
vs.
Roy G. Reeder
ZQ??4 SEP 21 ,r
Case Number
2009-6146
SHERIFF'S RETURN OF SERVICE
09/17/2009 08:26 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on
September 17, 2009 at 2026 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Roy G. Reeder, by making known unto himself personally, at 113 Kline
Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing
to him personally the said true and correct copy of the same.
SHERIFF COST: $46.44
SO ANSWER ,
September 18, 2009 R THOMAS KLINE, SHERIFF
By
Deputy Sheriff
ZQ~Q FF~ ~ ~ ~~ ~~ ~
Kazl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
~,~ '
~~~ f`';~ji`,'
MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
ROY G. REEDER
DEFENDANT
TO THE PROTHONOTARY:
NO.: 09-6146 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 Defendant, Roy G. Reeder, in the amount
of EIGHTY-THREE THOUSAND THREE HUNDRED TWO AND 58/100 DOLLARS
($83,302.58) 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 Defendant, Roy G. Reeder, to Plaintiff s Complaint within
twenty (20) days of service thereof and after a 10-day Notice was sent.
~I~.00 Pp AMY
ce~~ 3s~ I
~T,a. as~~r~9
~o~lea, luai l~
s
Date: February 17, 2010
~Larl 1~. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
I hereby certify that notice of intent to take default judgment was forwazded to
Roy G. Reeder by United States Mail, first class, postage prepaid on January 28, 2010.
The aforesaid notice was contained within an envelope bearing the return address of the
undersigned. The notice has not been returned to the undersigned as undeliverable or
otherwise. A copy of the notice and Postal Form 3817 aze attached hereto and mazked
Exhibit "A".
~~~~Q~-
M. Ledebohm, Esquire
s
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1sT FEDERAL
CREDIT UNION
PLAINTIFF
Vs.
ROY G. REEDER
DEFENDANT
TO: Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 09-6146 Civil
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
IMPORTANT NOTICE
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.
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"
Cumberland County Baz Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or (800)990-9108
Date: January 28, 2010
n
,~azl M. Ledebohm, Esq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173 `
(717) 938-6929
Attorney for Plaintiff
UNLTED STGTE.F
~ROSF,G ~ a
ems Ceror.a, ..i ~.n,;r,no nro~maca Ce(rtIIICd _ j'(F
ins ~~ .,~~~~„ ~~a~ magi ter. o>a -.
vrom ~ u.e ta,.,~'n,nuvi $p~'._-C~..
O
r i O
_ Kazl M. Ledebohm E ; ~ V
P.O. Box 173 ~ ~~ ,. . ``
New Cumberland, PA 17070-0~1.'~3`-:":
~~
~*
*N~
C y
aN
,, --., x m
o ~
- Roy G. Reeder o~
az ~ N
- 113 Kline Road o'"'' ON~IWD'
~'--' ~~o~°°
- Shippensburg, PA 17257 oC.T1 Q Z
- ~ o
m
PS Fprm 3 D
$17 April 2007 PgN 75~p-07.0009065
Kazl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
NO.: 09-6146 Civil Term
ROY G. REEDER :CIVIL ACTION -LAW
DEFENDANT :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: Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
You are hereby notified that on ~ (~ ~ ~* , 2010 the following
judgment has been entered against you in the above captioned case:
Judgment in favor of Members 1 Sc Federal Credit Union, Plaintiff, and against the
Defendant, Roy G. Reeder, in the amount of EIGHTY-THREE THOUSAND THREE
HUNDRED TWO AND 58/100 DOLLARS ($83,302.58) 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 Defendant, Roy G.
Reeder, to Plaintiff s Complaint within twenty (20) days of service thereof and after a 10-
day Notice was sent.
I ~
Dated: Prothonotary
is:
I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236
Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
A: Roy G. Reeder
Por este medio se le esta notificando que el de
2010 eUla siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso
mencionado en el epigrafe.
Fecha:
Protonotario
Certifico que la siguiente direction as la del defendido/a segue indicada en el certificado
de residencia:
Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
Date: February 17, 2010
~arl M. Ledebohm, Esquire
upreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
Fi~.+~a-aF~fcE
o~ ra~~ ~~ o~~a~o~,~;~
Karl M. I..edebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717~I38-6929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF
ROY G. REEDER
DEFENDANT
1Q! Q SEA' 22 PM 3~ ~ 3
CUMBERL~F~a CQUN3'~
PENNSYL~`~.~~1~~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 09-6146 Civil Term
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
AFFIDAVIT OF SERVICE OF NOTICE TO LIEN HOLDERS PURSUANT TO
Pa. R,C.P. 3129.2 (c)
I, Karl M. Ledebohm, Esquire, being duly sworn according to law hereby swear
and affirm that on the 17th day of September, 2010, I served the attached NOTICE
TO LIENHOLDERS AND OTHER PARTIES IN INTEREST pursuant to Pa. R.C.P.
3129.2(c) in the above captioned matter upon the following individuals by first class
mail, postage prepaid, addressed as follows:
Members 1 ~` Federal Credit Union
Attn.: Dave Thomas
5000 Louise Drive
Mechanicsburg, PA 17055
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
Farmers & Merchansts Trust Co. of Chambersburg
20 South Main Street
Chambersburg, PA 17201
Occupant
113 Kline Road
Shippensburg, PA 17257
Regina L. Reeder
113 Kline Road
Shippensburg, PA 17257
Postal forms 3817 evidencing the mailing of said notice is attached hereto as
Exhibit "1" and made part hereof.
I verify that the statements made in this ai~idavit 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: September 21, 2010
Karl M. Ledebohm, Esq.
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
(717)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF
ROY G. REEDER
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 09-6146 Civil Term
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa. R,C.P. 3129.2(c)
To: Members 1 S` Federal Credit Union
Attn.: Dave Thomas
5000 Louise Drive
Mechanicsburg, PA 17055
Domestic Relations
Cumberland County Courthouse
One Courthouse Square
Cazlisle, PA 17013
Cumberland County Tax Claim Bureau
One Courthouse Square
Carlisle, PA 17013
Farmers & Merchansts Trust Co. of Chambersburg
20 South Main Street
Chambersburg, PA 17201
Occupant
113 Kline Road
Shippensburg, PA 17257
Regina L. Reeder
113 Kline Road
Shippensburg, PA 17257
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the
Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of
Cumberland County, directed, there will be exposed to Public Sale in the
CUMBERLAND COUNTY COURTHOUSE
South Hanover Street
Carlisle, PA 17013
on December 8, 2010 at 10:00 a.m., the following described real estate which Roy G.
Reeder is the owner and reputed owner and on which you may hold a lien or have an
interest which could be affected by the sale of:
113 Kline Road
Shippensburg, PA 17257
(SEE LEGAL DESCRIl'TION ATTACHED AS EXHIBIT "A").
The said Writ of Execution has been issued on a judgment in the action of
MEMBERS 1ST FEDERAL
CREDIT UNION
PLAINTIFF
ROY G. REEDER
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 09-6146 Civil Term
CN1L ACTION -LAW
MORTGAGE FORECLOSURE
at Ex. No. 09-6146 Civil in the amount of $83,302.58 plus interest, additional
attorney's fees and costs.
Claims against property must be filed at the Office of the Sheriff before above
sale date.
Claims to proceeds must be made with the Office of the Sheriff before
distribution.
Schedule of Distribution will be filed in the Office of the Sheriff no later than
thirty (30) days from the sale date.
Exceptions to distributions or a Petition to Set Aside the Sale must be filed with
the Office of the Sheriff no later than ten (10) days from the date when Schedule of
Distribution is filed in the Office of the Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this
Notice, you should contact your attorney as soon as possible.
Date: September 16, 2010
submitted,
earl M. Ledebohm, Esq.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
ALL THAT CERTAIN real estate lying and being situate in Southampton Township, Cumberland
County, Pennsylvania, more fully bounded and described as follows:
BEGINNING at an existing parker kalon,nail in S.R. 4003, known as Kline Road, at the corner of
lands now or formerly>~f Robert L. Fink;thence along said lands now or formerly of Fink, North
78 degrees 02 minutes 18 seconds West 600.05 feet to an existing iron pin at a 40 foot oak;
thence along said lands now or formerly of Fink, South 33 degrees 36 minutes 09 seconds West
649.70 feet to an existin i (~ it a~lands now or formerly of Lloyd H. Herr; thence along said
lands now or formerly of Herr, North 63 degrees 47 minutes 03 seconds West 367.17 feet to an
existing iron pin at lands~ow or formerly of 1, Harold Holtry; thence along said lands now or
formerly of Holtry, North;39 degrees 53 minutes 17 seconds East 384.52 feet to an iron pin at
the corner of Lot No. 2 on the~hereinafter:.~i~escribed subdivision plan; thence along lot No. 2,
South 56 degrees ~3 minutes ~1 ~e(~r~~s' ~ X22:03 feet to an iron pin; thence along said Lot
No. 2, North 60;degees ~.O;~mmus4~ ~"~ _ sfd~-East 111.80 feet to an iron pin; thence along said
Lot No. 2, North 33 degrees~36`~~rnfnu~es 09~se~onds East 248.65 feet to an iron pin; thence along
said Lot No. 2, South 78 degrees 02 minutes 18 seconds East 559.31 feet to a railroad spike in
A,
Kline Road; thence in said Kline Road, South 44 degrees 14 minutes 25 seconds East 89.89 feet
to an existing parker kalon nail, the place of BEGINNING.
CONTAINING a total area of 3.916 acres, more or less, subject to a dedicated right of way area
of 0.059 acres, more or less, leaving a let lot area of 3.857 acres, more or less, and being known
as Lot No. 1 on a land subdivision for Sarah C. Reeder dated April 12, 1995 prepared by Carl D.
Bert, professional land surveyor, and recorded in Cumberland County Plan Book 70, Page 45.
BEING improved with a residence known as 113 Kline Road, Shippensburg, PA 17257.
SUBJECT to building setback lines and notations as set forth on the above described subdivision
plan.
UNDER AND SUBJECT to all restrictions, reservations, rights of way, conditions, covenants, and
easements of prior record.
BEING the same premises which Roy G. Reeder and Regina L. Reeder, his wife, by their deed dated
September 18, 2003 and recorded in the Cumberland County Recorder of Deeds Office in Deed Book
260, Page 125 granted and conveyed onto Roy G. Reeder.
BEING Parcel No. 39-12-0324-024
EXHIBIT `A'
ti
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MA4. DOES NOT
PROVI
F
~' _ ~„ "=~+..
.
J`~' `~ 5 8~
`J 2
~
DE
OR INSURANCE-POSTMASTER ~
~,.q
i
..-... ...-.rv.Cf ') p
N
Received From: ~ ~~
U~~~' ~'.
l~ N
~ ~
m
_ Karl M. Ledebohm, Esq. - f. ~ ~'
P.O. Box 173 ~ -~'~, `.
_
New Cumberland, PA 17070-0173 ~~ •
m
Ono ~:~o ..~ ~.n~~... ,nom i wnn.occnn_1p__.------- O~ ~
C
----~ - -~ ~
~
Farmers & Merchansts Trust Co. of `°~
~~ ~~~y
CVO~r~
_
Chambersburg
°'~ ..~
~~°A°~
_
20 South Main Street °' ~ ~ ~
Chambersburg, PA 17201
PS Form Sifl /,January lUUt
I '
U.S POSTAL SERVICE CERTIFICATE OF MAILING $
c
MAY BE USED FOR DOMESTIC AND wTERNAT10NAl MAIL, DOES NOT p ~
PROVIDE FOR INSURANCE-POSTMASTER ~ O a O
O ~ p
Received From- 5 ~
~r ~ h
~M
Karl M. Ledebohm, Esq. G `-
•~
~
"gyp, ¢ 'L
P.O. Box 173
i
S
New Cumberland, PA 17070-0173 '~, '
F
~.
One ~ ~~ Anarv mae adoressea io_
--- __. _. ----'-- - V _R .-.~~N
Domestic Relations '•'~ ~~ '` ~~~~~
~
•^tT1
-i •or- Vl
Cumberland County Courthouse ~~.T7 o p
1 `' One Courthouse Square ~ "'
i
-Carlisle, PA 17013
PS Form ,SCSI ~, lan~.~a.ry !UV I
~,
~. w
Exhibit "1"
• , o
U.S. PQSTRGE
-NEJ~t.,1rUMBERLRND. PA
1707Q
YN/riD SrpTFS SEP ; 1.7 r 1 Q
RosreiacRVTCF AMOUNT
1000 ; ;,- ~ ~',
`t ,: 0007 ~2 O6
~~~~~~,
N
0
z
h
0
Q
2
O
~¢
2 Vi
O~
ag
_U
F ~
N W
W U
S~
oz
w~
~°
W
m,°
>o
fa
Q
LL
w
`"'
Q
U
LL
N
W
U
W
U
w
J
Q
eM~f ~` _ I
_~
O
t
O
~ .~
~ _
W Q U
0.
~ c ["~
M ~ u ~ ~ ~
a ~ .o ~ C ~ ~
k ~ ~ U .-~ $
3 ; ~ a
~ ~
~~o~
w aZ ~U y ~
a~
~ I ~~~o~
U o
LL
a
~~
u/arscsrpres
ROSrpI SFRV/CE
1000
Z
J_
Q
LL
0
w
F-
Q
V
F-
W
U
W
U
w
a
r
O
a
N
O
ti
O
0
S
0
Z
ww
z~
0
r-
VO
F- d
N w
~Z
o~
O
~n
oZ
wo
~w
wo
mj
fa
U.S..POSTAGE
NEW CUMBERLAND,PA
1707
SEP 17,Q10
~y~~,.r~R,MOUNT
,+ a
_ ooo~s, _ s
_~
~,p`, `cn ~n~-~__ _l _ 1
''
.J
`
'
'A
(
~„~
~ ..
O •~
O
O +r ,~
~
CT' .-.
W a ~
U ~C
..,,
~ o
a
~ ~
air, ~
~ ~ ~ ~A
p ~
~C4U E
~
~ A ~~ U
~~
~~°z c
~
~g~
it ~ ~ ~
d
cc I I l o
R~
UN/TiDSTprFS
POSTdL SiRVlC
1000
C~
Z
_J
Q
0
W
H
Q
U
tt..
w
U
w
U
W
a
O
a
vi
O
Z
N
O
J
O
Q
W
ZoZ~
QN
~o
4
w "'
O~
0
~~
oZ
jo
w
w O
m~
~o
a
U.S. POSTAGE
NEW CUMBERLAND,PA
1707Q
SEP l7, !0
AMOUNT
F ~. ~ ~~ `~~15
``p` V I ~ yy I
r, Y ~: ,
~ r` -1.
t'~
O
O
l '
O
N .-. N
w a ~
'b o
~ a
^z'
~ ~
.~L~
i..~ k ~
.rt
E
y,+ y .G
~+
L, m U ~ a ~ (~
~
$ ~aZ ~
a p~
~
1 o
~~ U.S. POSTAGE
NEW CUMBERLRND.PR
17070
uNrrcosrares ....°~'" ~r', ; % 1 UNT 10
ROST4L SERVICE s'
r.
1 000 z'~"r,>
'~' lr.il 06
a
~
~~
l
1
Z _
.
^..~ f +: i - : -._
~'
_
J
Q p
Z ~~
~
u.
O w
o O
O
N
Q J
~ [~
~
~
U_
~ Z
~ Q'
W Q t`
~ a a ~
V ~ ~ ~
z~ N
N M ~ d ~
~ ~ .D B .~ a
~ k ~
U wv E
J
Q LL ? F ~
o
N
w 0
'' ~4 0.. 2 ~
.~ ~1
¢'
a w c~
I
~
~ N o
mO ~ ~ ~
~ I
K I O i i ~
~m
M
~ a
~a
a
0
N
00
M
a
;.
0
a
a
T --?: IC? TAFY
cry -l Aft g. 59
Karl A Ledebohm, Esquire OU
P.O. Box 173 CUMB
New Cumberland, PA 17070-0173 FE?1tiSYL4`ANU'?
(717)938-6929
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. SECTION 101 TO SECTION 149 ETC.
MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
NO.: 09-6146 Civil Term
Vs. Amount due: $83,302.58
Interest from: 2/19/10 at the legal rate
ROY G. REEDER Atty's Com. N/A
DEFENDANT : 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 Roy G. Reeder, 113 Kline Road, Shippensburg, PA 17257, Defendant;
and
(3) and against N/A Garnishee (s);
(4) and index this writ
(a) against Roy G. Reeder, 113 Kline Road, Shippensburg, PA 17257,
Defendant;
(b) against N/A Garnishee (s),
and levy upon and seize the following real property of Defendant and index this writ
against the following real property of Defendant as a lis pendens:
All that certain tract of land and improvements thereon erected situate in Southampton
Township, Cumberland County, Pennsylvania, known and numbered as 113 Kline Road,
G
J.blt?.oo Pa ATt
Hto.yq CBF
'78.50 n
14. oo n
a.50 ?r
1(06.gq -Pan
4a.oo Act
• 50 LL
at 151V
0 aU778q
PZ tor& 4
Shippensburg, Pennsylvania 17257 and as more particularly set forth and described on
Exhibit "A" attached hereto and made part hereof by reference.
(c) Exemption has (not) been waived.
Dated: August 31, 2010
,Carl 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 real estate lying and being situate in Southampton Township, Cumberland
County, Pennsylvania, more fully bounded and described as follows:
BEGINNING at an existing parker kalon nail in S.R. 4003, known as Kline Road, at the corner of
lands now or formerly of Robert L. Fink; thence along said lands now or formerly of Fink, North
78 degrees 02 minutes 18 seconds West 600.05 feet to an existing iron pin at a 40 foot oak;
thence along said lands now or formerly of Fink, South 33 degrees 36 minutes 09 seconds West
649.70 feet to an existing iron pin at lands now or formerly of Lloyd H. Herr; thence along said
lands now or formerly of Herr, North 63 degrees 47 minutes 03 seconds West 367.17 feet to an
existing iron pin at lands now or formerly of J. Harold Holtry; thence along said lands now or
formerly of Holtry, North 39 degrees 53 minutes 17 seconds East 384.52 feet to an iron pin at
the corner of Lot No. 2 on the hereinafter described subdivision plan; thence along Lot No. 2,
South 56 degrees 23 minutes 51 seconds East 222.03 feet to an iron pin; thence along said Lot
No. 2, North 60 degrees 10 minutes 4 seconds East 111.80 feet to an iron pin; thence along said
Lot No. 2, North 33 degrees 36 minutes 09 seconds East 248.65 feet to an iron pin; thence along
said Lot No. 2, South 78 degrees 02 minutes 18 seconds East 559.31 feet to a railroad spike in
Kline Road; thence in said Kline Road, South 44 degrees 14 minutes 25 seconds East 89.89 feet
to an existing parker kalon nail, the place of BEGINNING.
CONTAINING a total area of 3.916 acres, more or less, subject to a dedicated right of way area
of 0.059 acres, more or less, leaving a let lot area of 3.857 acres, more or less, and being known
as Lot No. 1 on a land subdivision for Sarah C. Reeder dated April 12, 1995 prepared by Carl D.
Bert, professional land surveyor, and recorded in Cumberland County Plan Book 70, Page 45.
BEING improved with a residence known as 113 Kline Road, Shippensburg, PA 17257.
SUBJECT to building setback lines and notations as set forth on the above described subdivision
plan.
UNDER AND SUBJECT to all restrictions, reservations, rights of way, conditions, covenants, and
easements of prior record.
BEING the same premises which Roy G. Reeder and Regina L. Reeder, his wife, by their deed dated
September 18, 2003 and recorded in the Cumberland County Recorder of Deeds Office in Deed Book
260, Page 125 granted and conveyed onto Roy G. Reeder.
BEING Parcel No. 39-12-0324-024
EXHIBIT'A'
. r ?
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
f7 7V7
9-- 59
COUNTY
MEMBERS 1 FEDERAL
CREDIT UNION
PLAINTIFF
ROY G. REEDER
DEFENDANT
IN THE COURT OF COM
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 09-6146 Civil Term
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Members 1St Federal Credit Union, Plaintiff, in the above action, sets forth as of
the date the praecipe for the writ of execution was filed the following information
concerning the real property located in Southampton Township, Cumberland County,
Pennsylvania, known and numbered as 113 Kline Road, Shippensburg, PA 17257.
1. Name and address of owner(s) or reputed owner(s):
Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
2. Name and address of defendant(s) in the judgment:
Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
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
Attn.: Dave Thomas
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
Attn.: Dave Thomas
5000 Louise Drive
Mechanicsburg, PA 17055
Farmers & Merchants Trust Co. of Chambersburg
R' 1
w
20 South Main Street
Chambersburg, PA 17201
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
Occupant
113 Kline Road
Shippensburg, PA 17257
Regina L. Reeder
113 Kline Road
Shippensburg, PA 17257
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
unworn falsification to authorities.
Date: August 31, 2010
y submitted,
Respectfu
VIA
Karl M.?Ledebohm, Esq.
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
RLED-CF'r-!C'E
'TAN
(T Tlf
i0 0 -1 St 7' S7
CUMBEt;L .x;'1;:1 COUNTY
PENt,6YLVANlA
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1ST FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
NO.: 09-6146 Civil Term
ROY G. REEDER CIVIL ACTION -LAW
DEFENDANT MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
To: Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
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 113 Kline Road, Shippensburg, PA 17257, 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 8, 2010 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
$83,302.58 plus interest at the legal rate, additional attorney's fees and costs of suit
and foreclosure and sale of the mortgaged property, obtained by the above named
Plaintiff against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs 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 or all amounts due to Plaintiff under the
judgment. 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 or before January 7, 2011 (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.
karl M. Ledebohm, Esquire
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Attorney for Plaintiff
I
ALL THAT CERTAIN real estate lying and being situate in Southampton Township, Cumberland
County, Pennsylvania, more fully bounded and described as follows:
BEGINNING at an existing parker kalon nail in S.R. 4003, known as Kline Road, at the corner of
lands now or formerly of Robert L. Fink; thence along said lands now or formerly of Fink, North
78 degrees 02 minutes 18 seconds West 600.05 feet to an existing iron pin at a 40 foot oak;
thence along said lands now or formerly of Fink, South 33 degrees 36 minutes 09 seconds West
649.70 feet to an existing iron pin at lands now or formerly of Lloyd H. Herr; thence along said
lands now or formerly of Herr, North 63 degrees 47 minutes 03 seconds West 367.17 feet to an
existing iron pin at lands now or formerly of J. Harold Holtry; thence along said lands now or
formerly of Holtry, North 39 degrees 53 minutes 17 seconds East 384.52 feet to an iron pin at
the corner of Lot No. 2 on the hereinafter described subdivision plan; thence along Lot No. 2,
South 56 degrees 23 minutes 51 seconds East 222.03 feet to an iron pin; thence along said Lot
No. 2, North 60 degrees 10 minutes 4 seconds East 111.80 feet to an iron pin; thence along said
Lot No. 2, North 33 degrees 36 minutes 09 seconds East 248.65 feet to an iron pin; thence along
said Lot No. 2, South 78 degrees 02 minutes 18 seconds East 559.31 feet to a railroad spike in
Kline Road; thence in said Kline Road, South 44 degrees 14 minutes 25 seconds East 89.89 feet
to an existing parker kalon nail, the place of BEGINNING.
CONTAINING a total area of 3.916 acres, more or less, subject to a dedicated right of way area
of 0.059 acres, more or less, leaving a let lot area of 3.857 acres, more or less, and being known
as Lot No. 1 on a land subdivision for Sarah C. Reeder dated April 12, 1995 prepared by Carl D.
Bert, professional land surveyor, and recorded in Cumberland County Plan Book 70, Page 45.
BEING improved with a residence known as 113 Kline Road, Shippensburg, PA 17257.
SUBJECT to building setback lines and notations as set forth on the above described subdivision
plan.
UNDER AND SUBJECT to all restrictions, reservations, rights of way, conditions, covenants, and
easements of prior record.
BEING the same premises which Roy G. Reeder and Regina L. Reeder, his wife, by their deed dated
September 18, 2003 and recorded in the Cumberland County Recorder of Deeds Office in Deed Book
260, Page 125 granted and conveyed onto Roy G. Reeder.
BEING Parcel No. 39-12-0324-024
EXHIBIT `A'
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-6146 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 ROY G. REEDER
(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 $83,302.58 L.L.$.50
Interest from 2/19/10 at the legal rate
Atty's Comm % Due Prothy $2.00
Atty Paid $165.44 Other Costs to be added
Plaintiff Paid
Date: 9/7/10
Dav D. Buell ofhonotary
(Seal) By:
,
Deputy
REQUESTING PARTY:
Name: KARL M. LEDEBOHM, ESQUIRE
Address: PO BOX 173
NEW CUMBERLAND, PA 17070-0173
Attorney for: PLAINTIFF
Telephone: 717-938-6929
Supreme Court ID No. 59012
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF/PETITIONER
Vs.
ROY G. REEDER
DEFENDANT/RESPONDENT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 09-6146
i
CIVIL ACTION-LAW
MORTGAGE FORECLOSURE ==°
-i
PLAINTIFF'S PETITION FOR RULE TO SHOW CAUSE WHY
LEGAL FEES AND COSTS INCURRED BY PLAINTIFF IN THE ABOVE
sv
CAPTIONED MORTGAGE FORECLOSURE PROCEEDING IN THE AMOUNT
OF $5,625.36 SHOULD NOT BE ADDED TO THE MORTGAGE OBLIGATION
DUE TO PLAINTIFF BY DEFENDANT
AND
WHY THE JUDGMENT IN FORECLOSURE SHOULD NOT BE VACATED
WITHOUT PREJUDICE
Plaintiff, by its attorney, Karl M. Ledebohm, Esquire, petitions the Court to issue
upon Defendant a rule to show cause why the relief requested herein should not be
granted, and in support thereof avers the following:
1. Pursuant to Local Rule 208.3(a)(2), no judge has ruled upon any other
issue in the same or related matter.
2. No attorney has entered an appearance in this matter on behalf of
Defendant and; therefore, Local Rule 208.2(d) does not apply in seeking
?t
Ca
the concurrence of opposing counsel is not possible.
3. Plaintiff commenced this foreclosure action by filing a Complaint in
Mortgage Foreclosure (the "Complaint in Foreclosure") on September 10,
2009, to the above captioned matter.
4. Judgment was entered on February 18, 2010 in the principal amount of
$83,302.58 (the "Judgment").
5. Since the date of the Judgment, Defendant has requested Plaintiff to
reinstate the mortgage obligation which is the subject of the Complaint in
Foreclosure (the "Mortgage Obligation") and Plaintiff has agreed to
Defendant's request to reinstate the Mortgage Obligation conditioned
upon Defendant paying current the past due principal and interest due
under the Mortgage Obligation and further conditioned upon outstanding
legal fees, expenses and costs in the amount of $5,625.36 being added to
the principal balance due by Defendant to Plaintiff under the Mortgage
Obligation as permitted by the underlying Note (the "Note") and the
Mortgage (the "Mortgage"). A copy of the Note and the Mortgage are
attached hereto as Exhibits "A" and "B" respectively and made part
hereof.
6. Defendant agreed to Plaintiff's conditions set forth in paragraph 5 above
and on March 1, 2010, paid to Plaintiff the past due principal and interest
required to bring the Mortgage Obligation current.
7. By signing the Note and the Mortgage, Defendant specifically agreed,
among other things, to be responsible for the payment to Plaintiff of costs
of collection including reasonable attorney fees and specifically granted to
2
Plaintiff a security interest in the Property described in the Mortgage and
the Note to secure payment of, among other things, all expenditures of
Plaintiff in connection with the loan or in realizing upon Plaintiff's
collateral.
8. Legal fees, expenses and costs incurred by Plaintiff in this matter are in
the amount of approximately $5,625.36, calculated as follows:
a. Legal fees and costs $4,611.68
b. Sheriffs Sale costs 1,013.68
c. Total fees and costs $5,625.36
9. Legal fees, expenses and costs in the amount of $5,625.36 are well within
the limits of such expenditures reserved to Plaintiff for collection under
the Mortgage and the Note.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an order;
a. Authorizing Plaintiff to add to the principal balance of the Mortgage Obligation
due to Plaintiff by Defendant legal fees, expenses and costs in the amount of
$5,625.36; and,
b. Vacating the Judgment without prejudice to the filing of a future complaint in
mortgage foreclosure or the exercise of any and all rights of Plaintiff under the
Mortgage Obligation as to any future default.
Date: April '-74-'' 2011
sari M. Leaenonm, hsq.
Supreme Court ID #59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717) 938-6929
Attorney for Plaintiff
3
5000 Louise Drive, P.O. Box 40
Mechanicsburg. PA 17055
IV I
M EMBERS 1"
nawoanhroe
Wiw-oPAL AMOUNT
ERS NAME AND
REEDER
NE RD
VARIABLE
ANNUAL PERCENTAGE FINANCE CHARGE: Amount Financed
id
d t The mount of Total of Payments: The amount
our you win have paid after you have
u or on
o y
e
credit prov
RATE: The cost of your credit as a The dollar amount this credit will behalf. y
o
made all payments as scheduled.
yearly rate. ' cost you.
9,14 % 0 $ 50,888.88 ` $ 95.000.00 • $ 145,686.68
Variable Rate: If your bars has a vorNble note as ktdkaled above pr Annual Pedantne Rote mail kwasas Aurkp
The
dais mcrah the tern of this transaction It the (index) nJtanpos. The
rata will never be Npher than the maximum rela allowed by
.
cr•dk union will add s margin of to the index value. The role wW dmge monthly on the "day
and h wB never be less than . My kseesl rate kwaasas wNl reeuh N mare payments or she sent- amount. F
taw a Example, rt your loan "a l or $5.000 at 15% for 48
,
months and the Annual Percentage Role irwossad by 2% alle one year, tie farm of your loan would increase by I wo months
•Pnlerred Rate: If checked, the logowing applies to yaw ban:
Automatic Payment Discounted Rate: BecaYN you have to m"a your required monthly payment
NTAGE RATE has been W==1 ra0%. TM ANNUAL PERCENTAGE RAT
thrWph N sulornotic deduction from your Checking SarNpa
dstloMd above In the ANNUAL PERCENTAGE RATE box is
unt. yw ANNUAL PERCE
This rate will Increase by .20%If you cease the outor afc payment arranp
rtrnt Discounted Rate
malic Pe
N
Z amsnt or tail b mairasIn sufficient lands In your arcounl to
i
10%
t
d R
t
i
.
y
O
cover the automatic payments. In such a case, the affect of the increase will be b extend the term d yw ban. Fo
our rote WIN xhcrasse l0 10
ement
t
ran
i a
e
s
scoun
e
example, If your Automatic Payment D
.20%. resulting in 1 additional payment.
, Y
c paymen
ar
g
on a $5,090.00 loan for 60 months and you vase the automat
Variable Rate P If your ban Is a inuloble role
NUALThIs
'
o
k
new preferred ANNUAL PERCENTAGE RATE will en vary accord" to 95 in The Index (in disclosed b"
refens ANNUAL PERCENTAGE RATE w
hW * "let N
low
in a variable two
o). F example,
ill be WA%. Your IMual preferred ANNUAL PERCENTAGE
p
PERCENTAGE RATE W 12% of the time you take the ban, yaw n
RATE ,All then very acdording to the Index, as disclosed In the "Van" Role" provision above.
our bars is a fixed raw ban and you quality for a preferred rob, your ANNUAL P
d Loans
h
d R
Fi
P
fa
RCENTAGE RATE win be the preferred ANNUAL
.
y
ate
r•
m
xe
PERCENTAGE RATE disclosed above for as long as your preferred status remains in ehect.
Number of Payments Amount of Payments Payment Fmquwwy When Payments An Out Property Insurance: You may obtain property
Insurance from anyone you want that is acceptable to
Iryyou got the Insurance from the
the credit union
y°h'r 119 $1214.07 Monthly Beginning 07/16/2006
Ply
- .
credit union you win pay
adul
isel e: 1 $1212.35 Final Due - On 0811&7018
te
$ N/A
S"uriry: Coasleral severing other loans with the credit union this goods or Property
wig also sews This loan. You am giving a security interest in a being purchased. ie
El (Describe):
your shams and/or deposit in the credit union, and:
Ute Charge: If a ment 's late by 10 days of more you win Rrq-w-p- It Balance: The Annual Pen;
W Uurped a IMe be 0151.1 your udndulad payment. W take into W=uM your raqured deposit balenc e ale does Filing F••s: Non-Filing Insurance:
, M any. $ WA s WA
Is you iosy o sany, you w na web payaponalry. yaw aril
l)
-.' m••n. satlmsr. r. ededaad OW nod ptowshe noun a and pone
a
Pon amp narvoymon , gem^ any r rsplyhrom at 1.
wa.
I I CIYIIL^ I awry Vr
AMOUNT FINANCED $ 95,00D,00 Amount Paid to others on your behalf (o scribe)
AMOUNT GIVEN TO YOU DIRECTLY $ 95,000.00 $1, To Mnmwfa LN' $ To
$O.W To uweots4w i To
AMOUNT PAID ON YOUR ACCOUNTS S To $ To
$0.00 To Fees
PREPAID FINANCE CHARGE $ 0.00 $ To Anil $O"Aw" i To Also solutions
OTHER (Describe): 113 KLINE RD SHIPPENSBURG, PA 17257
YOU Pledge Shares 1 AMOVNT ACCOUNT NUMBER AMOUI
and/or Deposits of = $
You apree thal the terms and conditions Inthe dlsebsun sulenMl and iM ban and securRy agreements local
then one banower, we agree out ail the conditions of the ban and security ogmwanb governing this ion shat
received a copy of the ban and security agreements and d)Sddlure Statement. Co•s"r, B You sit signing as
contain" on page 2.
CO-MAKER OTHER OWNER •-C"IGNER DATE
BOR R5/,SIGHA ,VRE 1 DATE
X V ?jCJ (SEAL) t/
? CO R ? -OTHER OWNER ? ••COSIGNER DAT
X (SEAL)
E) CO-MAKER 'OTHER OWNER 0 '-CO-SIGNER DATE
CD CO-MAKER C] 'OTHER OWNER 0 •'C0.SIGNI:R DATE
X (SEAL)
orNU owas: sIy •anw, tow n...eraaarq.rwrrn row. sew r.nraw w kiwal r •w atww •eeera•e tow nor,. neI•.tnraew
..sx..,h-, xr • wewaY Mwwh M .,• W:?wl r raYM. r ew Yway AM.x.w^h• ••cOLONaa: flew Yrs. M swal,w?n wM ref
.wrwnw .rues d alas- Y sAra ?. w sea vJe "-.I. M eeYM M rw.
APPLICATION FOR GROUP CREDIT INSUI
sew. a ill so"- r ana• assn, nJ wwwsMr.r
M purwr •1 toy M J saws M r ew Ito. Tits
?e) an all er Oedl ? ehrehw 4lvwapels) aateWd Oats eIe ogre- b pay srreglses P?• t ) LsnOlatane M kill •eY W paroo( ae aetser In ooareoon will this oawsg• to the c;r•ono
Iw•) uroana due h purd?ssa a see krtxwnas 4 wfanley slid not rpWMN ado b ebtenondt dhat I Mal may tamyrr d Machine. Iwo) undrsled N•1 t ynl hie Ireu ants, u WOW. w
man a ptih •na khdwdlat•r hea• undue lie loan. ant that colpra are guarwnbr 111 rat •tpbla he W VIKa. AANT C?A PL Nr
n. ratowMe ewsearr 1 .w ;mars. smwsnd te awmoM my (W h «gIWRy rer fir aorta: s
I (ApphWN b No NMlran,,e awarage only) this you be under ego TO on pall W THAN awMtly alb of your toan7 X
2. (App4coM o du My cowrepe otx(') WN Wu a Ybo age To on ale sgbelllq nabW) dal ai r bII ANOere yp+peaen working
outso• your Ilona for wage n or Poat a>0 Mls a mac Pa' wait atl NN Iran so woAYg W 7v cons o man bebr efia oet•j ? a ED E
N .edition, If your low excess If A000.00 the 1"awing spragan swat also be mswred M WNW t• dOW"I a sophistry,
3. Wire ve far t x. ears. na,. you peen IneOesYr aM•s0 a a.eas lor rarxar asaa a Drwuq awry "ON 0110"I
? 0 ? o
amnia. Acgw" bT•r,r a s S .0 1. In e NI061 ball aor ADS R.axW CenfPln tAR
am y lour) slr.w. b er Was V+akaen are aura b my 1oer) Wwnbags and WI•1 , y sa-aoWkat• a 1 kip Iii an /a• st r con 1 din urhowat•roW I Vs. Denim I. nom «VNm b
4+axrv are
rwii nut w Mw.a. d rtry w•eDDLarx a 1 anaww Yu' b quadan 7. tw rrarea+d IMt w v •plga(looyl Nvenq W b an armW n01 •IC•adle 5 1.00
The an.cnne OMs of ray low) ir-o nw •1N be we dal ar thiss=Ion Any person Wr knq•?ally that ran kaars to defraud any lnwerca Win, a dh.r person roes n apycatbn for inaursnc•
atsl•m.nl or claim c•maNb,v any erlerleay, f«se Nlomlallan er canOMls for the p Wsse dbnbbsNq. Information DorrrmYq My tact drbnY fMnb eommka a fnudulw Vann c1,
will I. a crime and subjects +utlh person to criminal and cINI parishes. Do net sign this Application N elY aooaca0repegt ire blsrit This ppacadon MN ran so ..ad.. r:onraNDx.a epplelubk
blank .pa:.s hoe rid been comptef.d, the dealer has not slgned and dal" go application and If the to c Ms not been stood.
CREDIT INSURANCE APPLIED FOR: NOTE: ONLY ONE-APPLICANT MAY APPLY FOR DISABILITY COVERAGE.
?,Yes Q No Single Credit Life Total Premium CD Yes Q No Credit Disabilty Total Premium
? Yes ?X No Joint Credit Life
Indicate wfllch applicant(s). ? Applicant El Co-Apparcant $ 0.00 Indicate which appgcant(s : ? Applicant ? CoAppsom f 0.00
You am cow" ory la the y; n d comrspe forwhiah a thwg• Is InSoud nth'd spplo.on. I
JAPPLI TS SI NAT DATE OF BIRTH DATE C0.APPLICANT'S SIGNATURE DATE OF BIRTH DATE
X o 6- ode X
WTNES TE SECONDARY BENEFICIARY (APPLICANT) SECONDARY BENEFICIARY (CO-APPLICANT)
u Y V
MHC-0)140077 SERNORD F. aaIas Rev 1N7 nun C[-oayee. Inc. All npnu I.-
Exhibit "A"
page 2 of Nis document shag apply to this ban. If there b moe
f to both jointly and severely. You acknowledge that you have
net, you acknowledge receipt of the notice to co-signer
(SEAL)
D CO-MAKER
'OTHER OWNER C] -CO-SIGNER
DATE
X (SEAL)
X (SEAL)
5 ROY G REEDER 1155386 I I- 1 05MnO06
THE WOROS 'CREDIT UNION' MEANS MEMBERS IST FEDERAL CREDIT UN
S
N
SA
BO
O
RR
S)
ANED
WER
S
LOAN AGREEMENT SECURITY AGO
Payments/Finance Charges: For value received, you promise to pay, at
the Crsdd Union's office, all amounts due. All payments shall be made
You
f this document
nt
n
1
l
t
h
di
t 1. Tosew??t1rep oPn
gent W the
.
eme
page
o
o
e
sc
osure s
a
pursuant to t
understand that the finance charge and total of Dayments shown on page i
don that alt instalment ppa manta
based on the aaaum
f thi
d
m
nt
r Doa of IN
tu6stltuaon
insurance of
p
a
o
s
ocu
e
e
will be made on the scheduled due dates, and , if you have vu IdUd for
f
le
r
d secured pro
a
c
a
e
that pra
r
preferred rate that you continue to satisfy the conditions o
rate. If you. fall to ay any instalment by a time N is due, you wlk pay
additional stteres?on the overdue amount. rovsao
.
other b.n B?
Borrower v%
Allocation of Payments and Additional Payments: Payments and ecuning and
15013 owda
i
credits shall be applied In the following order: any amounts peat due; any
fees or charges owing, including any insurance premiums: accrued Interest ven. a
g
money n
or finance charges: Outstanding principal. Payments made In addition to 2. iyh. 4 N
regularly scheduled payments shall be applied In the same order.
Preferred Rate: If you quality for a preferred rote as disclosed on paps 1 of
d
d
t
dd
d
f 3 You warrant I
W=0
um, you un
ers
an
erred role a
en
this document or in a separate pre
that you must meat lhro Cbndhlons dlsdosetl to you in order to gwlfy for the
k
i
i
d
( Piece•
Y
il
tions
n or
er
o
eep
prelertsd rate, and must continue to meet Iflbse p9nd
your preferred rate. If you fall to meet those conditions, your rate will ou W
l pay r
g.
2,59 tiod and
M shalt
increase, thereby exterldNlg the larms of your load. You pDtortNee to OOnIkNJ6
making payments and to meet all obligations under this Agreement even !f pi?rrt Wva
you no longer receive the preferred rate. 5 you will main
Late Charges: If you make a late payment. you agree to pay a late charge
if one is disdosed on page 1 of this document, aedk union n
a,wum Baird
Property Insurance: If you obtain a ban secured by a motor vehicle or
other tangible property, you must obtain insurance which protects the credit
union from financial loss
The amount and coverage of the property N such
K i
wow
.
insurance must be acceptable to the credit union. Such a pbticy must
provide at least fire, theft, combined additional coverages and collision
i
i
P
t
th
bl
l
d assign a the
de prooerh
You
i
e
Insurance. It must conta
n a Loss
aya
ause en
orsemen
nam
ng
e c
credit union as lien holder. You may obtain this Insurance from only agent of
i
i
h ?s
the =0
va unit
your choice and direct the agent to send the cred
t un
on a copy o t
e
pdiuy, ry?
is D: neo4i
Debtor Responsibility: You promise to notify credit union of any change In
your name address or employment You promise riot to apply for a ben If
know t11ero is e reasonabl
robabiil
unable to
o
that
ou will b
e
a You a,tn OWN
?union W
I Yin
y
u
e p
y
p
y
e
yy
r
your obligation according to the terms of the credit extension. You romfse a. Should the cn
to inform cred'd union of any new information which relates to your ability to
repGay your obligation. You promise not to submit false or inaccurate
Intomrslion or Milfully, conceal Information regarding your creditworthiness d?iwed in
asrw1p
der es
welt 11l
low
,
credit standing, or Credit capactty. .
7. It a default as
Statutory Lion: If you are In default, federal law gives the credit union the
right to apply the balance of shares and/or dividends in your accounlls) at
rho time of? udetault to satisfy this ban. Once you are In default the cr l
union may exercise this right without further notice to you.
Delay In Enforcement: Credit Union ma delay enforcing any of the credit
union rights under this agreement with loskg them.
Irrogular Payments: The credit union may accept late pa=ts or partial
payments, even thou4h marked 'payment in full, without losing any of the
cede union rights under this agreement.
be eegwUy rospoonsWk wRh thetb rroofi we?r, bunt adscrodNmnion ayy sue a to
eititef or both 61 you. The credit union does not have to notify you that this
agreement has not been paid. The credit union may extend the terms of
payment a y atiNs any sec i ty without notifying or releasing you from
Contractual Pledge of Shares' you pledge ON your shares and depositsin the
credit union, Including future additions, as security for this ban. In case you
default the credit union may apply those shares and ONPOfps b the payment
Of 49 lung due at the alma of defauk, Including costs of collection and
reasonable afeen, oy% foes, that the credit union may Incur, up to 20% of the
unfold principal and Interest No lien or night to improve a lien on shone and
deposits ahall apply to any of your shores which may be held In an 'Individual
Retirement Acdounl' or'Keogh Plan.'
9.
9.
to. Tnis , t
hale
You are being asked to guarantee this debt. Think carefully before you do. If the borrower doesn't pay
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
amount.
The creditor can collect this debt from you without first trying to coked from the borrower. The creditor c
can be used against the borrower, such as suing you, 99arr9gshiny your wages, etc. if this debt Is ever In
record. This notice is not the contract that makes you stable fir the debt.
THE WORDS 'YOU,"'YOUR" AND 'YOURS" MEAN THOSE
ihl i?an or for any
re N amounts
are
1 bulbs Of, sea or transfer the colateml unless you nave
written oOn .14
are pgod Nile to ft coastal tree N sa security Interest$
i rxedit singe and except ter any interest of a myrco-
M.arsl who has started Ina adresrrent In ft indicated
rowy?M cored NN?y? In s
ore's r ef(tamaned will defend ail prop.ny
veldde or other property in welch the
nsur*nca wilt De in a firm and an
w vie eypply the rredll union with proof
redlt union to andoras any check or dron provided as
'once, and apply those proceeds to the sums owed to
k2 i0rdei Iun Yon _ povid* ty?in hturance S*nica Center
era?t?n goals coverage.
ranee er any? extension M.raol. nlaud by INe credit
you NdWlduaq but Is primarily fof the protection of tied
union haa;
lawful
nil
N the
it- and
Non. If
on may
any
f?Wfill lei k ill This M
not only Will you, but your execulors, administrators.
5100 2/99
e debt, you will have to. Be sure you can afford to
/ pay late fees or collection costs, which Increase this
n use the same collection methods against you that
efaull, that fad may become a pan of your credit
F. 43759 1102
APP90 Spam, sic . 2241070
Page 2 of 2
Prepared By: Members 1st FCU
5000 Louise Drive
Mechanicsburg, PA 17055
When recorded mail to:
FIRST AMERICAN TITLE INSURANCE
LENDERS ADVANTAGE
1228 EUCLID AVENUE, SUITE 400
CLEVELAND, OHIO 44115
ATTN: NATIONAL RECORDINGS
PoLre'e1 Made
3011 ao3 a4bo'14
ROY G REEDER
MORTGAGE
06/06/2006
Between
BE,?
NOGG Jul, ? A('J I G 29
llo? Ao?
(hereinafter cal le "Mortgagor"
And
MEMBERS I ST 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
$ 95,000.00 , lawful money of the United States of America, and has provided therein
for payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with
interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and
containing certain other terms and conditions, all of which are specifically incorporated herein by
reference;
Now, Therefore, Mortgagor, in consideration of said debt or principal sum and as security for the
payment of the same and interest as aforesaid, together with all other sums payable hereunder or under
the terms of the Note, does grant and convey unto Mortgagee,
All that certain property of the Mortgagor located in SOUTHAMPTON
TOWNSHIP , Cumberland County, Pennsylvania
SEE EXHIBIT" A"
which currently has the address of 113 KLINE RD _
[Street]
Shippensburg Pennsylvania 17257
[City]
Acct No
AppID 155586
Exhibit "B"
[Zip Code]
Page 1 of 4
8K ! 957PG2904
Together with the buildings and improvements erected thereon, the appurtenances thereunto
belonging and the reversions, remainders, rents, issues and profits thereof.
To Have and To Hold the same unto Mortgagee, its successors and assigns, forever.
Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum,
including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder
and under the terms of the Note, together with interest thereon, and shall keep and perform each of the
other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby
granted and conveyed shall become void.
This Mortgage is executed and delivered subject to the following covenants, conditions and
agreements:
(1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any
future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and
intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall
be added to the principal debt.
(2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and
discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water
rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon
any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt
secured hereby, (b) pay all ground rents reserved from the mortgaged premises and pay and discharge all
mechanics' liens which may be filed against said premises and which shall or might have priority in lien
or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax,
including interest and penalties thereon, if any, now or hereafter becoming payable on the Note
evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums
and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time
require upon the buildings and improvements now or hereafter erected upon the mortgaged premises,
with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear,
and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing
charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge
the foregoing charges be paid in installments to Mortgagee.
(3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and
substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the
mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair
of the buildings and improvements erected thereon.
Acct No 411101111? AppID 155586
Page 2 of 4
BK ! 957PG2905
(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 or 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 sc veral.
Acct N? AppID 155586
Page 3 of 4
BKI957PG2906
Witness the due execution hereof the day and year first above written.
ROIAG REEDER
Commonwealth of Pennsylvania
County of Cumberland
ss:
On this, the 6th day of June ,2006 ,before me,Luarlne E. Kyle
notary public the undersigned officer, personally appeared
Roy G . RPPCiPr 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 offici 1 seal.
??/)I'f f- V///
/
My commission expires:
COMMONWEALTH OF PENNSYLVANIA
ary Public
=ShippensburgBoro, al
berland County
Jan. 20, 2009
M ember. Penneylvsnle Association of Nal&rl@g
Certificate of Residence of Mortgagee
Members 1ST Federal Credit Union, Mortgagee within named, hereby certifies that its residence
is 5000 Louise Drive, Mechanicsburg, PA 17055,
By
Acct Noodimm-p ApplD 155586 Page 4 of 4
OR I957PG2907
EXHIBIT A
All that certain property situated in the Township of
Southampton, in the County of Cumberland, Commonwealth of
Pennsylvania , and being described as follows: 39120324024.
Being more fully described in a deed dated September 18, 2003
and recorded October 24, 2003, among the land records of the
County and State set forth above, in Deed Volume 260 and
Page 125.
Permanent Parcel Number: 39120324024
ROY G. REEDER
113 KLINE ROAD, SHIPPENSBURG PA 17257
Loan Reference Number 155586
First American Order No: 9634769
Identifier: FIRST AMERICAN LENDERS ADVANTAGE
11111111111111111111 IJII REEDER
9634769
FIRST AMERICAN LENDERS ADVANTAGE
MORTGAGE
1111111111111111111111111111111111 I Certify this to be recorded
In Cumberland County PA
f II"!!
Recorder of Deeds
8 I957PG2908
04113/2011 16:51 7179320317 KARLLEDEBOHM PAGE 06/10
MEMBERS IsTFEDERAL
CREDIT UNION
PLATNTIFF/PETITIONER
Vs.
ROY G. REEDER
DEFENDANT/RESPONDENT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.: 09-6146
: CIVIL ACTION-LAW
: MORTGAGE FORECLOSURE
VERIFICATION
I, Dan Summers, Collections Manager for Members 1'? Federal Credit Union,
being authorized to do so on behalf of Members I"t Federal Credit Union, hereby verify
that the statements made in the foregoing pleading are true and correct to the best of my
information knowledge and belief. I understand that false statements are made subject to
the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to
authorities.
Members 1 st Federal Credit Union
By: tGrYU - - --
Dan Summers, Collections Manager
4
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF
ROY G. REEDER
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
: NO.: 09-6146 Civil Term
CIVIL ACTION -LAW
MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, Karl M. Ledebohm, Esquire, hereby certify that on the 28 h day of April, 2011, I
served a true and correct copy of the foregoing Plaintiff's Petition for Rule to Show
Cause upon the following individual by first class mail, postage prepaid, addressed as
follows:
Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
Respectfully submitted, 1?
Date: April 28, 2011 r
Karl M. Ledebohm, Esq.
Attorney for Plaintiff
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
Karl M. Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070-0173
(717)938-6929
MEMBERS 1 J' FEDERAL
CREDIT UNION
PLAINTIFF/PETITIONER
Vs.
ROY G. REEDER
DEFENDANT/RESPONDENT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA c
-I
=r rj
-
r
NO.: 09-6146 c s
`.0
rte;?'^
--fi ca
y
CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
ORDER
i
N
AND NOW, this day of 2011, upon
consideration of the foregoing petition, it is hereby ordered that:
(1) a rule is issued upon the Respondent to show cause why the Petitioner is not
entitled to the relief requested;
(2) the Respondent shall file an answer to the petition within twenty (20) days of
service upon the Respondent;
(3) the petition shall be decided under Pa. R.C.P. No. 206.7;
completed within -c?ays-ofItm-date;
(5)_ argt tshalfbe Field on , 2011_ f -Corntroo of the
14 -
?- o ouse; an -
(6) notice of the entry of this Order shall be provided to all parties by the
S
Petitioner.
By the Court:
Notice addresses:
Defendant/Respondent:
Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
Plaintiff/Petitioner
Legal counsel for Members 1St Federal Credit Union
? Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173
Karl A Ledebohm, Esquire
P.O. Box 173
New Cumberland, PA 17070
(717)938-6929
MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS
CREDIT UNION CUMBERLAND COUNTY,
PENNSYLVANIA
PLAINTIFF
: 09-6146 Civil Term
NO
.
ROY G. REEDER CIVIL ACTION -LAW
DEFENDANT MORTGAGE FORECLOSURE ,
cn C
CERTIFICATE OF SERVICE
I, Karl M. Ledebohm, Esquire, hereby certify that on the 4t' day of May, 2011; I
served a true and correct copy of the attached Order upon the following individual by
first class mail, postage prepaid, addressed as follows:
Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
Res y submitted,
Date: May 4, 2011 Wfor Karl , Esq.
Attorney Plaintiff
Supreme Court ID #: 59012
P.O. Box 173
New Cumberland, fA 17070-0173
(717)938-6929
J
Karl M. Ledebohm, Esquire
P U. Box 173
Ne" Cumberland, PA 17070-0173
('17)938-6929
MEMBERS 1" FEDERAL
CREDIT UNION
PLAINTIFF/PETITIONER
Vs.
ROY G, REEDER
DEFENDANT/RESPONDENT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
,
PENNSYLVANIA
=M r
z -< 7
. -`
NO.: 09-6146 <
CIVIL ACTION-LAW
MORTGAGE FORECLOSURE
ORDER
AND NOW, this day of 1,t 2011, upon
consideration of the foregoing petition, it is hereby ordered that:
(1) a rule is issued upon the Respondent to show cause why the Petitioner is not
entitled to the relief requested;
(2) the Respondent shall file an answer to the petition within twenty (20) days of
service upon the Respondent;
(3) the petition shall be decided under Pa. R.C.P. No. 206.7;
---(4}--depositi-ort ialTbe completed within __ clays o It's-date;
(5) argument shall be held on 2011 inC-ourtroom of the
-Curnberland-C-oun ou ho`use; and _ _
(6) notice of the entry of this Order shall be provided to all parties by the
Petitioner.
By the Court:
v
J.
Notice addresses:
Defendant/ Respondent:
Roy G. Reeder
113 Kline Road
Shippensburg, PA 17257
PlaintiffTetitioner
Legal counsel for Members I" Federal Credit Union
? Karl M. Ledebohm, Esq.
P.O. Box 173
New Cumberland, PA 17070-0173