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Home My WebLink About09-6253iKarl A Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1" FEDERAL CREDIT UNION PLAINTIFF Vs. LOUIS E. SABO a/k/a LOUIS E. SABO, JR. DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. C Q- (oa'.53 t l em CIVIL ACTION -LAW MORTGAGE FORECLOSURE NOTICE TO DEFEND AND CLAIM RIGHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 NOTICIA Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las 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 objectiones a las demandas en contra suya. Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar Una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THE THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUESTS US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: 01- 6.2Y3 ?c f Tlc LOUIS E. SABO A/K/A LOUIS E. SABO, JR. DEFENDANT : CIVIL ACTION-LAW : MORTGAGE FORECLOSURE COMPLAINT AND NOW, comes Members l St Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the following complaint: 1 1. Plaintiff, Members 1 St Federal Credit Union ("Members 1" ), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Louis E. Sabo a/k/a Louis E. Sabo, Jr., ("Defendant'), is an adult individual having a last known address of 243 Cumberland Road, Camp Hill, PA 17011. 3. On or about April 22, 2008, Defendant borrowed from and agreed to repay to Members 1St FIFTY THOUSAND AND 00/100 ($50,000.00) dollars (the "Loan"). The Loan is evidenced by a Closed-End Note, Disclosure, Loan and Security Agreement dated April 22, 2008 (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 April 22, 2008, on all that certain real estate and improvements erected thereon situate in Lower Allen Township, Cumberland County, Pennsylvania, known and numbered as 243 Cumberland Road, Camp Hill, PA 17011 (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 May 6, 2008, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office at Instrument No.: 200814707. 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 1St 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 $579.42 each, which amount was subsequently adjusted to $578.76 each, beginning on May 15, 2008 and continuing on or before the 15th 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 $578.76 each for the months of May through August, 2009 as set forth in the Note and as more particularly set forth and describe, in part, on 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. M by lett er dated July 16, 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. A copy of the electronic tracking confirmation evidencing the mailing of said Notices is attached hereto as Exhibit "E" and made part hereof. 11. 12 13. 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 l St. The Notices forwarded to Defendant in said manner have not been returned to the offices of Members 1St as undeliverable or otherwise. As of September 15, 2009, Defendant is indebted to Members 1St in the amount of FIFTY THOUSAND NINE HUNDRED FIFTY-TWO and 94/100 ($50,952.94) dollars itemized as follows: a. Outstanding principal $47,288.12 b. Interest to September 15, 2009 1 ,049.06 c. Late fees 115.76 d. Attorney fees 2,500.00 e. Total due to Members 1St as of 9/15/2009 $50,952.94 The above attorney's fees and expenses above 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 Sheriffs 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. Defendant will be responsible for actual reasonable legal fees incurred by Members 0 in this matter subject to any limitation contained in the Note.. Defendant also agreed under the terms and conditions of the Mortgage that in the event of default there under Defendant would pay, in addition to the 4 amounts set forth in paragraph 12 above, costs incurred by Members 1St as a result of the institution of these legal proceedings. 14. The obligation owed to Members 1St continues to accrue interest at the rate of $8.0196 per day, through the date of payment and continues to accrue late charges and attorney's fees. 15. As set forth above, Members 1 St has made demand upon Defendant to cure the default under the Mortgage and the Note. However, as of the date hereof, Defendant continues to fail and refuse to cure the default. WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment against Louis E. Sabo a/k/a Louis E. Sabo, Jr., in the amount of FIFTY THOUSAND NINE HUNDRED FIFTY-TWO and 94/100 ($50,952.94) DOLLARS plus interest at the rate of $8.0196 per day, through the date of judgment entered on this complaint and at the legal rate thereafter until the date of payment, additional legal fees and costs of suit and for foreclosure and sale of the mortgaged property. Date: 1?- /q- O 7 Respectfully submitted, Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff 5 1ST CLOSED-END NOTE, OISCLOSUR I DAN AND SFCrIRrTy pT:RFFMF SDDD Louise Mechanicsburg. PPA.O1. Box 7055 417 BORROWER'S NAME AND ADDRESS Drive, Mechanicsburg, I LOUIS E SAGO 243 CUMBERLAND ROAD r.,vuiY S P HILL_, PA 17011 ACCOUNT NUMB SOCIAL 1-11 26531 6531 .0 -07 Pft 8.19% CPBORROWER'S NAME IHCIPAI AM(.i LOAN NUMBER OPBORROMR-5 NAME Q?Q 00 DA OF 9F,7,19. FO W4/2 MATURITY IAIITA?, 2 2005 X FIXED O VARIABLE ANNUAL PERCENTAGE FINANCE CHARGE; Amount Financed The amount of T RATE: me cost of your credit as a The dollar amount the credit will credit Provided to you or on our olel Of Payments The amount yeany rate. ' cost you. behalf. y you will have nt after you have made all Payments as scheduled 8.19 % a $ 17,315.71 e $ 50,000.00 $ 68,520.23 di blo R.I.; II your loan has a was in rate as Ind1t01ed above We Annual p ,m ercanlage Rare may it"Cl961e during the lerm of this lrenaetlmn if the gndex) Changes. The ' lue, awarl end union will never be le,, margin to IAny infix vast relo hinc er ate will change month y on the 5ral day of Iho month. The role will never be higher than, the moxlmum .to allowed by hs and the Annual Percenla00 Role increased by 2% alt mont er one year, the term of your loan would ncreasa Dy Iwo monI, a your loan was or 55,000 eI 15% for 48 'Pratarfed Rale: If checked. the lollowln0 epplla• to your loan: ® Automatic Payment Discounted ReU: Because you have Slimed la make your mqulred monody payments tMaughden aulomelic deduction from Your Checking/Sovings Account, Your ANNUAL PERCENTAGE RATE has been dlscounled by 20%. The ANNUAL PERCENTAGE RATE disdose RATE box 1• the AmomaBC Payment u It n such ucch a hla. oaseThis tote will e Increase by .20% If a b you erase the outom"C payment arrangement or tail to ove in the maintain ANNUAL cumdenl funds in your PERCENTAGE .-_t to cover the auto (or 60 Payments. sthe e effect of the Inaeese W be to extend the lerm of your loan. For axsmpk on a $5,000.00matic 1oan for 60 rronlhs and you cease the automatic Payment arR, resuldnp addltianef payment. npemenl, your rate wls increase to 10 .2D%, II yyourin 1 Automatic PaymaN Diacounutl Rsle Is 10% Wrlab4 Rare PraJelrad Ldana. 11 yew loan Is a eroleloon and Of variabl you quakJy for a pRtanetl Rla, your prelene discount Ia taken al the time n. you Ieka ou1 r your ban. This oitial pretrrted ANNUAL PERCENTAGE RATE will IMn vary accordlnp to Uargea In the Ibex (ea disaoaed above I. For example, if 81 the re le ban's - ANNUAL Initial PERCENTAGE RATE is 12% el the Ame you take the loan, you Initial prelened ANNUAL PERCENTAGE RATE cola be NIA%. p YOU' a, ini1191 preferred ANNUAL PERCENTAGE RATE w/ll men very eccominp o the Index, es dlsdosed In Ihe'Vedable Rale• provision show. PERCENTAGE IRATE WsUpseO above fortes long p I our prefemsd alaluel nmein? i rarys?lm1•, yourANNVAl PERCENTAGE RATE will be the pre/erred ANNUAL Number of Payments Amount of Payments Payment FRquanry When PaymenU Are Dua Property Insurance: You may obtain property Yw P.ymam t 19 $579.42 Monlhl Be Innin msL ante Iron anyone YOU want that Is acceptable to SNaaw. Y' B 9 05/15/2006 the credit union. If You get the Insurance from the ll wula: 1 5576.25 Final Due On c NIA union you wi pay securlry: Gonalarel secunnA oNer loans with the 04/1512018 $ redtl crodll union von arse secure 07s ban. you era piNnp a unry inlereslin ulr goods or Pope, OIMr Your shares anoror deposit to Ina credit uNon, se0and: a hemp purchased. Describe) Late Chu:: If late a (ea pay of ment 5% is of late your sc by 10 dayshadukdp a men you will Roqulrod Deposit 84 once: The Annual Percentage Rate does Filin Feoc: ba durpetlayrtxnl. not lake into account your required deposit balance, if any. IAA Non•Filiny Insunncr. I hus".: k: yr .a r r"y not ova o pay a Peru y. tour eenlrsl $ IA ! mr.m..r. .... _....__.. _ ___. _ $ N $ AMOUNT GIVEN TO YOU OIRECTLY S AMOUNT PAID ON YOUR ACCOUNT $ PREPAID FINANCE CHARGE MAKE MODEL 50,000,00 Amovnl Paid IOOlhers on your b9half (Describe) $ To 50,D)0.00 i To S $ To T ro o $ To $ $ To $ To To $ To $ To is To S To $ To $ To S To s $ To 0.00 $ To To s To Ae»d Ski $0.00 $ TO F.•. ' "-2`-?l"-,•^-- SECURITY INFORMATION '----'""+__ _..,_-,_. TO Alt Md 6oluliem YEAR I.D. NUMBER TYPE VALUE OTHER (Describe): 247 CUMBERLAND ROAD anoror Uepos11S Of ) $ I 1--hl NUMULK AMOUNT ?COUNT NUMBER You ayes Ihel the t I re stelemenl end In loon and Saw ro $ emsnfa c I ° man one bonower, we epro W I as th dllio s or the ban and sectu agree ry eptled on papa 2 01 lhtf d OWmenl shall ap p ly Io Ihta loan . II mare is mom ments one are aligning as w , i received a copy of Ina hen and secudry apreemenla ono tllsdosure slalamenl. C-st r: o If poveminp you Ihlsloan shall a cont a to bolo jointly and sewraliy. Yob acknowledge Thal you nave ined on page 2. pner, you acknowledge receipt 011 0 notice to caslpner BORROWER'S SIGNATURE DATE X 4.-rj C (SEAL) fDC-MAKER O-MAKER 'OTHER OWNER ? "CO-SIGNER DATE ? CO-MAKER ? 'OTHER OWNER ? ••CO-SIGNER (SEAL) X GATE O? 'OTHER OWNE R (SEAL) ? •'CO-SIGNER DATE ? CO•MAKER ? •OTHER OWNER Q "CO-SIGNER DATE (SEAL) (SEAL) O-MAKER ? •OTNEN OWNER ? ''CO-SIGNER DATE GmNeA OV«eAArv pm..,, n (SEAL) Iunbn Asa an<vey rnYrmrln ureNlar ra w~i .ylWgwp nr'a"raranMr err?nrlFt o;i_ annlMe maen.?.4'e meta rM OlMr eymr. wly a?•y.rnYar.h,W Wranrar A'alw Mnpli. ro MrlrA MOr.na •auN NMr..:u4 t^aamvY Aar I.'•CIONle. Upon Nr.,•, n. mm? u..M n•Y.rrlnrrrae'.y aallaudra prv In 0.gy ?e1lnn, •'r Irone»eya•anbryanY one a. arnp.w on lM MnIMInY You are being asked guarantee this debt. Think refully belore you OTICE TO pay it You have to, and Thal you want ca do. If the bonlo weE doesn to accept this respons,Ljilly, P Y the le bl, you will nave lo. le sure you can afford 10 amount. 't a You may have to pay UP to the full amount of the debt It the borrower does not pay. You may also have 10 pay late fees or collection costs, which Increase this The creditor can cotl th this debt from YyOU without first trying to gmllecl from Ina borrower The creditor can use the same colleclion methods (eeoro 7his is no61ce Is not the contract that makes you'l'ade for (g your wages, etc. If this debt is ever in default that tact may aqalnsl you that Y become a part of your credit Paoe 1 of 2 Exhibit "A" I LOUI$ E SAGO LOAN NUMBlfl ACCOUNT NUMBER wTE or LOAN 257394 28531 07 04/22/2006 IN THES AS AGBORRRREEMENR TS$, NAMED )THE WORDS CREDIT UNION" MEANS MEMBERS IST FEDERAL CREDIT UNION. THE WORDS YOU.' YOUR- AND YOURS' MEAN THOSE LOAN AGREEMENT SECURITY AGREEMENT cna,%&a: For value received, you promise to pay, at ice, e8 amounts due. All payments shall be made Mure statement on page t of this document. You nonce charge and total of payments shown on page 1 based on the auumlwoIt that all inategmenl payments cheduled due dales, and , if you have qualified for NJ continue to satisfyy the conditions of that preferred any Installment by Rite lima it is due, you will pay the oYertlue amount. -•• -.• .• eyments and Additional Payments; Payments and creeesIOf Shall e Including any Insurance premiums: accrued interest or finance charges; outstanding principal. Payments made In addition to regularly scheduled payments shall be applied in the same order. Preferred Rate: it you quail ryry for a preferred rate as disclosed on page 1 of This document or in a sepsrate preferred rate addendum, you understand that you must meet the conditions disclosed to you In order to quailly for the Preferred rate and must continue to meal those conditions in order fto keep your preferred rate. If you fail to meet those conditions, your rate will increase, Thereby extending the terms of your loan. You pprromise to continue making payments and to meet all oWlgations under [his Agreement even if you no longer receive the preferred role. Late Charges: It you make a Isle pa merit. You a ree to If one is discosed on page 1 of This oxument. g pay a late charge Property Insurance: It you obtain a loan secured by a motor vehlce or other tangible proper, you must obtain insurance which protects the credit union from financial loss. The amount and covemr of the property insurance must be acceptable to the credit union. Such a poli asulrance, least must conta n oss payable clause enadorserrrlienl ty must nahming the ,edit union as lien holder. You may obtain this insurance from any agent of your choice and direct the agent to send the credit union a copy of the policy. Debtor Rasponslblif You promise to notify ,edit union o! any thanpe in your name address or employmfr`n t. You promise not to apply for a ban it you know there is a reasonable bilit thl be unble 10 repay ur ogation crding Ilia rmodiextension, Ypromise inform l union of any nw ormaon which relates to your reay your oblWill Yu prome not I. submit fat se or Inaccurate in ormalvn or willfully conceal information regarding your credlhv cretlk standing, or credit capadtY. orthlness, Statutory Lion: If you are in default, federal law gives the credit Union the right to axe Iyy the balance of shares and/or dividends kt your acoollnl(s) at Ire lime oPdefaull to satisfy this loan, Once you are illdetaulL hoe creddll union may exercise this right without further notice Iv you. Delay in Enforcement: Credit Union may delay enforcing any or the credit union rights under this agreement without losing them, Irregular Payments; The credit union may accept )ale Payments or partial payments, even tho h marked "payment In full, without losing any of the Gedd union rights un?er this agreement. Co-makers: If you are siggning this agreement as a co-maker, you agree to be equaly responsible wt the borrower, but the credit union may sue either w both of you. The credit union does not have to notify you that this agreement has not been paid. The credit union may extend (he terms of Payment and release any security without notifying or releasing you from responsibility on this agreement. 1. To sscun payment of this ban and all expen4hures Incunsp 0 the credit grant Inc nadlon with this to n, r n r-.Vns on. security rntalsl, you P.14 to off this ddolCtuml?on Th,c reyr urex Inn tits Mvper.tpv dascrlb I on s suranclons , .Id to Litt a untl pros 0r[uaas -'-ids Ira. o Insurance on tIN J10 property and all eamRngs recelvad from the sscwe0property, Crossaollalenllzatlon: Propppppparty, plran cur ucuH Iw this loan or kr my other ken Borrower Aee wi Die cndtt r1 lon wll?eecwe all amounu Borrower owes the croMt tin on row axen If Le tutor However securing another debt will not secure this I%. fsrutch. Ho Howev flhe- . gd er progeny any Dill or 1.1. 1 rrequl rsma%inPr.0r eCScissPon notice, are money household goo s. ). or are nompurchsse 2. You will not phange, the buflon of, sell or transfer the Witaleral unless you heve the credit union's prior wdttan consent 9. Yougw¦rnnl that au hsve goad tine to the Ceealeral, free of all s curiy Mleresls rrlMO., Ow n ed the Creole el ral who has slprieC in srny jnl Ih'•ainron plan. as In r?tl di 4. You will pa all taxes ,agree to assessments, +red Wm against or attached to she preCfrig de -of. a a no wrlhor keep Ins Properly in gqood conohan, housed In a mitols shelter, You 1,2-1 10 execute finanti Clif inrienls and against a adverse Alyd p ante third p ser ary l the credit union's request claims and will dabnO tits pert' 5. You will maintain insurance k gree any whlde a ofhef Drepeny k whidi t'- o Credll union has a security Intense.. tThis Insurance w111 be (n s form and an amount sadsleuory to the uedil unbn You wul wCilly the tit unkp ,NiLn propf a auM insunrke un01 eY auln, d tp asdil ynion arM sewrad by 1Ms roperrryry are reFStd, II YOY IMI b melnaM such tmursnclr' rndn union `hay but P. not requked lo, obis n insurance of our own and add eLe coat of .uC? b the sums owed, This furl vn71 ppe?ar Interest cur the Conastt to I. id. Vol Iurlner eeslgn to the aedd yynion th. r1ph1 to hiatus she proged.01 any Insurance on audit PropaRy, and dtrlq arty fret War to pay moss proceeds dNeuly k uetit union. 4Yeoeu aRmhorize yIa cra c union to endata any one. or dratl poured se the credit . On such msuranp, and appy Those prxeeds to the wan. owed to You (unNr autiwdxe Ire rntlll union k with Prevke1 your IASursnce Service Curler necessary Inlomulkn nor wnrIcaflpn o adequate Coverage. Vou acknowledge Ilia'' Insuranccee or an sodonsion 8urro1, paced opvv the credit uniopn is yA'Ohoul bsnafr to you irxilviduayy but , Primarily for the Profacdon of the cre Wl is g 8• houk ft predit union feel al any a.. Uw11 the security prosenlay has irtunishod in value, or for any raison feel Ih.1 adtllUons sscuanddbl s r WncQ you the aeCi luraiwon ieels la lnooeuiy to p lei )sae days union a0anil?l se p? ry loss. Posel 7. 6190 2/99 Comncwal Pledge or Shsns; You P190199 all your Shares and d"Posits credit union,ue Inc al luding future .ddltlons, as securityfor Ihls loan o e yw Of all s,ums tl the credit union mar ¦PPIY these shares and deposits to the payment of all s the time of tla0uq including costs of COINKflon and reesona I, aikmeye I ush ,at the credit union may Inver, up to 20% of Ihs unpaid Principal and IntvnL No It-- or right to impress a lion on shares and daposita shall ePPiY to any of your shares which may be held In an "Individual Retirement Account" Of "K.ogh Plan." Page 2 of 2 scie rky rcry, Ilia 0`6011 union ?iNs in nacrrsiery upro{Sd theu coiisled-o and the secudry kNerest which this agreement 70ate, If t -h`anon Pun one oorrVq% yyour ob110allons under this aores loin) and uwrai, secrh being aquelry re.ponsiWO to fuIRN tits Isrmsof Ihis agreement, mam are This s helm -and cddfy aeasignipraomanl not only binds you, txd your executors, admnislmors, , . ALL THAT CERTAIN all that certain tract or parcel of land with the buildings and improvements thereon erected, situate in Lower Allen 't'ownship, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: - BEGINNING at a point on the Southerly line of Cumberland Road, which point is 270 feet Eastwardly of the Southeasterly corner of Cumberland and Sussex Road and at the dividing line between hots Nos. 30 and 31 on the hereinafter mentioned Plan of Lots: thence along the Southerly line of Cumberland. Road North 56 degrees 55 minutes 30 seconds Fast, 60 feet to a point at the dividing line between Lots Nos. 31 and 32 on. said Plan; thence along said dividing line in a line at right angles to Cumberland Road aforesaid in a Southerly direction 154.47 feet to a point at the Nonlherly line of property now or late of Allen Park Development Company; thence along same South 69 degi-ecs 22 minutes West, 61.44 feet to a point at dividing line of Lots Nos. 30 and 31 on said plan; thence along said dividing line in a line at right singles to Cumberland Road in a Northerly direction 141.23 feet to a point, the Place of BEGINNING. Being I.ot No. 31, Tract No. 2 on Flan of Lots known as Cumberland Park, which plan is recorded in the Cumberland County Recorder's Office in Plant Book 6, page 3; and being known as No. 243 Cumberland Road. li EING the same premises which Darvin Keith Heltniek and Avis M. Helmick, his wife by deed dated August 21, 1956 and recorded August 23, 1956 in Deed Book "J", Volume 17, page 36 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, granted and conveyed unto Louis F. Sabo and gsthcr. . Sabo, his wife. Esther L. Sabo died on April 21,, 1987, thereby vesting title in Louis E. Sabo, Sr., the surviving tenant by the entirety. Louis l;. Sabo, Sr. died on April 11, 2007 seised of the above premises. Being the same premises which Louis E. Sabo, Jr., Executor of the Estate of Louis E. Sabo, SR., by his deed dated February 28, 2008 and recorded in the Cumberland County Recorder of Deeds Office at Instrument No.: 200806677 granted and conveyed onto Louis E. Sabo, Jr. Exhibit "B" Prepared By: Members I st FCU 5000 Louise Drive Mechanicsburg, PA 17055 Return To: WHEN RECORDED RETURN TO: Equity Loan Services, Inc. 1100 Superior Ave., Ste. 200 Cleveland, OH 44114 National Recording - FACT - r1-aq - &191- o aq MORTGAGE Made 04/22/2008 Between LOUIS E SABO JR (hereinafter called "Mortgagor") And MEMBERS 1ST FEDERAL CREDIT UNION (hereinafter called "Mortgagee") Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter called the "Note") of even date herewith, payable to the order of Mortgagee in the principal sum of $_ 50,000.00 , 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 LOWER ALLEN TOWNSHIP Cumberland County, Pennsylvania SEE EXHIBIT "A" which currently has the address of 243 CUMBERLAND ROAD CAMP HILL [Street] [City] Pennsylvania Acct N ApplD 25739407 17011 [Zip Code] Page 1 of 4 l Exhibit "C" Together with the buildings and improvements erected thereon, the appurtenances thereunto belonging and the reversions, remainders, rents, issues and profits.thereof. To Have and To Hold the same unto Mortgagee, its successors and assigns, forever. Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum, including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder and under the terms of the Note, together with interest thereon, and shall keep and perform each of the other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby granted and conveyed shall become void. This Mortgage is executed and delivered subject to the following covenants, conditions and agreements: (1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall be added to the principal debt. (2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt secured hereby, (b) pay all ground rents reserved from the mortgaged premises and pay and discharge all mechanics' liens which may be filed against said premises and which shall or might have priority in lien or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax, including interest and penalties thereon, if any, now or hereafter becoming payable on the Note evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged premises, with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear, and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge the foregoing charges be paid in installments to Mortgagee. (3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair of the buildings and improvements erected thereon. Acct No AppID 25739407 Page 2 of 4 (4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fails to maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the principal debt secured hereby, and collect the same as a part of said principal debt. (5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this Mortgage. (6) In case default be made for the space of thirty (30) days in the payment of any installment of principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum, additional loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice become immediately due and payable, and foreclosure proceedings may be brought forthwith on this Mortgage and prosecuted to judgment, execution and sale for the collection of the same, together with costs of suit and an attorney's commission for collection of five percent (5%) of the total indebtedness or $200, whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said proceedings, waives stay of execution, the right of inquisition and extension of time of payment, agrees to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions from levy and sale of any property that now is or hereafter may be exempted by law. (7) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage. Mortgagor shall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing this Mortgage, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. The covenants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall inure to, the respective parties hereto and their respective heirs, executors, administrators, successors and assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each shall be joint and several. Acct No ApplD 25739407 Page 3 of 4 Witness the due execution hereof the day and year first above writtenQn. L LOUIS E SABO JR Commonwealth of Pennsylvania County of CUMBERLAND ss: day of APR T 12008 , before me, the undersigned officer, personally appeared 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 offrci 1. My commission expires: CO1vi,?IO;VL?rL? TtT (aF PL(dIVSYLVA.N.TA Notarial Seal Jody L. Travis, Notary Public Upper Alien Twr.?., Cumberlarxt County C'ertifle of Re id n of Mortgagee tiny Commission Erplres Sept. 29, 20011 member P@r2rc?,1 ,. ? err. 1k'of No ,rF.t• Members T T ?'ederaredit Union, Mortgagee within named, hereby certifies that its residence is 5000 Louise Drive, Mechanicsburg, PA 17055. By Acct No APPID 25739407 Page 4 of 4 EXHIBIT A All that certain property situated in the Township of Allen, in the County of Cumberland, Commonwealth of Pennsylvania , and being described as follows: 13-24-0797-027. Being more fully described in a deed dated 02/29/08 and recorded 03/06/08, among the land records of the County and State set forth above, in Instrument 200806677. Permanent Parcel Number: 13-24-0797-027 LOUIS E. SABO, JR., AN ADULT INDIVIDUAL 243 CUMBERLAND ROAD, CAMP HILL PA 17011 Loan Reference Number 257394 First American Order No: 14593308 Identifier: FIRST AMERICAN LENDERS ADVANTAGE 11111111111111 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200814707 Recorded On 5/6/2008 At 10:08:22 AM * Instrument Type - MORTGAGE Invoice Number - 20218 User ID - AF * Mortgagor - SABO, LOUIS E JR * Mortgagee - MEMBERS 1ST FEDERAL CR UN * Customer - FIRST AMERICAN * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $13.50 RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $40.50 * Total Pages - 6 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA ? °f avye? RECORDER O D PEODS t »so * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. MOM III IIIINIIIRNIIIIIIIIII? (Rev. 9/2008) Date: July 16, 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 intends to foreclose Suecific information about the nature of the default is Qrovided in the attached ages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) AGENCY WITHIN 33 DAY OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have anyguestions ou may call the, Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with im aired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION 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 "D" HOMEOWNER'S NAME(S): LOUIS E SABO JR PROPERTY ADDRESS: 243 CUMBERLAND ROAD CAMP HILL, PA 17011 LOAN ACCT. NO.: 26531 - 07 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 MUST OCCUR WITHIN THIRTY-THREE (33) DA OF THE DATE OF 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. CONSUMER EDIT .O INS IIV A NL S -- 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 property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediate of your intentions. APPLICATION FOR MORTGAGE AS ISTANC 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 HEMAP 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 jo date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 243 CUMBERLAND ROAD CAMP_ HILL, PA 17011 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 5/15/2009 in the amount of 578.76, for 6/15/2009 in the amount of 578.76 and for 7/15/2009 in the amount of 578.76 Other charges (explain/itemize): TOTAL AMOUNT PAST DUE: $1,736.28 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,736.28 , 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 V Federal Credit Union, ATTN: Tracey Mackey 5000 Louise Drive Mechanicsbure, 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 D .FAULT--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 ht. 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 ullon your mortgaged rollerU. 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 1? re iod• you will not be required to pay attorney fem. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE. -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by Paying the total amount then past due, plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately Three (3) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender: Members I" Federal Credit Union Address: 5000 Louise Drive Mechani sb urg. PA 17055 Phone Number: 717-506-5438 or (800) ?ft3_ 3 Q E.± cm Fax Number: (717) 795-5207 Contact Person: Tracey Mackey E-Mail Address: mackeXtZmemhersl st.org EFFECT OF SHERIFF'S SALE, -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may 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 YOU MAY ALSO HAVE THE Rl HT- • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT O NSEi IN[: AGENCIES SERVING YOUR COUNTY LFill_ its a list d all Counseling Agencies lasted in AgDendix C FOR THE COUNTY in which the 1p = is located. using addi_ tional-aces ifnecessarv), Certified Mail # 91 7108 2133 3936 2347 5366 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 Captlal 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 717780.3940 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 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 SC_R_A? • 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. :':'hat Legal Protections Are Servicemembers Entitled To Under the SCRA? The SCRA states that a debt incurred by a servicemember, or servicemember and spouse jointly, prior to entering military service shall not bear interest at a rate above 6 percent during the period of military service. The SCRA states that in a legal action to enforce a debt against real estate that is filed during, or within 90 days after the servicemember's military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 90 days after the servicemember's military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate. The SCRA contains many other protections besides those applicable to home loans. How Does A Servicemember or Dependent Request Relief Linder the SCRA? • In order to request relief under the SCRA, a servicemember or spouse, or both, must provide a written request to the lender, together with a copy of servicemember's military orders. The Lender providing this Notice is Members I` Federal Credit Union, ATTN: Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The phone number is toll free (800) 283-2328. How Does a Servicemember or Dependent Obtain Information About the SCRA? The U. S. Department of Defense's information resource is "Military OneSource". Website: http://www.militaryonesource.com The toll free telephone number for Military OneSource are: o From the United States: 1-800-342-9647 o From outside the United States (with applicable access code): 800-3429-6477 o International Collect (through long distance operator): 1-484-530-5908 • Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal assistance office locator for all branches of the Armed Forces is available at http://legalassistance.law.af.m it/content/locator.php form HUD-92070 (2/2007) Form 3877 Pagel Permit Number: MAC Cert. Ver. Num. filer's Name and Address: 9223844001 SendSuite - MAC v6.00.6.01 J tubers 1st Federal Credit Union 00 Louise Dr Sequence Number: CHANICSBURG, PA 170SS 0000277 ID #/ Addressee Name ES Postage ES F Insur ed Due Sende Total Charge ticle # Delivery Address Type ee ___--- i )0000001 9745 Louis Sabo 1710 8 2 13 3 3 9 3 6 2 34 7 5 3 66 243 Cumberland Road Camp Hill, PA 17011 0.610 C 2.800 ERR 1.100 0.00 4.510 S?A? ?rN V 0 *P4ItOF1! ZI?' DE ' 7 0 5 5 4.300 35.100 Y h „ =, 39.400 Page Totals: 9 4.300 35.100 39.400 Cum Totals: 9 Fnrm ?R77 (Facsimile) SendSuite - MAC v6.00.6.01 .J USPS CERTIFICATION ROL Exhibit "E" r?r 1?0`s? Gy \ 02 1M $ IDI.490 0004250959 JUG"E 2009 FROM ZIPCODE 1 7055 ERS 15T FEDERAL IN THE COURT OF COMMON PLEAS T UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINT7~Fl? Vs. : NO.: E. SABO A/K/A E. SAI3O, JR. DEFENDAN'1' : CIVIL ACTION-LAW MORTGAGE FORECLOSURE VERIHICAI',ION I, Dave Thomas, Lead Collector for Members 10 Federal Credit Union, being ied to do so on behalf of Members I" Federal Credit Union, hereby verify that the nts made in the foregoing pleading are true and correct to the best of my axon knowledge and belief. I understand that false statements are made subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to Members 1* Federal Credit Union BQ Dave Thomas, Lead Collector . 6 0 FILE VICE OF 7P- 200 SEP 17 P, 12: t 4;. r $ "18 . so PIS ATT`1 Gtr` 341'1 Rta3o(t3 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor jr ?01 C[T -7ti` 3 t Cl.`i?< ; _ 1~ to ''' "Y OFFS[ F FRIFF f LI'i?'. 1 t Members 1st Federal Credit Union vs. Louis E. Sabo Case Number 2009-6253 SHERIFF'S RETURN OF SERVICE 10/05/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Louis E. Sabo, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Louis E. Sabo. The Camp Hill Postmaster has advised the defendant's mail is delivered to 243 Cumberland Road Camp Hill, PA 17011. After several attempts the Complaint has expired. SHERIFF COST: $60.44 SO ANSWERS, j,. October 05, 2009 THOMAS KLINE, SHERIFF Sheriffs Office of Cumberland CountyF1m O,PT„y F OF TH= F' s? ;.RY Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 ST FEDERAL CREDIT UNION PLAINTIFF Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6253 Civil LOUIS E. SABO alk/a CIVIL ACTION - LAW LOUIS E. SABO, JR. DEFENDANT MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT To the Prothonotary: Please reinstate the complaint filed in the above captioned matter. submitted, Date: October 13, 2009 Karl M. Ledebohm, Esq.- Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff OF THE F", 2099 OC 15 Pt i 2: 3 L +tc.oo Pp ATTY C!Ic'?'' 3?3? Sheriffs Office of Cumberland County R Thomas Kline FILED-O' rV. Sheri aC c?tbrrr t F V r C'I?'riT ..-1, ? ?'?? "4 OTfX Ronny R Anderson 2009 OCT 20 All SO Chief Deputy j Jody S Smith OFFICE JIB ESHERIFF Civil Process Sergeant Edward L Schorpp Solicitor Members 1 st Federal Credit Union Case Number vs. 2009-6253 Louis E. Sabo SHERIFF'S RETURN OF SERVICE 10/16/2009 08:45 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 16, 2009 at 2045 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Louis E. Sabo, by making known unto herself personally, at 619 Cumberland Pointe Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.44 October 19, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff n Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 (717)938-6929 MEMBERS 1„ FEDERAL CREDIT UNION PLAINTIFF LOUIS E. SABO a/k/a LOUIS E. SABO, JR. DEFENDANT TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA NO.: 09-6253 Civil CIVIL ACTION -LAW : MORTGAGE FORECLOSURE PRAECIPE Please enter judgment in the above captioned proceeding in favor of Members I" Federal Credit Union, Plaintiff, and against the Defendant, Louis E. Sabo a/k/a Louis E. Sabo, Jr., in the amount of FIFTY-ONE THOUSAND FOUR HUNDRED SIXTY-SIX AND 19/100 DOLLARS ($51,466.19) 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, Louis E. Sabo a/ka Louis E. Sabo, Jr., to Plaintiff's Complaint within twenty (20) days of service thereof and after a 10-day Notice was sent. Respectfully submitted, Date: November 18, 2009 (717)938-6929 Attorney for Plaintiff I hereby certify that notice of intent to take default judgment was forwarded to Louis E. Sabo a/k/a Louis E. Sabo, Jr. by United States Mail, first class, postage prepaid on November 6, 2009. 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 Forms 3817 are attached hereto and marked Exhibit "A". d? Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 IT FEDERAL CREDIT UNION PLAINTIFF Vs. LOUIS E. SABO a/k/a LOUIS E. SABO, JR. DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-6253 Civil CIVIL ACTION -LAW : MORTGAGE FORECLOSURE IMPORTANT NOTICE TO: Louis E. Sabo a/k/a Louis E. Sabo, Jr. 619 Cumberland Pointe Mechanicsburg, PA 17055 Louis E. Sabo a/k/a Louis E. Sabo, Jr. 243 Cumberland Road Camp Hill, PA 17011 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800)990-9108 Date: November 6, 2009 ,Kdrl M. Ledebohm, tsc : Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff a R IIII w ? . ? M ti A g a N b y ao c V o czo ? ? `? ? m s r ;` = ? m y W S ' v 'd R 3 , c rD W v O C c c C ti 0 u?nr£DSrAr£s POSTAL SER VICE 1000 U.S. POSTAGE PAID NEW CUMBERLAND,PA 17079 NOV 06. 09 AMOUNT 0$115, o V Cfl ?• y '-" 0 3 ^^ b l l • " Ci7 CrJ ? W 0 o ~? ' W y gS ? g a? V ? O p i>' ?b a 3 a rn 3 I t VNITEDSTATES POSTAL SERVICE 1000 0 O = V - W o? p ?m mw n v m O U.S. POSTAGE PAID NEW CUMBERLAND.PA 17079 NOV 06, 09 AMOUNT 0$1.15, 19LED-4:)Fr ICE OF THE PR^T i?CN,'0TAPY 2009 NOV 19 APB 11: 26 CUMb , k . (ZUNTY PEN `NSYLVANIA s J '/. t)G f c,t Id - 3 y 1 y 2,3 3 -7 ?J'?7cc 5 M-a •` ? c? Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 (717)938-6929 MEMBERS I"' FEDERAL CREDIT UNION PLAINTIFF LOUIS E. SABO a/k/a LOUIS E. SABO, JR. DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-6253 Civil pla cm t -n . CIVIL ACTION -LAW : F I F va J, MORTGAGE FORECLOSU y -v n ip , k- 2 [3 6 1?;QL 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: Louis E. Sabo a/k/a Louis E. Sabo, Jr. 619 Cumberland Pointe Mechanicsburg, PA 17055 Louis E. Sabo a/k/a Louis E. Sabo, Jr. 243 Cumberland Road Camp Hill, PA 17011 You are hereby notified that on /VdVc a,4 e,, / , 2009 the following judgment has been entered against you in the above captioned case: Judgment in favor of Members I" Federal Credit Union, Plaintiff, and against the Defendant, Louis E. Sabo a/k/a Louis E. Sabo, Jr., in the amount of FIFTY-ONE THOUSAND FOUR HUNDRED SIXTY-SIX AND 19/100 DOLLARS ($51,466.19) 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, Louis E. Sabo a/ka Louis E. Sabo, Jr., to Plaintiff's Complaint within twenty (20) days of service thereof and after a 10-day Notice was sent. dij Dated: f - 9 -oL Ud P othonotary is: I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236 Louis E. Sabo a/k/a Louis E. Sabo, Jr. 619 Cumberland Pointe Mechanicsburg, PA 17055 Louis E. Sabo aWa Louis E. Sabo, Jr. 243 Cumberland Road Camp Hill, PA 17011 A: Louis E. Sabo a/k/a Louis E. Sabo, Jr. Por este medio se le esta notificando que el de 2009 el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso mencionado en el epigrafe. Fecha: Protonotario Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificado de residencia: Louis E. Sabo a/k/a Louis E. Sabo, Jr. 619 Cumberland Pointe Mechanicsburg, PA 17055 Date: November 18, 2009 Louis E. Sabo a/k/a Louis E. Sabo, Jr. 243 Cumberland Road Camp Hill, PA 17011 K*I M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ~1L~D -~~. . G ~~ T!-Ir ,,, ~ ~ ~",-~~Y Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1sT FEDERAL CREDIT UNION PLAINTIFF Vs. LOUIS E. SABO a/k/a LOUIS E. SABO, JR. DEFENDANT 2010 ~,Y i 8 P°- ~~ 2~ CUhli~ a .,}Ui~T'~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6253 Civil CIVIL ACTION -LAW MORTGAGE FORECLOSURE PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment entered in the above captioned matter satisfied. Date: May 13, 2010 1tar1 Nl. Ledebohm,l~;sq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff $8.00 P p ~~`I (~~~ S(o90 ~ a u~ ~~ Respectfully submitted, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~4~1,,ti;.~ tat ~.Ir7~~(~.~,~.rl x~y ~. r.: , ~~~ _,-: - _ L• t i 2~!i'P7AY 2~ ~~Uft~~ Z~ ._ -~, Members 1st Federal Gredit Union vs. Louis E. Sabo Case Number 2009-6253 SHERIFF'S RETURN OF SERVICE 12/21/2009 08:41 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 21, 2009 at 2041 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Louis E. Sabo, located at, 243 Cumberland Road, Cumberland County, Pennsylvania according to law. 12/21/2009 08:23 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 21, 2009 at 2023 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Louis E. Sabo, by making known unto, Louis E. Sabo, personally, at, 619 Cumberland Pointe, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 02/11/2010 Property sale postponed to 4/7/2010. 04/05/2010 Property sale postponed to 6/2/2010. 05/18/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Ledebohm on 5/13/10 SHERIFF COST: $776.86 SO ANSWERS, ~~~ "'-'-----__r May 21, 2010 RON R ANDERSON, SHERIFF ~2 -CX~ ~~~ . C'c~ F ,.:.:~t t~~~ ~'~ ~ ~G ~o~`, 4 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 (717)938-6929 MEMBERS 1' ` FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF LOUIS E. SABO a/k/a LOUIS E. SABO, JR. DEFENDANT NO.: 09-6253 Civil 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 Lower Allen Township, Cumberland County, Pennsylvania, known and numbered as 243 Cumberland Road, Camp Hill, PA 17011. 1. Name and address of owner(s) or reputed owner(s): Louis E. Sabo a/k/a Louis E. Sabo, Jr. 619 Cumberland Pointe Mechanicsburg, PA 17055 Louis E. Sabo a/k/a Louis E. Sabo, Jr. 243 Cumberland Road Camp Hill, PA 17011 2. Name and address of defendant(s) in the judgment: Louis E. Sabo a/k/a Louis E. Sabo, Jr. 619 Cumberland Pointe Mechanicsburg, PA 17055 Louis E. Sabo a/k/a Louis E. Sabo, Jr. 243 Cumberland Road Camp Hill, PA 17011 C~Op~7 ._ ~_ r { 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 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 Spouse of Louis E. Sabo a/k/a Louis E. Sabo, Jr. 243 Cumberland Road Camp Hill, PA 17011 Spouse of Louis E. Sabo a/k/a Louis E. Sabo, Jr. 619 Cumberland Pointe Mechanicsburg, PA 17055 Occupant/Tenant 243 Cumberland Road Camp Hill, PA 17011 Commonwealth of PA Bureau of Individual Taxes Inheritance Tax Division 6~h Floor Strawberry Square, Dept. 28061 Harrisburg, PA 17128 Department of Public Welfare TPL Casualty Unit -Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: November 18, 2009 y bmitted, /' K~brl M. Ledebohm, Esq. upreme Court ID #: 59012 .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 J' FEDERAL CREDIT UNION PLAINTIFF iN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-6253 Civil LOUIS E. SABO a/k/a LOUIS E. SABO, JR. DEFENDANT CIVIL ACTION -LAW MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Louis E. Sabo a/k/a Louis E. Sabo, Jr. 619 Cumberland Pointe Mechanicsburg, PA 17055 Louis E. Sabo a/k/a Louis E. Sabo, Jr. 243 Cumberland Road Camp Hill, PA 17011 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 243 Cumberland Road, Camp Hill, PA 17011, 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 March 3, 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 $51,466.19 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 Sheriff's Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount necessary to bring current the mortgage obligation evidenced by the judgment plus costs and reasonable attorney's fees. To find out how much you must pay, you may call Karl, M. Ledebohm, Esquire, at (717)938-6929. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 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 April 2, 2010 (within thirty (30) days after the Sheriff Sale). This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed by the Sheriff. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 The Sheriff s phone number is: (717)240-6390. ,~-- Karl 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 tract or parcel of land with the buildings and improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Cumberland Road, which point is 270 feet Eastwardly of the Southeasterly corner of Cumberland and Sussex. Road and at the dividing line between Lots Nos. 30 and 31 on the hereinafter mentioned plan of lots; thence along the Southerly line of Cumberland Road North 56 degrees 55 minutes 30 seconds East, 60 feet to a point at the dividing line between Lots Nos. 31 and 32 on said plan; thence along said dividing line in a line at right angles to Cumberland Road aforesaid in a Southerly direction 154.47 feet to a point at the Northerly line of property now or late of Allen Park Development Company; thence along same South 69 degrees 22 minutes West,. 61.44 feet to a point at dividing line of Lots Nos. 30 and 31 on said plan; thence along said dividing line in a line at right angles to Cumberland Road in a Northerly direction141.23 feet to a point, the place of BEGINNING. BEING Lot No. 31, Tract No. 2 on Plan of Lots known as Cumberland Park, which plan is recorded in the Cumberland County Recorder's Office in Plan Book. 6, page 3; and being known as No. 243 Cumberland Road. BEING the same premises which Louis E. Sabo, Jr., Executor of the Estate of Louis E. Sabo, Sr. by his deed dated February 29, 2008 and recorded on March 6, 2008 in Cumberland County to Instrument No. 200806677 granted and conveyed unto Louis E. Sabo, Jr., adult individual. TAX PARCEL # 13-24-0797-027 EXHIBIT `A' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-6253 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 LOUIS E. SABO A/K/A LOUIS E. SABO, JR. (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 properly 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$51,466.19 Interest FROM 11/19/09 AT THE LEGAL RATE Atty's Comm Atty Paid $226.88 Plaintiff Paid Date: November 19, 2009 L.L.$.50 Due Prothy $2.00 Other Costs C rtis R. Lon , P (Seal) REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: P.O. BOX 173, NEW CUMBERLAND, PA 17070-0173 By: Deputy Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 On November 30 2009 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered, 243 Cumberland Road, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 30, 2009 By: Real Estate Coordinator ~~-~~ ,~ -_~n ___ -~ i~ d~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 22 January 29 and February 5 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Z isa Mari Coyne, Edito SWORN TO AND SUBSCRIBED before me this 5 day of February, 2010 fl: ,+' ry Notary DE8!~ rt'~i A ~:OLLI~iS N:~1a^i P~~`.!i~, ~ ^F~RLISI.E 0~)??t:,, CU;~r.~C:"?LgpJD CC3U~1~7Y Writ No. 2009-6253 Civil Members 1st Federal Credit Union vs. Louis E. Sabo Atty: Karl M. Ledebohm Lower Allen Township, Cumber- land County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Cumberland Road, which point is 270 feet Eastwardly of the Southeasterly corner of Cum- berland and Sussex Road and at the dividing line between Lots Nos. 30 and 31 on the hereinafter mentioned plan of lots; thence along the South- erly line of Cumberland Road North 56 degrees 55 minutes 30 seconds East, 60 feet to a point at the divid- ing line between Lots Nos. 31 and 32 on said plan; thence along said dividing line in a line at right angles to Cumberland Road aforesaid in a Southerly direction 154.47 feet to a point at the Northerly line of property now or late of Allen Park Development Company; thence along same South 69 degrees 22 minutes West, 61.44 feet to a point at dividing line of Lots Nos. 30 and 31 on said plan; thence along said dividing line in a line at right angles to Cumberland Road in a Northerly direction 141.23 feet to a point, the place of BEGINNING. BEING Lot No. 31, Tract No. 2 on Plan of Lots known as Cumberland Park, which plan is recorded in the Cumberland County Recorder's Of- fice in Plan Book 6, page 3; and be- ing known as No. 243 Cumberland Road. BEING the same premises which Louis E. Sabo, Jr., Executor of the Estate of Louis E. Sabo, Sr, by his deed dated February 29, 2008 and recorded on March 6, 2008 in Cum- berland County to Instrument No. 200806677 granted and conveyed unto Louis B. Sabo, Jr., adult in- dividual. TAX PARCEL # 13-24-0797-027. PROPERTY ADDRESS: 243 Cumberland Road, Camp Hill, PA 17011. ,,,The Patriot-News Co. ,812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c~he ~lahiot-News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the taws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01 /22/10 01 /29/10 C ~ `' 02/05/10 ~.C~ : ~....:-.... ... ......... ---~ . ,, orn to ~id'subscribed before ~ e t~s 2 d of February, 2010 A.D. /J / / ~ ~ , ~~ ~ 1 ~ , _..,, _.. Notary Public COMMON-~/EALTI'i OF P Not~!rtal Saal C Sherrie L. fCisnar, Notary Public hY Of Herr~b~n3.O~trphln Cou ~' ~xnlseit'n E~~~ Nov. 26, 20 1 Member, Pennsylvania A aaociaticn nr n~~.;,,a, DocketNumbsr:2009-6253 Civil Term Members 1st Federal Credit Union vs. j Louis E, Sabo Atty; FCarl M. tedebohm Lower Allen Township, Cumberland County, Pennsylvania, more particu[arlr bounded and described as follows, to wit: BEGINNING at a point on the Southerly line of Cumberland Road, which point is 270 feet Eastwardly of the Southeasterly corner of Cumberland and Sussex Road and at the dividing line between Lots Nos. 30 and 3I on the. hereinafter mentioned plan of lots; thence along the Southerly line of Cumberland Road North 56 degrees 55 minutes 30 .seconds East, 60 feet to a point at the dividing line between Lots Nos. 31 and 32 on said plan; thence along said dividing line in a line at "right angles to Cumberland Read aforesaid in a Southerly direction 154.47 feet to a point at the Northerly line of property now or late of Allen. Park Development Company; thence along same South 69 degrees 22 minutes West, 61:44 feet to a point az dividing tine of Lots Nos. 30 and, 31 on said plan; thence along said dividing line in a line at right angles to Cumberland Road in a Northerly direcfion ]41:23 feet to a point, the place of BEGIlVNING. BEING Lot No. 31, Tract No. 2 on Plan of Lots known as Cumberland Nark, which plan is recorded m the Cumberland County Kecorder's Office in Plan Book 6, page 3; and being known as No. 243 Cumberland Road. BEING the same premises which Louis E. Sabo, Jt, Executor of the Estate of Louis E: Sabo, 5r: by his deed dated Februa~ 29, 2008 and recorded on March 6, 2008 in Cumberland County to Instrument No. 200606677 granted and conveyed unto Louis B: Sabo, Jr, adult individual. TAX PARCEL: # 13-240797.027 PROP}?RTY ADDICESS: 243 Cumberland Road, Camp Hill, PA 17011