HomeMy WebLinkAbout09-8528McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
RGARET GAIItO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
HSBC Bank USA
5701 East Hillsborough Avenue
Tampa, Florida 33610
V.
Tracey L Ashley
316 Eutaw Ave
New Cumberland, Pennsylvania 17070
and
Chad E Ashley
316 Eutaw Ave
New Cumberland, Pennsylvania 17070
Attorneys for Plaintiff
Cumberland County
Court of Common Pleas
Number Qa - 8.w CCIVIL ACTION/MORTGAGE FORECLOSURE
NOTICE
You have been sued in court. If you wish to defend
against the claims set forth in the following pages, you
must take action within twenty (20) days after this
complaint and notice are served, by entering a written
appearance personally or by attorney and filing in
writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a
judgment may be entered against you by the court
without further notice for any money claimed in the
complaint or for any other claim or relief requested by
the plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO
YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A
LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT
AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
AVISO
Le han demandado a usted en la corte. Si usted quiere
defenderse de estas demandas ex-puestas en ]as paginas
siguientes, usted tiene veinte (20) dias de plazo al partir
de la fecha de la demanda y la notificacion. Hace falta
asentar una comparencia escrita o en persona o con un
abogado y entregar a ]a corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de
su persona. Sea avisado que si usted no se defiende, la
corte tomara medidas y puede continuar la demanda en
contra suya sin previo aviso o notificacion. Ademas, la
corte puede decidir a favor del demandante y requiere
que usted cumpla con todas las provisioner de esta
demanda. Usted puede perder dinero o sus propiedades
u otros derechos importantes para usted.
USTED LE DEBE TOMAR ESTE PAPEL A
SU ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE A UN ABOGADO, VA A O TELEFONEA LA
OFICINA EXPUSO ABAJO. ESTA OFICINA LO
PUEDE PROPORCIONAR CON INFORMATION
ACERCA DE EMPLEAR A UN ABOGADO.
SI USTED NO PUEDE PROPORCIONAR
PARA EMPLEAR UN ABOGADO, ESTA OFICINA
PUEDE SER CAPAZ DE PROPORCIONARLO CON
INFORMACION ACERCA DE LAS AGENCIAS
QUE PUEDEN OFRECER LOS SERVICIOS
LEGALES A PERSONAS ELEGIBLES EN UN
HONORARIO REDUCIDO NI NINGUN
HONORARIO.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
t
CIVIL ACTION/MORTGAGE FORECLOSURE
1. Plaintiff is HSBC Bank USA, a corporation duly organized and doing business at the above
captioned address.
2. The Defendant is Tracey L Ashley, who is the mortgagor and real owner of the mortgaged
property hereinafter described, and his/her last-known address is 316 Eutaw Ave, New Cumberland,
Pennsylvania 17070.
3. The Defendant is Chad E Ashley, who is the mortgagor and real owner of the mortgaged
property hereinafter described, and his/her last-known address is 316 Eutaw Ave, New Cumberland,
Pennsylvania 17070.
4. On June 8, 2005, mortgagors made, executed and delivered a mortgage upon the premises
hereinafter described to Mortgage Electronic Registration Systems, Inc. as nominee for Wilimington Finance,
a division of AIG Federal Savings Bank which mortgage is recorded in the Office of the Recorder of
Cumberland County in Mortgage Book 1910, Page 4872.
5. The aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration
Systems, Inc. as nominee for Wilimington Finance, a division of AIG Federal Savings Bank to HSBC Bank
USA, by Assignment of Mortgage, which will be duly recorded in the Office of the Recorder of Cumberland.
6. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A"
and is known as 316 Eutaw Avenue, New Cumberland, Pennsylvania 17070.
7. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due March 1, 2009 and each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month, the entire principal balance and all
interest due thereon are collectible forthwith.
8. The following amounts are due on the mortgage:
Principal Balance $
Interest through September 3, 2009
$ 164,864.85
(Plus $31.57 per diem thereafter) 8,712.95
Attorney's Fee $
Late Charges 1,250.00
Corporate Advance $ 571.50
Escrow Advance $
$ 32.50
GRAND TOTAL 1,361.80
$ 176,793.60
9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice
required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et
seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail
with a certificate of mailing and by certified mail, return receipt requested.
WHEREFORE, Plaintiff'demands in rem Judgment against the Defendant in the sum of $176,793.60,
together with interest at the rate of $31.57 per diem and other costs and charges collectible under the
mortgage and for the foreclosure and sale of the mortgaged property.
McCABE, WEISBERG AND CONWAY,P.C.
BY: A-e-"ei
Attorneys for PI ntiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
VERIFICATION
The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the
within action, and that he/she is authorized to make this verification and that the foregoing facts based on
the information from the Plaintiff, who is not available to sign this, are true and correct to the best of
his/her knowledge, information and belief and further states that false statements herein are made subject
to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities.
McCABE, WEISBERG AND CONWAY,P.C.
BY:
Attorneys for P mtiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
09-10-'09 17:34 FRM- T-755 P0006/0060 F-657
1'? 1 ?'CNr 'F P. VE1;LER
?': ^ r
,_GF DEE11S
1005 JUN 16 A? 10 16
Preparw By: Retara To:
we?+lelw r+".K. , irhkn d Aa1 ra.,r s..:r. a..t
r?n'rIm .wrr... owW."1 Ato s.ar
40t PMeo now#, sm1w 400 401 RMOV RIK edl. 490
P""06 ?q.M1w M 11162 phMVA MI 6r IA 12462
Parcel Number:
25.25.0008.124
[SPVe Above U* Ibe Yet Rearafs0 VaW
MORTGAGE
Lou Number; A05053133 MIN 100372408058352862
DEFINITIONS
Words used in multiple amions of Wa documW are *4=d below and other words are defined is
Sections 3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words usod in this dommem are
also provided in Section 16.
(A) "Stxalrity Lstenutatt" tO= this document. which is dated June 08. 2005 ,
together with all Riders to this doaunant.
(B) "Borrower" Is
CHAD E. ASHLEY AND TMCEY L. ASHLEY, HUSBAND AND WIFE
i•P
Borrower is the mongagm under this Security hlatrumam.
(C) "Mm" Is Mortsage ls'teetronie Registration Systems. Inc- MM is a separate corporation that is
acWW Aolely as a nominee for [.render and I.eader'a sttoeessors am assigns. mug is the mwgagee
Bader NO Serenity bA MU=t. MM is orgadzod and existing artier the laws of Delaware, and has an
addrms And talephorte number of P.O. Box 20x6, Riot MI 405012026, ml. (888) 67%MM.
PO MaiYLVAM - Sin& Family - Farms Alaa/Flddte on koroMS IMSTINfWW VM H Mg" FaM 3039 1101
•.a.1 016 Initl.lst r 4 R . A.
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DO&-VA
BK 19 1 OPG4872
09-10-'09 17:34 FROM- T-755 P0007/0060 F-657
(D) "Lender" is
Wilmington Finance, a division of AI6 Federal Savings Bank
Loader is s Federal savings sent
organized said existing under the laws of United States of America
Lender's addrtts is 401 Plymouth Road, Suite 4oo
Plymouth heating, PA 19462
M "NOW mtm the promissory note sipW by Borrowear and dated June 08. 2005
11e Note states that BMW owes LtmderON Hundred Seventy-Two Thousand 8 00/100
Dollars
N.S. $172,000,00 ) plus inuxest. Borrower has Promised to pay this debt is regular periodic.
Payments and to pay the debt in M wt later am July 01. 2035
(1) "Property" means the property that is date %W below tinder the headittj "Ttts* of Rights in the
PrOpMy.V
(G) 'UM" mum the debt evidenced by &a Now, plus interest, my prepayment charges sod late charges
due under the Note. aid all aunt due under tbis Socrnity Instrument, plus irnarest.
(H) "Riders" means all hiders to this Security instrument that are executed by Borrower. Tito following
Riders are to be executed by Borrower (check box as applicable];
Adjusnbhs Rata Rider C] Condominium Rider Second How Rider
Balloon Rider Planned Unit Development Rider 14 Fully Rider
VA Rider Biweekly Psymom Rider 4 ogter(s) [specify]
(1) "Applicable Law" means all controlling applicable federal. scam and local statutes, regulations,
ordh across and adminlstrative rules and orders (that bave the effect of law) ar well as all applicable find,
non-appeaLble judicial opinions.
(J) Commmsity Asoodation Does, Fees, and Assaamsemts" means all duos, fees, asswsunq and outer
charges that at imposed on Borrower or the Property by a condominium sgwiatiom, homeowum
association or si» eilar Organization.
(R? "Etadroale gluads Tnti fee nVanS any transfer of funds, other than a traosoction orightwrd by
check, draft, or similar paper instrument, whit Is hddated through an electronic net w". telephonic
instrument, computer, Ot magnetic ape so as to order, instract, or attthorias a financial im6ttnion to debit
or credit an seeottat. Such term Includes, but Is not limited to, pout- sate traasfbra, automated teller
machine transactions, trmsfars initiated by telephone, wire uzz& n, and sumo tated clearlogbouse
transfers.
M ' Rurow Itnrs" means tbose items that are described in Section 3.
(M1 "Miseeaaaoous Proceeds" means any compensation, settlement. award of datnages, or promo paid
by any third pay (Ocher than iaaun=e proceeds paid under the eoverttgas described in Section S) for. (1)
daatage to, or (1eauuction of, the property; (1i) condemnation or other taking of all or any part of the
Property: {iii) conveyance in flan of condemnation; or (iv) misrapresentatione of, or OwAssions as to, the
value and/or condition of the Property.
(M) Mortgage bworuce" meant Itautance protecting Lender against the nonpayment of, or default on,
the Loan.
(O) "Periodic 14ayment" means ft regularly scheduled ataount due for () Principal and interest uu&r the
Notc, plus (ii) any amounts under Section 3 of this Security Instrument.
gk4A(PA) snDU ?.o. t or Is
DDS-VA
FDMr 3039 1101
SK191OPG4873
09-10-'09 17:34 FROM-
T-755 P0008/0060 F-657
(P) "AMA" MCA" the Real BUM $onlemeat Prawdt m Act (12 U.S.C. Section 2601 at seg.) and its
implomatdng relpuhuloa, Repulmdoa X C.F.R Part 310011 as dMy might by aa?atded dons bate to
time or any rtddideew. or 6110mor or halation that governs the pare Att(ect matter. As used
In this small Imstrtttnent, •RESPA' soft to A[ roquirwoeats sad vastricdoaa dWA a v in regard
to a •blerew related mortgago Ions" overt it the Loan does not qualify m a 'hda mill Wand stiortgage
loan'under 00A.
(0 'Successor in l(nterrtst of Borrower" mom my party this has taken title to rho Property. whether or
sot that party baa assumed Borrower's obligations wider due Note M&or this security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: (0 the repaymera of tha Loan, and '16 teoewais, e:ttendons and
modifications of the Note: and (9) die pc*n move of Borrower's covenants mad apoeem um under this'.
Security Inttrunm and the Note. For this purpose, Borrower does hereby mmtpape, grant ad oonvey to
MW (solely as nondim for Leader and Lender's sucoessors and =kW) sod to rho successors and
assigns of MFRS, rho following described property located in the County lrype of 1WW t a jaft dmj
of CUMBERLAND IN%= otleeaMiq lnrkdktim):
SEE GEED
which curreotly has the address of
316 EUTAW AVE (8"-11
NEW CUMBERLAND (Ckyl, Pendsylvam • 17070 (Zip Cod")
(Property Address"):
TOGETHER WrM all the improvements now or hereafter erected on the property. and all
eaaerneaU, and tixams now or hereaft a part of the AB tp?la and
additions slnl Btcovered by this Security )mattnmaot. All of the rag it ratorsed to In this
Sir Instrument as the 'Property.' Borrower uudetstands mod ag+eas that 6[ER5 holds only lq d tide
to the fnterms & ed by Borrower in this Security lnsbutoettt, bk if nam- nary to cmggy with law or
custom. MFRS (m nominee for Lender so Le s successors and no ) bas the ft to exorcise any
or dl of these hatordsts, inclu_diltg, but mot IidgW 10, the right to foreclose and NOT Property. and to
take any action required of Lawler including, but not liadred to, rdeodag and canceling this ?ecurity
Inst rumest.
W o-).
41 ft"(PA) pro6 rap 7 rr a Form 3039 1101
90"PA
OK 19 1 OPG4874
09-10-'09 17:34 FROM-
T-755 P000910060 F-657
BORROWER COVENANTS that Borrower Is lawfully seised of the estate hereby con"yed and bas
the right to mortgage, Pat wad Convey the Property ad that the Proptlrty is paesicwmbered, tgeotpt for
euntmbattoot of record. Borrower wwttants NW wig defend SomMly nice tote to the Property against all
01001118 and dwronda, soVect to arty a0adwraces of record.
THIS SECURITY INSTRUMENT combims uniform covenants for watiomd rue and non-umitonn
covenants with limited variations by jurisdiction to 0orudtute a uniform soon* histturueat covering reel
pro".
UNIFORM COVENANTS. Bmwwar and Louder covemnt and agree as follows:
I. Frt""I t of Bfinelpal, latervot, Barrow lima, Pmpgmant (merges, and Lacs Chargers,
Borrower :ball pay when due the prin0lpd of, and hoarser on, the debt rviderrA by the Now and any..
prepayment oiraW and late dwps due under the Note. Borrower ahatl do pay Bmds for H row Items
purwau to Section 3. Pqmlents dwe under the Note and this Security hmnrotmt "D be trade in U.S.
currency. Ifowsver, if any check or other Instrument received by LApdar as pw r,-w tinder the Note or this
Security Instrument ts rehnn d to Lenda unpaid. Lender may require that any x aB Nbopient payments
due under the Note and this Security Instrument be made in our or caeca of the following forms, as
selected by Larder: (a) push; (b) moray order, (c) carcifiM ckwk, WAk check, treasurer's obeek or
cashier's check, provided any such check is drawn upon an institution Whose deposits sre insured by a
federal agency, Instrumentality, or entity; or (d) Electronic Funds Transfer.
Payments are deemed ntxivcd by Leader when received at the location designated in the Note or at
such other location ea may be desigmted by Leader 011 accordance with the notice provisions in Section Is.
Lender may rem= any payment or partial payment if the payment or patriot payments are htsuffleient to
bring the Loan current. Lewder may accept any payment or partial payment innfficieot to bring me Loan
current, without waiver of any rights heramder or prejudice to its rights to refuse such pomwat or partial
payments in the future, but Lender Is not obligated to apply such payments at due Om such payments are
atwepted. If tack Periodic Payment is applied as of its scheduled dua date, then Lender need not pay
interest on unapplied funds. Leader may hold such unapplied dads until Borrower mekas payment to bring
the Loan current. If Bormwar does not do so within a reasonable period of time, Lender shall either apply
such finds or return them to Borrower. If not applied earlier, such funds win be applied to the outstanding
principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower
migbt have now or in the futon against Loader shell relieve Borrower from malting payments due under
the Note and this Security Inammont or performing the covenants and agreements secured by this Security
Instrument.
2. Appil"tion of Pmymo* or ProcoAL Except as otherwise described in this Section 2, all
payments accepted and applied by Ia udBr shag be applied in the folidwing order of priority: (a) interest
due under the Norte; (b) pdnipal due under the Note; (c) amounts due under Section S. Such payments
shill be applied to each periodic Payment in the order in which it became due. Any remaining amounts
shell be applied first to late charges, sawed to any other amounts due under t w Scarcity justrunmene, and
then to reduce the principal balm= of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a
SufRcieot amount to pay any late charge due, the payment my be applied to the ddhq mt payment and
the late change. If more than cue Periodic payment is outstanding, Larder may apply any payment received
from Borrower to the repayment of the Periodic Payments if, and to the oaten that.. each payment
'f )
w"(PA) t9M] Par e1 to l '.G- Form 3030 trot
004.OPA
.8(19 1 OPG4875
09 -110-' 09 17 ; 34 FROM-
T-755 P0010/0060 F-657
can be paid in fall. To the extent that any excess exists d w the pttyauatt is applied to the fail payment of
one of mere Periodic Payments, orb estcaa trey be VOW to zW hoe Ono duo. Voluntuy
wbtnmnaats "I be applied tine to By prepayment dWW and tbm as dearibod In the Now.
Any application of payments. tnsurattce proceeds, or Mitedlancous Ptooeeds to prinelpef dun under
the Note shall not extend or postpone the duo date, or change do amtwet, of the Periodic Payasears.
3. llrmda for Part+ow ktelgtt. 19MV*W :hell pay 10 [.ender on the day Ptaiodk Paymaitts are due
under the Note, undh the Note is paid In full. a stun (the Toads") to provide for psymeent of amounts dua
for: (a) taxes and a to end other items wtdch on attain priority over this Security Instrument U a
Hen or ernttrnbnsnee on fhb Property; (b) I udold payments or ground temp on the Property, if W. (c)
pnniums for any and aH mautsace required by Lender under action 5; and (d) Morw o Insurance
premiums. If say, or any sumo PaYbb by Borrower to Leader In lieu of the payment of Mortgage'
Insurance premiums in accordance with the provisions of Section 10. These item are tailed "Facrow
Items.' At origination or at any time during the tertu of the Low, Lander may require that Community
Association Dues, Fits. and Asmamente, if say, be escrowed by Bomaawer. sad w& dues, fees ad
asses smeno shall be an Escrow Item. Borrower shall promptly danidt to Lwex- all notices of amounts w
be paid under this Section. Borrower shall pay Leader the Funds for Escrow 'ease unless Leader waives
Borrower's obligation, to ray the Funds Aar any or all Fi mw Items. Lerida may waive Borrower's
obligation to pay to Lender Funds for say or all Escrow Items at any tint. Any such waiver any only be
in writing. In the event of such waiver, borrower shall pay directly, when. trod inhere payable, the amounts
due for say Escrow Items ft ftM paymwt of Funds has bean waived by Lander and, if Lender requim
shall fhrnish to Lender receipts evidencing such payment widdu arch time period as Lender racy require.
Borrower's obligation to mare suds piymanta and to provide mxlptr shat! For all purposes be deemed to
be a covenant and agreement contained in d& Security Instrument, as the pltmsa "covenant and agreement"
Is used In Section 9. K Borrower is oblipted to pay Escrow Items directly, pursum a to a waiver, and
Borrower fails to pay the amom due for an Escrow Item. Lou* may ccor tee its rights under Section 9
and pay such amount and Borrower shall then be ohNigated under Section 9 to repay to Lender any such
amount. Lender may revoke the waiver as to any or all Escrow Imm at any rheas by a notice given in
accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all Funds, and in
such amotms, that are then required under this Section 3.
Leader may, at any time, collect and hold Funds In as amount (a) sufiicieat to permit Lender to apply
the Funds at the time specified under RESPA. and (b) not to ennead the mminwm amount a leader can
require under RESPA. Lender stall estimate the amount of Funds due on do basis of current data and
reasonable estimates of expeaditum of fature Escrow Items or rotlt min in accordance with Applicable
Law.
TIc Funds shall be held in an institution whose deposits ire insured by a federal agency,
lustrumetuatity, or entity (including Lender. if Leader is an institution whoa: deposits are so insured) or in
any Fedcral Flome Loan Bent. Lender shalt apply the Fonds to pay the Escrow Items no later ,Lan the time
specified under RMPA. Lender shall not charge Borrower for bolding and applying the Funds, arutualty
analyzing the escrow account, or verifying the Escrow Item, unless Lender p,? a Borrower interest on the
Funds and Applicable Law permits Lender to make such a charts. Unless an ar,roemm it wade in writing
or Applicable Law requires Interest to be paid on the Funds. Lender shall not be required to pay Borrower
any interest or earnings on duce Puncds. Borrower sad Leader can agree in writing, however. that interest
t1-iA(PAI aim
006-VA
4A
?? ?t c Fwm 3039 1101
89191OPG4876
by-10-'09 17:35 FROM-
T-755 P0011/0060 F-657
Shull be paid on the Funds, Lander shall give to Borrower, without charge, an wi nual accounting of the
Funds a mgWmd by RBSPA.
If there is a wWus of Funds held in escrow. as donated under RBSPA, Lender stall secount to
Borrower for the exem hinds in aoc, am with RESPA. if thane is a shortage of Funds held in escrow,
a defined under REVA, Leader shall notify Mower as mpdmd by RLWA, pad Borrower shop Pay to
Lender the amount necessary io make up the shortage in woordsom with RWA, but in so more that 12
monthly payments. If there is a deficiency of Farads bold in escrow, a defined under RBSPA, Lax* *41
notify Borrower a required by RPSPA. sad Borrower shall pay to Lauder the amount w*cssary to make
up the deficiency In aocotdtmoe with RE.SPA, but in no amore duet 12 moadtly pbrmm,
Upon pamew in 6A of all cams seared by this Security fn u mnL Lender shall promptly refUnd
to Borrower any Funds held by Lender.
4. tbtaM Uaus. Borrower shall pay all taxes, assassmeat, charges, fines, and irapooldoes
attn'buuble to the Pmpsrty which can attain priority over this Seewhy Inswim at, IMdWW Payments or
greund mats on the Property, if any. and Cmmuahy Association Dos, Fees, and Msessro rats, if nay. To
the extent that these mama are Escrow Gretna. Borrower WWI pay them in the manner provided in Section 3.
Borrower shall promptly discharge any lion which has priority over this Soartity lustrtuaeat valet
Borrower., (a) agrees in writing to the payntetu of the obligation secured by rho lien in a manna satltptable
to Lander, but only so long a Borrower Is parforming such a Steemeat; (b) contests the lien in good faith
by, or defends against onforcemaat of the lien in, legal proceedinga which in lender's opinion operate to
prevent the ea llorcemeat of the lien while those proceedings are pending, but why until such promedings
are conciuded; or (c) secures from flu holder of the lien an agreemat rafisfsct,,sy to Lender subordinating
she lien to this Security Instrumew, if Leader detandm that nay part of the Property is subject to a lien
which can stain priority over this Security Instrument. Lender may give Borm weer a notice identifying the
lien. Within 10 days of the data on which due notice is given, Borrower shall satisfy the lien or take one or
more of the actions set font above in this Section 4,
Lender uxy enquire Borrower to pay a attetomo charge for a teal estate tax verification and/or
reverting service used by Leader in colhnection with this Loan.
S. Property Wuranee. Borrower shall keep the improvements now existing or hereafter erected on
the Property Insured against loss by fire, hazards included within the faun 'extended coverage." and soy
other hazard; including, but not limited to, earthquakes and floods, tot which Londer requirm insurance.
This insurance shell be maintained in the amounts (including deductibie lavd:) and Ibr the perloda that
Lender requires. What Leader requires purmwit to the preceding sameness can change during the term of
the Loan. The k wraaee carrier providing the insurance shall be chosen by Borrower subject to Loader's
rigiu to disapphwe Borrower's Choice, which right shall not be exercised unrewombly. Lender may
require Borrower to pay, In connection with this Loan, either. (a) a one•titao charge for flood zone
detertninslon, eenificadon and traddag ser4m; or (b) a one-time charge for flood zone detecminstion
and cartiScstion services std subsequent charges west time remappings or similar changes occur which
reasonably might effect such determination or e;etdficatioa. Borrower shall also be responsible for the
payment of any fetes imposed by the federal Emergeacy Meoalisenew Agency in connoetioa with the
review of any flood zone determination resulting from an objecdon by Borrower.
Ift"(PA) e2ao "909 0.r 10 Foam 3039 tfol
Dos VA
Pl(1910 F6 4 8 7
09-10-'09 17;35 FROM-
T-755 P0012/0060 F-657
If Borrower fails to autintain any of do coverogea dsaedW above, Latter may obtain issa ance
covarsge, at Lender's option and Borrower's evemo. Leader is under no obligation to pwdtans any
1?nrticWsr typo or amount of eovarage. 't'herefore, such eovmw dmil cm Lender. but aright or might
not protect Borrower, Borrowae's sanity in the Property, or du Comm of the Property, sgsitst shy risk,
hazard or liability ad might provide grater or lesser coverage than was pro*wJy in dkct. Bottowa
acknowledges that ibe cost of the Insurance coverage sic obtained ad* dpdfleatlly exceed the cost of
inwrw= that Borrower could bare obtained. Any amounts disbuseed by Lender trader this Swim f shalt
become additional debt of 8orrowe r secured by this seemly bstramm. These sasm nu shall bear interest
at the Note rate *m rho date of disbrusmnent and sMi be payable, with such interest, upon notice trout
Lender to Borrower rcgoestng payment.
All insurance policies rcgtrirvd by Larder and renorrals of such policies shall be subject w Lender's'
right to disapprove such policies. shill indttde a standard wAMa a clause, and shall name I.adar a
mortgagee and/or as aG additional Ion p"". bander shall here the right to hold the po kiss and tooowal
caniflcatss. If Leedes eegoires, Borrower shall promptly give to Gilder all rooaipts of paid premiuaas and
renewel notices. If Borrower obtains any form of Wituttutce coverage, trot Aawise required by Lender,
for damage to, of desnttadon of, the Property, tatcb policy alien iGetode a standard mortgage Cleves end
shalt tutus I?der a mottgove and/or a an additional low payee.
In the event of bas. Borrower shall give prompt notice to the in atrance tinier and Lender. I andcr
may make proof of loss if not made promptly by Borrower. Unless I ander sod Borrower odserwiso ?
in writing, any insurance proonds, whether or not the undcrlyIng inarsmoe w:,s required by Lender. shall
be applied to restoration or rop& of doe Property, if the nwomion or repair is eeonoudcally feasible and
Undoes security Is not lessened. During suet repair red testoration period. Lender slid! have the right m
hold such insurance proceeds until Leader has bad an opportunity to inspect such Property to enmre the
work has boon completed to Lender's satiaifrction, provided that suck btspeodon awl be undertaken
promptly. Lender may disburse prooWs for the repairs and nator tioa In a single payment or in a seder
of progress payments as the work is corpleted. Unlew an agreement is ands In writing or Applicable Law
requires interest to be paid on such itstasnce proceeds, I.endk dull not be required to pay Borrower any
interest or earnings on such proceeds. Fees for public x4 taters, or other third police, retained by
Borrower shall not be paid out of the la trsmce proceeds and shall be the sole obligation of Borrower, If
the restoration or repair is Got eooaotNaally feasible or Lender's seemly vmuW be lessened. the iasursoce
proceeds shall be applied to the sums secured by this Securi4Y houtieseot. whether or not than due, with
the excess, if any, paid to Borrower. Snit insutance proceeds shall be applied in the order provided for in
Section 2.
If Borrower abandons the Property. Lender may fide, negotiate lad settle any ,fellable insurance
claim and [dated matters. If Borrower does not respond within 30 days to a notice front Lander that the
insurance carrier has offered to settle a claim dun Lender may nagodue ad settle the claim. The 30-day
period will begin when the notice is given. In either event, or If Leader acquires the Property under
Section 22 or otherwise, Borrower haroby a sW* to La*r (a) Borrower's rights to arty iaswaace
proceeds in an amount not to ennead the amounts unpaid under the Note or this Security Instrument, and
(b) any other of Borrower's rights (other then the right to any refund of wtearaed promihums etd
Borrower) under all insurance policies covering the property. insofar as such rights are applicable to the
dxyvWW of the Property. Lender may use the ihts rum proceeds tither to repair or rests, the Properly or
to psy Amounts unpaid under the Nola or this Security iasnument, whether or not then due.
Q ft-eacvAt cam 9"070110 """"!
form 303s trot
CN)S.GPA
O K I 91 OPG4878
UV-U-' Uy 1Y; ;i5 FR M-
T-755 P0013/0060 F-657
6. J'. Borrower shall occupy, atabiish, and use the Property U Borrower': prisdpal
rulda= within 60 days aster tits Woution of Us Saatrity frsstrumeat and tdralt wrtrlnua to occupy sib
'uropatY u Borrower's PiUcPhi raaldeMI bf at bast one year attar the date of occapsue7 otheawiae agrees In writing, which oosw M go trot be , sales Leader
cutamstanoas exist which are nsaeasonbly withhold, or unigs extenuating
beYoud Borrower's contrrol,
7. tv"OrvaHoo, Maintwaaes and Ptobeetisai of the Property; b"Pecdaus. Borrower awl not
destroy. damage or impair the property, allow the property to deteriorate or com uh wash: on the
PmPar/• Whether or not Borrower is tosidigt in die Property. Borrower shall maintain rho property in
00er to prevent the ftVwW &OM doledortting or decreasing in value due to In ooadidoa. Unless it is
determined purauaut to Seodon S that repair or sv toratiat is got oconomMly Possible, Bamwer shall.
Promptly "P* sine Property if damaged to avoid ttuther deterioration or datuage. If inetratee oe
" be motion proceeds are paid in On with dstuaga to. at die W ft of. the hop", Borrower
resp=IW for rapaldag or restoft rho property only if render has nsisssed proceeds far retch
purposes. L"dr any disburae Proceeds for the repairs and lesson" M a shoe peyment or in a series of
Progress Payments a the wort is conrpleced. If the insurance or condega atioa proceeds are not sutllotem
to repair or more she Property, Borrower is not relieved of Borrower's obligation for the camplotion of
such reps or ronoraton.
Lender or its agent may Maim reasonable entries npoa and inapections of doe property. If it has
reasonable cause, Lender nosy impact the h mdor of the improvements on the Property. Lender shall give
Borrower notice at the time of or prior to such an !major lnspeotion apedfying such ms sow" Cause.
S. Borrower's Lam Appbeadoa. Borrower shall be In ddkdt if. duff sib Loan application
Pay, Borrower or any persons or entities acting at the direction of Bo- wer or with Borrower's
knowledge or consent gave materially false, misleading, or ioeccurate ltt=U 'on or statements to Lender
(or fa1W to provide Lender with material information) in connection with the Loan. Material
representations iucludc, but are not limited to. reptoaentatioos concartning Bonoww's occupancy of the
property a Borrower's principal residence.
9. Protection of LNnder's Interea in the Property said Rights Uodar this Security howeased. If
(a) Borrower falls to perform the eoveasm and "=We Contained in aids Security fit, (b) are
is a legot proceeding that nttgltt significantly erica Loader's intatest in the property and/or rights under
this Security Insi mnew (such as a proceeding In bsulu vpteY, probate. JO condemnation or %*it=. for
wforcement of a lien which may attain priority over this Somrity Imtrmaopt of per oak= laws or
regulations), or (c) Borrower has abandoned the Property, thus I.ondet cranny do and pay for whatever is
reasonable or appropriate to prow Lender's Interest in the Property and don under this Security
Irustrnment, Including protecting and/or assessing the value of the Property. and securing and/or repairing
the Property. Loader" actions On include, but are not limited to: (a) paying any stusta socurod by a Urn
which has priority over this Security Instrument. (b) appearing in court: and (e) paying rwsonshie
attorneys' fees to protect Its interest in the Property and/or rights under this Security Isstnunettr, including
its secured position in a bankruptcy Proceeding. Securing the Property includes. but is sot lidded to,
entering the Property to make repairs, change lochs, replace or board up doow ud windows, drain water
from pipes, edhninate building or other code violations or daggerous conditions, and have utilities turned
on or off. Although Lender may take action under this Section 9. Lander does trot have to do a and Is not
under any duty or obligation a do so. It is agreed that Lander Incurs no liability br not taking any or all
actions authorised under this Section 9_
tw.r? /' 2 A
ft"(PAr ahem ?.a 0.r ?e Fwm 3039 1101
OMOPA
BK 191 OPG4879
0y-10-'09 17;35 FROM-
T-755 P0014/0060 F-657
der of
Any asnounts dWxnnd by Lender under this Section 9 sholl awed by dds Y Instrument- These a11040 a ahtll bM IM become at O AM M deb 1f OW Borrown
disbursement and shdl be payable. with such Interest, upon notice bom Lender OD Borrower requagit g
payment.
If this Security lnetrument is on a leasehold, Borrower tthtdi comply with all the pmvialons of fhrl
lease. If Borrower at phu hr tide to the property. the leasehold and the fa title shat! not map unless
Lender agrees to the n in writing.
10. Mertppe >lpgrattoa. If Lmd9r required Mortgage Ilnsnrauoe sac a condition o[ aukiq` the Lose.
Borrower shall pay the pinudgma requited to a hdsin the b4wq ge beggenee in etlbt:t. If, for any reason,
40 WGV*W liaturavca coverage required by I.sndnr taut to be available been the morwp barterer that
WWWd the provided such insua,nca and Borrower, wea umpired to rake separately designated payer
he prtmiunis for Mortgage lnaunmec, Bftmm shall pay dw prmmhtms tdyuired to obtain
coverage substantially equivalent to 111w Idaeteae Ia waoas previoudy in oflaa, at r coat sari tuiaitY
equi t to the coat to Borrower of the b?MW Inmate previously in affaot, ft M an ahearaee
mortgage suave selected by Loader. If tubstawidly equiwient MogW lumrance aovmp is trot
Available, BMW" shalt continue to pay to Leader the amw d of the sepaately dnabOd payments that
were due when the insuranua coverage ceased to be in st1hat. Lander will swept, use aid rayin titterer
payment as a nortaefbncbbta loss rCWV6 in lieu of Mortgage Insurance. SAreh loss unnerve :lieu be
nmttetilodttble, notwithstanding the that that the Loan is Wdm tely paid in Nil, and i ender shill not be
required to pay Borrower arty itxma or earnings on snob lea reserve. Icndtx can no longer require toss
reserve pay km if Mortgage Irourancs o0varago an the amount and for 1119 period the I ender requites)
provided by an usurers selpged by Lender again becomes avahabla, is vbtriasd, tad Lender requires
separately designated paymm toward the premtmm ibr Mortpge Ipquance. If Leader ro*dWd Mortgage
bwxaaca as a condition of making the Lou and Borrower was requwed 10 MW
sgatratdy desipuated
Payment; toward the prcmittma for Mortgage Intntrance, Borrower shall pry the prudemt re Weed to
maintain Mortgage Insurance in effect, or to provide a n0a4dindable lose neuve, anti) Lender's
requbwmt for Mongege Iub taw ands in accordance with any wrium sgrerrAt between Borrower and
IA2der providing foe vxh ortniasdou or v a wrmimrton is trued by App,?c,7We IA*. Nothing in this
Section 10 dtku Borrower's obligation to pay intorest at the rate pmv' in the Note.
Mortgage I11mrsaw tnimburses Lender (or any enmity the purchasers the Note) for certain losses it
may incur if Borrower does not try the I.aan as agreed. Borrower is not a party to the Mortgage
Insurance.
Mortgage lower; evaluate their totd risk on all such insunmee in force boar time to time, ad may
enter irtbtt agreements with other parties that share or modify their risk, or reduce lames. These sgeeements
are an tams and conditions ttat are satisbsxnry to the mortgage I== and the other party (or parties) to
these Agremneats. These agreements may require: the mortgage insurer to make pagm u is using any source
of Muds that the moutgaM9 insurer MRY have available (which IWW Include funds obtained from Mortgage
lmurance prardums).
As a result of these a reerneats, lender, arty purchaser of the Note, another insurer, any reinsura,
any other awk, or Any AMIIIate of Arty of the foregoing. WAY receive (directly or indirectly) amounts that
dative 11 om (or might be charseted ed ere) a portion of Borrower's payments for Mortgage looMmee. in
exchange !tor sharing or modifying the tnortgsge insurer's dash, or reducing IDsm, If such agteensent
provides that aA affiliate of Lrnder takes a share of the insurer's risk In exchange for a share of ttu
premiums paid to the Insurer, the arrangement Is often tamed 'captive rdnmratsr." Porther:
(t) Any such Mvesnwte trill pot Affect the sanounft tbrt aorroW has atpned to pay for
mortgage v or any other tetras of the Lan. Slndr apusaseats will got increue the wMa nt
Borrower will owe for Mortgage bwram, and tbey will not sudde $otrower to any rdimd.
5 AAA
?8A(VA) p10N t•.o. ?» Fonn 3039 1101
MUM BK 19 1 OPG4880
by-1b-' by 17:; b FROM-
T-755 P0015/0060 F-657
(b) Any aueh agreusoants wW shot &Md me riglieba Borrewer has - if .eery . with r spo* to the
Mai mrow* under the ltgameownas !hale.. m Act of IM or anq other low. 7haas dotx
Mf? the rJdht to tticatve .Biwa &seiaow% a Below acrd ,..1-fain Modktioet of We
moo, io have the Move Luarsece Qeerrn W auts Mails, rm&0, b receive a rdhad Uradua? Rust wee unearned at due Wee of stab er eaWdon or
11. Assipument of Nliagll=eoae hum* g eintre, All Mieeellemoou: Protxeda ate hereby
sulgned to and dWI be paId to Leader,
it the is 4awaW. qwh miscellaneous, proceeds shell be applied to
the reetoratiop or repair of
proparty? resoortulon or repair is coo MO Wy feasible rod Lander'. secariw is not know.
f roP? a reuoratkvm
of period, Leader *1111 have the right to !told such sesumreove proceeds
until' has had an to lnspoct 06 PMP1tY to =am the work hat been Completed to-
t sd rMwt rMm n in - d" ch inspection shall wtdertal=pmopdy. Lender may pay IN the
t pafra and restoratio n in a Bindle Oi uaemrmt or in a Md" of puts the work is
?N?ed. Unlep an agreement is made la writing or AppliCaide Law r1atpires h to be paid oa such
Miscellap,001111 Proofs, Loader *dl not be ngWmd to pay Borrvwar any Ittdtueu or serninp on such
irftsc Weam Prooeada. If the restoation or paur is not economically feasible or Loader's security would
bee im ened, the Mh llanwus Prooeods sbalzrbee spplied to the in= secured by leis decudty iattsument,
whedur or not than duo, with the c,u, if any, paid to Borrower. Such Muoepar noes PsooeWs shall be
applied in the order provided for in swoon 2.
to the event of a total taking, destruction, or loss in value of tha Property, the Mismilaneous
Proceeds shalt be applied to the sum: secured by this Security Instrument, whether or not then due, with
the excess, if any, paid to Borrower.
In the avant of a partial taking destruction, of Ions in value of the Propatty in whieb do fair market
value of the Property Immediately before the partial taking, destruction. or lop in value u equal to or
greater thaw the amatatt of the sums panted by iris ScCt dty Instnaaent i>tmsedimely before the partial
taking, destruction, this Security by or IOU in value, unless Borrower and Instrument shall be reduced by >th aaaaoootherwisc agree in n of do i laneo us Pthe sums
roceeds
multiplied by the followleg fraction: (a) On total amount of the sums secured imrnedistaly befom the
partial taki destruction, or loss in value divided by (b) the fair ata.l:t value of the Property
nanediately before the partial taking, destruction, or lop in valna. Any bAuw 4tall be d to Borrower.
In the event of a partial taking, destruction. or loss in value of the piny In ch Ow fair market
value of the Property immediately before the partial taking, destruction, or lop in value is less than the
amount of the stars $KWW i=ladindy before the Wool taking, destruction, or loss In value, wiless
Borrower ad Leader othawise agree in writing, the MisceBaneout Proceeds shall be applied to the sums
secured by this Se=IT insmen
trut whedw or not the am era than due.
If the Property is abandoned by Borrower. or it, after notloe by Leader to Bortowa that the
OPlosleg p'as1Y (as defined In the nett sentence) otters to make an award to settle s claim for damages
Borrower fails to respond to Leader within 30 days after the due the notice is given. Leader is authorited
to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the
suet secured by this Security Instrument, wltahrr or not UM due. Vppositig Puty• mom the third party
that owes Borrower Miscellaneous Proceeds or the perry &gal= whom Borrower has a sigh of action in
regard to Misoallancous Proceeds.
Borrower shall be In default if any action or proceeding, wbether civil or criminal, is begun that, in
Lender's judgmwt, ovuld result In forfoivm of the Property or other material imipaimoeat of Leader's
I== in the Property of riou under Otis Security Instrument. Borrowaf rasa cars such a default and, if
acceleration has oectured, nwslats as provided in Section 19, by owing the action or proceeding to be
etftPA) toaoee
P*" 10 .11 s form 1039 1101
D04-0A
BK191OPG488I
17y-1?a ?y 17:3b FROM-
T-755 P0016/0060 F-657
dismissed with a ruling that, in Under's jhwgthtent, pmdudu foft u s of the Property or odwr material
impairment of Lender's httenest in the Pmpotty or rlgW undnu this Seourky Instrmnnaot. The proceeds of
any award or claim for damages drat are attrflmaable to the tats of Leader's interest in the property
are 4ooeby assignod ad shall be pod to Laude.
All Miscellaneous ?tooo*& that are not applied to restoration or repair of the property shall be
applied iu the order provided for In Secdoo 2.
12. 8atrowa Not Released; >Porbatrna By Lander Net a Wdvar. Lxtettaioa of the time for
Payment at modlAwAon of amortkW= of IN soars setarrad by this Security Iaftromont gtamodby Leads
to BUZO vnr or say SapCearoa In Imnwt of Borrower ;bell not operate to then the liability of 8oetower
Z Sha cessan In Interest of Sommer. Lender taludl not be worW to ocmmeace protxodittgs swot
Y?tceaaor in Interest of Bosrowu or to room to extend dow fat paymmt oe otherv?ise modify.
amotdUllon of dw sums secured by this Soc arlty Iw nnocat by reason of any demand made by the ad 'real'
Borrow or any Successors in Interest of Borrower. Any lbrbesraaee by Lander in asoisipg ray or
r=WY Including. without lladtation, Lander': oceptanos of payments fboa third pessoos. ouddes or
Successors in Interest of Borrower or in amounts loss than the amount dsa due, shall not be A waiver of Or
Prechter the Candse of nay right or rowdy.
IS. Jelhnnt and Several 14"tyl Cowl otY aid Aedpa Bound. Borrower covenants
and agrees that Borrower's obligadons and liability shall be joint aod:twesd. However, arty Borrower who
ensigns *b Security InstmOwnt but does not axtatte the Now (a 'oo•dgaer`), (a) is ao 4lgning this
Security instrument only to mortgage, gttmt and convey the co-signer's interest in the Property under the
terms of this Security Inanutnenl; (b is not peamally obligated to pay tlt¢ sums secured by this Security
Instrument: and (c) agrees tat
h Leta and any other Borrower can was to attend, modify, forbear or
make any aoeommodadons with regard to the tarns of this Scoarlty Instrument or the Note without rite
ccr-signer's COMM,
&Ib cct to the provisions of Section 18, any Seemsor in bxerest of Borrower who assumes
Borrower's obligaions under this Security Instrument in writing. and is approved by Lender, shall obtain
all of Borrower's rights and benefits under this Security Instrument. Borrower :bill not be released flrom
Borrower's obligations and liability under this Secw* Instrument unless Leader to suoh rd"" in
wridn;. The oovetants and agreements of this Security Instromi at shall bind rexc?t as provided in
Sxtiom 20) and benetlr the succatsors and assigns of Lender.
14. Loan Gauges. Leader mg charge, Borrower fees for services performed in connection with
Borrower's d"It, for the purpM of protecting Lender's interest in the Property and rights under this
Security Instmtment, indudLng, but trot !united so, evornoys' thee, PAY b 4'On and valuation fare.
In regard to any other fees. W axwm of egress authority In this Security Injument to claw a specific
&e to Borrowor shall not be oonsttuad as a proMbltion on the chargiq of ao al fee. Lender nay sot ebarge
fees that an expressly hibited by this Security I strunwat or by Applicable Law.
If rite Loan is sub aCt to a law wldeh rats maximum loan charges, and that law is finally inkrpreted so
that the interest or other loan char ?at eoilocted or to be collected in comwedon with the Loan exMW the
permitted limits. then: (a) any such loan charge shall be metre; by the amount necessary to reduce the
charge to the permitted limit: and (b) any sum already Collected from Borrower whidt exceeded permtted
limits will be refunded to Borrower, Lando may choose to make this refund by reducing dine Principal
owed under the Note or by a direct payment to Borrower. If a rotbnd reduces primo 1, the
reduction will be treated as a
Pu=
withart any psepsyahahet dMp ( or not a
PMAYment dhuge is provided for under. Borrower's aco" or any such refund made by
direct payment to Borrower will codstipttc a waiver or any right of M %MA er might Mft wising out
of auch overcharge,
is. Notices. All notices given by Borrower or Lender in connection with this Security Instrument
must be in writing. My nonce te Borrower in connection with this Security Instrument shall be deemed to
.?? 7-Z. A.
BAMA? 0a':ow pry. oft N - 3039 1 rot
DMOA
SK191OPG4882
09-10-'09 17:36 FROM-
T-755 P0017/0060 F-657
have bcen given to Borrower when mailed by fitu ilia =0 or whm neurally dell*=1 to Borrower's
n
Imles; otice addrW if scut by other mains. Notice to any one borrow shall constitute notice to all Borrower ;
? cab Law "maly MOM ooh nit. The Odra address shall be On Property Address
unl Lauder er has designated a substitute notice address by notice to Lender. Borrower shall promptly
fY Borrowers chimp of addrew if Larder 900m a procedure for r*onhrg Borrower's
dm%c of addceat. than Boxmw shall only report : dm$e of address dnroagh that specified procedure.
Thera may be ode one dedgwttod notice wid" uOhr tide Security hwaiiew ac any are time. Any
notice to I.eadef shall be given by delivering i< or by twilbrg it by first class until to Lender's address
stated heroin unless Lender has designated ataother addross by rmeice to Borrower. Any notice In
connection with this Security Insttunr s shall not be deemed so have barn given to herder until NMWIy
received by render. If any notice required by this security lastrawant is ab•v rogokW under Applicable
L
aw Applicable law requirement will satisfy the conetpwAh% requt mm under this Security.
Instrument.
16. Go'f Wd" Law; Severabllityi Sales of Conotrudi . Tbh Secmky Instrmment shall be
governed by W" law and the law of the jurisdiction in which duo PrcWW is located. All rights and
obligations conwined in this security Instrument are subject to requirements and limitations of
Afplkabk I". Applicable Law might explicitly or implicitly diow On Par" to sgroe bin contract of it
might be silent, but such silence shall not be tuna rmd w a p mWbIdou as" agreemen by comm. In
the event that ally provision or clause of this Security ittsttuasent or the Note conflicts with Applicable
Law, such conflict ship not affect other provisions of this Security huttument or the Now which can be
given eflbca without the congiating provWon.
As used in this Security Instrument. (a) words of do nwtcviioe gender shall mean and include
Comas O411g neuter words or words of the teminina geudar: (b) twook In the slmgotar shall mqn and
include the plural and vice Yana, and (e) the word 'arty' gives sole discretion without nay obligation to
take any action.
17. Borrower's Copy. Borrower shall be given one copy of the Note sari of this Socu ty Iasu went.
IS. T aader of the Property or a BoWkial laterest In Borrower. As used in this Section 18,
'Interest in the Property' means any legal or baaeficial laterest in the Property, including, but not limited
to, those bmdcciai interests transferred in a bond for deed. contract for deed, install tnsnt sales contract or
escrow agreement, the intent of which is the transfer of tide by Borrower at a futnm date to a purchaser.
If all or any part of the Property or any Interest in the Property is sold or traroterved (or if Borrower
is not a natutal person and a beneficial interest In Borrower is sold or trans&nan without Lender's prior
written consent, Landor may require Immediate paystent in fill of all stuns secured by this Security
Instrument. However, this option shall tot be searched by render if such a tercim Is prohibited by
Applicable Law.
If Lander exercises this option. Lender Spell give Borrower notice of soaelecation. The notice shall
provide a =Borrower not less than 30 days from the date the notice is given in accord aaoc with section 15
within which Borrower must pay all surfs seamed by this Security Instrune u. N Borrower fails to pay
time sums prior to the expiration of this period. Leader may invoke any remedies permitted by this
Security lbstrumeat without Author notice or demand on Borrower.
19. Borrower's Rlgbt to Rehsctate Mar Acceleration. If Bormwev treats certain conditions.
Borrower shall have the right to have Wforeement of this Security Instntnsatu disaoatktued at time
prior to the earliest of: (t) five days before sale of the Property to any power of sate ?aaaaf?y to
this Security Instcuma; (b) such other period as Applicable might S W.W for the termination of
Borrower's right a reinstate; or (c) entry of a judgment eahbreiug this Secatiry Instrument. Those
conditions are that Harrower; (a) pays Lender all sums which then would be due under this Security
Instrument and the Note as if no &=Iemtion had occurred; (b) cures any default of any other covenants or
SAtPAI tons rp, it 61 to
Form 30" trot
oaw•vn
8K 191 OP64883
09-10-'09 17:36 FROM-
T-755 P0018/0060 F-657
agramnwts; (c) pals all expenses itteaaned in edordats this Security Intamu rent, indaditts, but not limited
to, a , Inspection and valuation foes, and other fees Incurred for the
Pam ed Prottxxintt 's in the hVerty sod rights uWw duds Security Instrument, turd (d)
tastes $Wh union a Lmader may reasonably mgdm to semen that 1re4t1er's Interest in the Property and
dshm under this Security Instrument, and Borrower's obligadoa to pity At sum secured by this Sumity
Instrument. dull condme undumpti. lender may require fiat Dwower Pay welt vskormt tstrmt and
expanse In one or more of the Mowing lbrms, at selected by Lader: (a) cash, (b) money order; (e)
endued dw t, bank check, treasurer's cheek at o ubiar's dwL prvvbw any such check is dem open
sat Institution wbow deposits are WaM by a MW tt ng, inky or oft or (d)13ba mutt:
Fands'1lnmafhr. Upon a' I -ateuae it by Boo war, thise? Inswimeot and obitsetioea secured have
shall recta in My eaflactive as if no Acceleration had Howw"r, this right to reinseate staid rat..
apply in the ass of aocelesration undar Section IS.
20• Sale of Notal Chan* et Loan Setvieer, Netfc6 of Cklemm. The Note or s partial interest in
the Not: (togother with this Security Insttuumno co, be sold one to more fiance without notice to
Borrower. A laic ukk result in a chose in the entity (ltaown as the 'loan ftvicer¦?that comets
Periodic PeytttOs On under the Now and Us Security Itstruatmht amd pe tc cros other nWrWP loan
servicing obligtulans under the Note, this Set dty imtsommtt, ad Applies Law. nm also might be
one or more changes of the Lou Servicer utnelated to a sass of the Note. It them Is a ebonsa of the Loan
Setvicor, Borrower will be given written notice of the change which will sure the new end address of rho
new Loan Setvicar, the address to which payments should be ua& and any other iafortudon MPA
regetires in connection with a notice of trutsfor of servicing. If the Note is sold and dae utter the Loan is
ssnviceud by a Lout Servicer other than the purchaser of the Note, the mortgage tetan servicing obligations
to Borrower will remain with the Loan 3erviear at be tran+(etrod to a saccaator Loan Servieer and aro not
assumed by tbo Note purchaser unless otherwise provided by the Note paardwar.
Neither Borrower nor Lc,der may commence, join, or be joined to any judicial action (as either an
individual lidgmet or the member of a dass) that arises then the other party's actions putgtanc to this
Security Instrumat or that alleges clot the other panty has breached any provision d. or sqy duty owed by
reason of, this Se Inutru icut, nmdl latch Borrower or Lmader has notified the outer patty (with such
notice given in compilanco with the requirements of Swim 13) of fetch »Wged brew and afforded the
other potty hereto a reasonable period otter the giving of such nouns to take eorrecove action. If
A-11-hie Law provides a time paudod which most alapse befin curtain action can be W am, do time
period will be deemed to bs reasonable for porposes of this paagaph. 1% funded, of aoteie>tettion and
opportunity to ease liven to Borrower Pursuant to section 22 and the notice of sooderatlon liven to
Borrower ptarwant to Section 18 shall be deamd to sandy the notice and oppogtoniry, to take cmwdve
action provisions of this Soctiou 20.
21. gar rdo% Substances. As used in this Section 21: (a) 'Haratdoua Subsunc es' are those
substances defiucd as toxic or hazardous substances, pollutants, or vmm by Eaviromaeatal Law and the
following substances: p solute, kwo mas, other 11aim able or fordo peerclemn products, toxic penicides
and herbicides, volatile solvents, matm'ialt coutsinhig asbestos or formaldehyde. and radloaetive ttaasetids;
(b) 'Bnvironnwatal Law" assns Were] laws and laws of the jurisdiction wheere the property is located that
relate to health, safety or environnmial protection; (c) 'Eaviroo>esesta1 Clsamo" includes any response
action, remedial action, or removal action, as defined in En !muse ntal Laver, std (d) an 'linvirvmnontal
Condition' masse a condition that can caws, contribute to, or otherwise trigger an Environmental
Cleanup.
711A
eAePAa Mon f y? u w u ?? Poem 3036 Vol
BK191OPG4884
09-10-'09 17;37 FROM-
T-755 P0019/0060 F-657
Borrower " Dot caws or Permit ON Pretence, nxe, disposal, c, or relmse of any Hamrdoes
Substances, or thream to release any Hatsudoas Srbm". as cr is ? . Bummer "not do,
nor allow "hma else to do, . ydthtl ?ha proPottY (s? that b la v of rnt F?wimDDmeanl
Law, ) M?hid or"" an ?Saft=Eptal `?entl0nr of (C) wwc dui 0 the F010004, U04 or mieala of a
two mloom slue; rm an s cottdittwt drat atl y attars t? vahrs of ,, '01%
p?oedi?,?
+tOpIY to ? %xv, sae, of sawrt?ge on the o aasunU qwo?
Huardoua Subsimms?y ?reoori. to be Vptopdata to reAkalai nset gad to
mwabmmp of tbo p t toting, Urdted to, Iaaetdous subsmm In o o mer
Bmvft r 11aU Pftmf iy give Candor wrium noting of (1) my in?a. Will. 40=0 wiWt
or other action by any goverameatal or rgdatmy or unto 41, *0 hQWW ad my
Haasdous Subtance or Emrironmow Law of w Borrows ht1 aotad R) of
Enviro==W Condition including but not Ihafoed to, tpft, lWng. d e Ong release of any Ha wdoas Substance, and (c) any coal csusW by the Pr's, vu ot ulna of or
Hatstrdotts subgtanoe which advemeUr s?feots rho vmbm of dm 8topeety. If Borrower learns, or Is modAW
by vary verammgd or ttlg , or mY p Pwy. drat rearo or other[ remedimilon
of mtw t Sbbatnoe dw proptetr is neoeaquy. 8osrowar shalt provleml
pdy a8 eo
alontoWi on
mmedlat at am is aoootdam with lkvitnmmtel Law. Nothing hetain Val emm aDy aWUwty
Leads foe an Eavironmew d Caelm? p.fi
NON-UNIFORM COVI 7r. Borrower mad Lender Mahn oavoaattt ••ad W. as follow.:
22• Amlerationt Remedies. Leader ahoy give satkt to BormwprIor to aowimmion
Borr maliv breach of any covtnaat or opeetttcat in dds Smimity betraouet OM ad _Oder hawwb
to
seeattaWea uadw Section it uWm A ? Law l?da odmwim ). Lmdar dog am*
else ds6olt t be curd 7 (a) the %W(b) the action t+sgtdged to cure ttha tltslhn? (? when
ed; and (d) that [When to care 60 AN* sin aw et/tlit is
acceleration of tits sums eecared by to 9a?q' lmtaement, twedowtre M? pr
lhoperty. Leader ahaU f+ettftar iofoem Bolroweg of the right to relumb aftr ao?a
and the ff to aatiert to the faged"m pe g the soa•esdrleaee d a do&* or aw other
deteose of Eort+owar to m;ukt ra4n and terWasam. if the default is act tauad as Lauder at
its option away tequke itnrtrodtate In hill of ad mm nm d by that 3eearity
without drttMe and law tom ma , Instrument by judf w L:t
sbaU M satiWd to cotieet aU txpgntae inn uTW in ppr the remdim provi to tW oa 22,
tncpl but not lingtod to, attoraayt:' keg gad costs title "Wens to the extant Fensitted by
APPI Law.
23. Release. Upon payment of m11 mm secured by this Saourtty Imo, this SwAity bmum nt
and the eaate ooavnyW "I terWaste and bmma void. After such oacurmoe, leader " dimbuge
sad* this Security Instrument. Borrower shall pay an lrxordmtbs costs. Lmdar may tit qe
ftTower a he for relessing this Se?curitY barvmmt. but oWy if the fee is paid to a t1drd party fa smvias
rendered and the nbargiati of the fan Is pormitkd under Apoksbio law.
24. Waivers. Borrower. to the tntDlntemt "Im W by Andico* Law. valves and slams say error or deftcts
promedings to future IM p tot stay of execution, y W and a? y waives the benefit of aW present or
and bomaatead exemption. Mort trove mttschmeat, 16y and We,
25. RtWM& aeut Period. Bmtracver's than to reinstate provided in S"dou 19 shall extend to one
hour prior to the commm"matt of bidding st a sherifrs sale or other sale pummU to this security
Instrument.
2d. Putbase Mousy Mode. If soy of the debt sa meti by this Security lruttuomnt is lent to
Borrower to acquire dde to the property, this Security Instrument shsll be syu-cltaig moucy 27. Interest Rate After .ludam w. Borrower sprees thu the imerast rate •MymWee tfur? is
entered on the Now or in an action of mortgage foreclosure shall be the rue payable from tme m time
under the Note.
QtWPA) mm)
Pon* 14 of 10 form 3030 1101
OeS.MA
OK 191 OPG4885
09-10-'09 17:37 FROM-
By SK"NG BELOW, Dwower acoepm and Wow to the Was and oovemnts oootained in Ws
Sawrity Lat U=W and in ay Rider exciawad by &mower mnd reeordad w f*.,.
Wnueeuea:
O) (seal)
-8oUoww
(Seat) (W)
-BOMWer ,Bn~
Ali
CHAD E. ASHLEY
' (Scot)
TRACEY L. ASHLEY
T-755 P0020/0060 F=657
(Seal) (See)
-86nDwet .Batcowec
ft"PM atom
OMIPA
Pep 16 of to
/OflMI sm +lot
8K 191 OPG4886
09-10-'09 17:37 FROM- T-755 P0021/0060 F-657
Cerdl?eata of Iteddwtee ?? ?' J?-- ? J ,. ^
I' do Wmby oertify OW
dt corract address of tha within-numd Mortgagee Is P.O. Box 2026. Flint, MI 48501-2M6.
Witceas my hood this i day of VJt,-k "400S
C ACK V. VA VAL
Pvi*M A`saa otmoup$ft
:. n f11)gc h- m
COMMOMMALTH OF PENNSYLVANIA. County ast
On this, the day of Jv c?00`, , bctbrc mc, ttte
ttttderstCned ofticer, personally appeared cl"a 9 _ Q•34?? ``
i Ott?O ?3 p.czl L
satisfaclarily proven) to W the known to me (or
achnowl°48ed that he/sWthey asxa?coted ) this w same e for the p tut da purrposposees herein ootaltonrd. the widda instrunum and
n
IN WI[NEU WKUBO . I betam set my band and official teal.
MY Commission Expires:Otl _ k lw'C\50
Paft pa*
Lower
. Men
t -e;AiPA) 02oei rw. +s a t o . Form d i m
T A.
BK.19 1 OPG4887
N6'Q 1
09-10-'09 17:37 FA011-
T-755 P0022/0060 F-657
Stewart Title
Legal description of the land;
f_EGAL DESCRIPTION
ALL THOSE CERTAIN tracts or pieces of lend situated In the borough of New Cumberland, County of
Cumberland and 81ate of PenrWivanis, b"V the Northam 20 feet of Lot No. 34 and the Southern 2 feet of Lot
No. 33, 8" "H", in the general plan of =1 W. Bubx tls Addition to the Borough of New Cumberend, as
recorded In the Recorde une b, Page 488, and the
Southern r's oft* at Csdnnoylvania, in Deed Book *W' Vd
portion of 4 feet of Lot No. 34, Block H, in the general plan of George, W. Buttcrl's Addition to New
Cumberland, as recorded in the above described Reoordoes.Offioe In Deed Book *W, Volume 11, Page as,
both tracts more particularly bounded and described as follows, to wit:
TRACT NO. 1
BEGINNING at a point on the Western Une of Eutaw Avenue, said point being 71 feet In a Southerly direction
from he southwest comer of Ruby and Eutaw Avenues; thence in a Westerly direatbn by a line at fight angles
to Eutaw Avenue, 140 feet to Pear Allay; them In a Southerly direction aktM the Eastern line of Pear Alley 22
feet to a pohtt; thence In an Easterly direction 140 feet to Eutaw Avenue; twine In a Northerly direction along
the Western line of Eutaw Avenue 22 feat to the place of BEGINNING. and ha ng erected thereon the Southern
half of a double two and ons4W story bride and theme dwelling house, known as No 318 Eutaw Avenue, and a
part of a two and one-half story building to the rear of the above referred to dwelling.
TRACT NO.2
BEGINNING at a point 49 feet North;ef the Comer of a certain alley In Black H, and Eutaw Avenue, known as
River Alley, and extending WesMrl?y 140 feet to a 20 foot wide alley, thence Northwardly, 4 fast to a point:
thence Eastwordly through the Southern portion of Lot No. 34, 140 foot; them Southwardly 4 feet to the
Northern line of Lot No. $4, the place of BEGINNING, havktg erected thereon ft other ps# of a two and
one-half story building to the rear of the dwelling referred to as 310 Eutaw Avenue in Tract No. 1, above describe,
BEING PARCEL #26-254)006-124
1 Certify this to be recorded
In Cumberland County PA
h "w
Recorder of Deeds
Levi Desorption
MON54U PFOMOOM54M)
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McCABE, WEISBERG & CONWAY, P.C.
BY: MARL S. WEISBERG, ESQUIRE
Identification Number 17616
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
HSBC Bank USA
v.
Tracey L Ashley
and
Chad E Ashley
Attorney for Plaintiff
N ~~
a -i
v ~
~
rte"'
'~ ~
Cumberland County ~, ~;' ~ c': ~~~
Court of Common Pleas ~ ~ Vi
~ ~~ r~-,
Number 09-8528 Civil Te
"
r -c
PLAINTIFF'S REPLY TO DEFENDANTS' AFFIRMATIVE DEFENSES
Denied. Said averment is a conclusion of law.
2. Denied. Said averment is a conclusion of law.
WHEREFORE, Plaintiff demands judgment against Defendants, Tracey L. Ashley
and Chad E. Ashley.
Respectfully submitted,
McCABE, WEISBERG & CONWAY, P.C.
BY:
MARC S. WEISBERG, ESQUIRE
Attorney for Plaintiff
McCABE, WEISBERG & CONWAY, P.C.
BY: MARC S. WEISBERG, ESQUIRE
Identification Number 17616
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Tracey L Ashley
and
Chad E Ashley
Cumberland County
Court of Common Pleas
Number 09-8528 Civil Term
CERTIFICATE OF SERVICE
I, Marc S. Weisberg, Esquire, attorney for Plaintiff, hereby certify that a true and
correct copy of the within Reply to New Matter was served on the below party on the 4th day of
June, 2010, by the United States mail, first class:
Tracey L. Ashley, Pro Se
316 Eutaw Ave
New Cumberland, Pennsylvania 17070
and
Chad E. Ashley, Pro Se
316 Eutaw Ave
New Cumberland, Pennsylvania 17070
Ck~
DATE: ~ ( J
Attorney for Plaintiff
MARC S. WEISBERG, ESQUIRE
MCCABE, WEISBERG & CONWAY, P.C.
Heidi R. Spivak, Esquire (Attorney I.D. 74770)
123 South Broad Street Suite 2080
Philadelphia, PA 19109
HSBC Bank USA,
Plaintiff,
v.
Tracey L Ashley
Chad E Ashley,
Defendants.
Attorney for Plaintiff
Cumberland County
Court of Common Pleas
Number 09-8528 Civil Term
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
c <? o
y
-
.c
Kindly mark the above captioned matter as Discontinued and Ended, without prejudice.
McCabe, Weis
Attorney for P]
rR.
By:
HEIDI R. S
& Conway, P.C.
ff
MCCABE, WEISBERG & CONWAY, P.C.
Heidi R. Spivak, Esquire (Attorney I.D. 74770) Attorney for Plaintiff
123 South Broad Street Suite 2080
Philadelphia, PA 19109
HSBC Bank USA,
Cumberland County
Court of Common Pleas
Plaintiff,
Number 09-8528 Civil Term
Tracey L Ashley
Chad E Ashley,
Defendants.
CERTIFICATE OF SERVICE
1, Heidi R. Spivak, Esquire, hereby certify that a true and correct copy of the within Praecipe
to Discontinue and End was served on the below person by the United States mail, first class,
postage prepaid, on August 26, 2010 .
Chad E. Ashley and Tracey L. Ashley
316 Eutaw Ave
New Cumberland, Pennsylvania 17070
9/-L,/,- J
DATE: