HomeMy WebLinkAbout04-2896
F a,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
WAYPOINT BANK, F/KJA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
vs.
No. 0'1- 1 ~lj(, ~ TL~
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
NOTICE TO DEFEND
Pursuant to PA RCP No. 1018.1
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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
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 PERSON AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE OF THE
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
EN LA CORTE DE ALEGATOS COMUN DEL CONDADO DE CUMBERLAND,
PENNSYLVANIA
DIVISI6N CIVIL
WAYPOINT BANK, F/K/A
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
contra
Num. Del Caso.
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
AVISO PARA DEFENDER
Conforme a PA RCP Num. 1018.1
USTED HA SIDO DEMANDADOI A EN LA CORTE. Si usted desea defenderse
contra de la demanda puestas en las paginas siguientes, usted tienen que tomar acci6n
dentro de veinte (20) dias despues que esta Demanda y Aviso es servido. con entrando
por escrito una aparencia persona/mente 0 por un abogado y archivando por escrito
con la Corte sus defensas 0 objeciones por puestas en esta contra usted. Usted es
advertido que si fal/a de hacerlo el caso puede proceder sin usted y un juzgamiento
puede ser entrado contra usted por la Corte sin mas aviso por cualquier dinero
reclamado en la Demanda 0 por cualquier otro reclama 0 alivio solicitado por
Demandante. Usted puede perder dinero 0 propiedad 0 otros derechos importante
para usted.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI
USTED NO TIENE UN ABOGADO, VAYA 0 LLAME POR TELEFONO LA OFICINA
FIJADO AQuf ABAJO. ESTA OFICINA PUEDE PROVE ERE CON INFORMACI6N DE
COMO CONSEQUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE
PROVEERE INFORMACI6N ACERCA AGENCIAS QUE PUEDAN OFRECER
SERVICIOS LEGAL A PERSONAS ELIGIBLE A UN HONORARIO REDUCIDO 0
GRATIS.
LAWYER REFERRAL SERVICE OF THE
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION -- MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KJA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
vs.
No. 0'1. ~ rq(. ~"""It.--.
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
COMPLAINT
AND NOW, comes Plaintiff, Waypoint Bank, f/k/a York Federal Savings and Loan
Association and Harris Savings Bank, by and through its attomey, Benjamin F. Riggs,
Jr., and complains of Defendants, Richard J. Gordon and Patricia A. Gordon, as follows:
Parties
1. The Plaintiff is Waypoint Bank, a corporation organized and existing under
the laws of the United States of America, and it is registered to do business in
Pennsylvania, with offices for the purpose of doing business at 235 North 2nd Street,
P.O. Box 1711, Harrisburg, Pennsylvania 17105-1711.
2. The Defendants are Richard J. Gordon and Patricia A. Gordon who are
husband and wife and are adult individuals and are the mortgagors and real owner of
the Mortgaged Premises located at 836 Meadow Lane, Camp Hill, Pennsylvania
17011, Cumberland County, having acquired title by Deed dated October 7, 1976, and
recorded on October 8, 1976, in the Cumberland County, Pennsylvania, Recorder's
Office in Record Book 26-V, Page 526. The Defendant Richard J. Gordon is residing at
2971 North 2nd Street, Harrisburg, Pennsylvania 17110. The Defendant Patricia A.
Gordon is residing at 836 Meadow Lane, Camp Hill, Pennsylvania 17011.
Mortaaae
3. On or about November 11, 1998, Defendants made, executed, and
delivered to Plaintiff a mortgage upon premises therein described, which Mortgage
contains a description of the premises subject to said Mortgage and was recorded on
November 13, 1998 in the Cumberland County, Pennsylvania, Recorder's Office in
Mortgage Book 1497, Page 21. A true and correct copy of said Mortgage is attached
hereto, made a part hereof, incorporated herein by reference, and marked "Exhibit A".
Assianments
4. There have been no assignments of said Mortgage.
Default
5. Said Mortgage is in default because Defendants have failed to make the
monthly payments of principal and interest due and owing on their loan from July 1,
2003 through the date of filing this Complaint as required by the terms of the Mortgage.
Any payments that may have been made during this period were applied to the
delinquency balance due and owing prior to July 1, 2003.
6. Plaintiff hereby exercises its option to declare the entire amount owing
upon said Mortgage immediately due and payable in accordance with its terms and
provisions.
7. By reason of the default, the following amounts are due in accordance
with the terms of said Mortgage:
Unpaid Principal Balance
$64,484.39
Interest from 6/1/03 to 6/15/04
(inclusive) at $10.1585 per diem
$ 3,669.96
Late Charges from 7/1/03 to 6/15/04
(inclusive) at $52.15 per month
$ 521.52
$ 3,224.22
$71,900.09
Attorney's Fees 5%
TOTAL AMOUNT DUE
Compliance with Homeowners' Emerqency Assistance Act
8. The Temporary Stay as provided by the Homeowner's Emergency
Mortgage Assistance Program, Act 91 of 1983, has terminated because either:
(i) Defendant has failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiffs written Notice to Defendant, a true and
correct copy of which is attached hereto as "Exhibit B"; or
(ii) Defendant's application for assistance has been rejected by the
Pennsylvania Housing Finance Agency.
Inapplicability of Loan Interest and Protection Law
9. This Action is not subject to the provisions of Pennsylvania's Loan Interest
and Protection Law, Act of January 30, 1974, P.L. 13, NO.6 (41 P.S. S 101 et sea.), as
amended, nor are notices required to be sent to Defendant(s) pursuant to said Act,
because said Mortgage is not a "residential mortgage" within the meaning of said Act.
Termination of Automatic Bankruptcy Stay
10. On or about June 25,2003 Defendants Richard J. Gordon and Patricia A.
Gordon filed Chapter 13 bankruptcy with United States Bankruptcy for Middle District of
Pennsylvania, which bankruptcy case was docketed to Case No. 03-03788.
11. On March 23, 2004 said Bankruptcy Court entered an Order terminating
the automatic stay arising from virtue of 11 U.S.C. S 362(a) with respect to Plaintiff, and
permitting Plaintiff to bring this action to foreclose said Mortgage. A true and correct
copy of said Order is attached hereto, made a part hereof, incorporated herein by
reference, and marked "Exhibit C".
WHEREFORE, Plaintiff Waypoint Bank, f/k1a York Federal Savings and Loan
Association and Harris Savings Bank prays for judgment in its favor and against
Defendants, Richard J. Gordon and Patricia A. Gordon, in the amount of Seventy-One
Thousand Nine Hundred and 9/100 Dollars ($71,900.09), with interest thereon until paid
at such rate or rates as established by Plaintiff pursuant to the terms of the Note,
currently $10.1585 per diem, from June 16, 2004, late charges at 10% of the monthly
payment amount, currently $52.15 per month from June 16, 2004, attorney's fees, costs
of suit, and other charges collectible under the Mortgage; for the foreclosure and sale of
the mortgaged premises; and for any and all other relief as the Court deems
appropriate.
Dated: June 21, 2004
By: I rfl j A
Benja~. Ri;;l!Jt
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
Phone: (717) 815-4518
I.D. No. 72030
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Account Number _M070.0_2761
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OPEN. END MORTGAGE
(This Mortgage Secures Obligatory Future Advances)
THIS MORTGAGE is made this ~ day of
P~tricia__j'\. Gordon
of _~BJ6 Meadow Lane. CAmp Hill. PA 17011 . (whether one or more
persons c<llIe(j "Owner") and HARRIS SAVINGS BANK, 2nd and Pine Streets, Harrisburg, Pennsylvania 17101, (called "Lender"),
WHEREAS, Richard J. Gordon and Patricia A. Gordon (whelherone or more
persons called "Burrower") has been granted a Prime Line of Credit Account (called the "Account") by Lenderwith a Credillimit of $~ 000 . 00
as evidenced by an Account Agreement (called the "Agreement") datE!d November 11 . 19--.2.L; and
WHEREAS, Lender is obligated under the terms of the Agreement to make advances to Borrower from time to time up to the amount of the Credit Limit; and
WHEREAS, Borrower has agreed to repay such obligatory advances and interest thereon in accordance with the terms of the Agreement;
NOW, iHEREFORE, in consideration of the above premises and in order to secure to lender the repayment of all amounts, with interest thereon, advanced
to Borrower in accordanCe with the terms of the Agreement, the payment of all sums, with interest thereon, advanced in order to protect the security of this
Mortgage, the performance of all covenants contained in the Agreement and this Mortgage, and all extensions, renewals, modifications and amendments of
the Agrpement, Owner does hereby mortgage, grant and convey to lender all of the folJowing described real estate, together with all improvements now or
hereafter erected, and all easements, rights and appurtenances thereon, situated in the following (City/Township/Borough) of (1) _Hampden
(2) (3) , Commonwealth of Pennsylvania,
known and designated as
November
_, 19~ between
Richard J. Gordon and
(1) R'Hi M"-'1,lnl>f r."np-
Street Address
('-'1mr Hi 11
Municipality
r'lmhp-rj >'Inr1
County
(2)
Street Address
MuniCipality
County
(3)
Street Address
Pennsylvania, which were conveyed to Owner by deeds
Municipality
County
,19~) and duly recorded )
) in the Office )
,19~) of the Recorder of )
) Deeds for said County )
(3) dated ,19~) in Deed or Record Book ) No ~Vol._Page__~
as the premises are therein described (the "Premises") and if this box is checked 0 as the premises, or any of them are more particularly described in Exhibit
"A" which is attached hereto and made part hereof.
Owner and lender covenant and agree as follows:
1. THIS IS AN AOVANCE MONEY MORTGAGE-It is expreSSly understood and agreed that this Mortgage secures, inter alia, certain obligatory loans and
advances to be made from time to time by lenderto Borrower pursuant to the Agreement, which future advances are secured by this Mortgage as if made on
the date hereof
2. Owner and Borrower warrant and represent to lenderthatOwner owns and is lawfully seized of the estate hereby conveyed and has the r'ightto mortgage,
grant and convey the Property, and that the Property is unencumbered, except for encumbrances of record.
3. Borrower shall promptly pay to lender interest, principal and any other sums due under the Agreement, in accordance with the terms of the Agreement.
4. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of the Property, or part
thereof, or conveyance in lieu of condemnation, are hereby assigned and shall be paid to lender, subject to the terms of any prior mortgage or security
agreement rhe proceeds of such award may, at lender's OPtion, be used to pay the outstanding amount under the Agreement secured by this Mortgage.
5. Except lor any notice required under applicable lawtobegiven in another manner, (a) any notice to Owner provided for in this Mortgage shall begiven by
delivering it personally or by mailing such notice by certified mail, addressed to Owner at the address of the Property or at such other address as Owner may
designate by notice to Lender as provided herein; and (b) any notice to lender shall be given by certified mail to Lender's address stated herein or to such other
address as Lender may designate by notice to Owner as provided herein. If notice is given by certified mail, it shall be deemed to have been given on the date of
mailing.
6. Owner will not sell, give, transfer, or encumber the Property or any right in the Property, in whole or in part, without lender's prior written permission.
7, Mortgagor shall be in default under this Mortgage if Mortgagor breaks any promise or fails to perform any duties contained in this Mortgage or in the
Agreement.
8. Upon default, Mortgagee, after notice required by law or in the Agreernent, may take any action allowed by lawor under the terms of the Agreement or this
Mortgage.
9. Any extension of time for payment or reduction of the amount due under the Agreement which is granted by Lender to Borrower shaJll10t operate to tel ease
in any manmn any other Borrower or Owner under Ihe terms afthe Agreement or this Mortgage. Any forebearance by lender in e~ercising any rigilt or remedy
unde'r this Mortgage ur otherwise afforded by applicable law shall not be a waiver of or preclude the exercise of any such right or remedy.
10. Lender's rights and remedies under this Mortgage shf!U be cumulative and the exerciseof any olle or more of these rights shail not preclude the e~ercise of
any other rights or remedies specifically granted in this Mortgage or permitted by law.
11, fhe covenants and agreements herein contained shall bind and the rights hereunder shall inure to the respective successors and assigns of the parties. If
more than one Owner signs this Mortgage, their obligations shall be joint and several
12. As f1de]itional security hereunder, Owner hereby assigns to Lender thE! rents of the Property, provided that Owner shall, prior to the declaratiOIl of an Event
of Df'fauil, have the right to collect and retain such rents as they become due and payable.
13, The state and local laws applicable lothis Mortgage shall be the laws of the jurisdiction inwhicl, the Properly is located. The foregoing sentence sh<lli not
limit the appiicabiiityoffederallawlo this Mortgage. In theevent that any provisionorclauseofthis Mortgageor the Agreernentconflicls with applicable law,
such conflict shall not affect other provisions of this Mortgage or the Aweement which can be given effect without the conflicting provision, and to this end the
provisions of this Mortgage and the Agreement are declared to be severable.
14. Owner agrees that any interest payable after a judgment is entered, or on additional sums advanced, shall be at the same rate as is stated in the Agreement.
PROVIDED, nevertheless, that should Lender's obligations to make advances to Borrower pursuant to the terms of the Agreement be terminated, and provided
furthermore, lhat should Borrower pay in full all sums secured by this Mortgage, then, upon written demand of Owner, lender shall, within 10 days, either
satisfy this Mortgage or record or deliver a written release of this MOItgage to Owner.
(I) dated
October 7
No. V-26 Vol. ~_ Page2~
(2) dated
No _ Vol __ Page
IN WITNESS WH~EOF, eadl Owner has hereunto set hand and seal the day and year first above written
~E~S ("/1~ (7 'c:7 f/,
~--LtI;)'~;;~(2~~ i~- 21 r I J'tfi '--uwn ,~~~c:'_) ~ ( #--~~'-"" (SEAL)
'-;/)) , -"::)u")~, ')17 <'<1-/ o~fE.J."lc<L) it tJ, A,.z.. (SEAL)
fJANCONSUMER rORM f'ASloa'2J (R~v, 7/~1) CLD-1247/91 DOUIt 149j PAGE ...21 ~19Cjl SANCONSUMER SERVIr E 'NC
OnrGINAL
NOTICE
rhl~ is ail AdVi:lrILi:; r,.10IlldY Mortga~e S8Cllrirl!5 an Op!:II' End lineD! Cledit upon whid180rwwel may obtain IOi:lllstrurn tirneio time, ev~n allel "I' .;xIsllng
bald,l(G I:; IJc,ld IllliJll~rlY It-!ljlkst jly Burruwer, or by dllYUI!i::'un 801 rnWt:I's heildlf,lilat (he ACClllll1l be lerllllllateJ pllortu lis maturity IIdte,l! cJIIY, rl1l1~t he III
wri!illg and sigrled by JII Borrowers.
REOlJESl mR NOnCE OF DEFAULT AND FORECl_OSURE
- UNDER OTHER MORTGAGES
;)wll.:r dllLJ Lender ("qllest tile hnlJer of allynlOrtgagelirOlherellcwnbrancerll1 tile Pmperly to nolify Lender, atthe address set forth below, ot 3IlYI]dallll,
sale III t'HecluSlIIe dlti'lfI tllcit pel1aills (0 the Property ur Lender's illleresttherein.
Illcreliy ccrilly that the plecise address of tile Lender (Mortgagee) is' 2nd and Pine Streets, Iiarrishurg, Pennsylvania 17101.
,,-..Ullbellolltder ,( ,
By. _it?" H'7(IlI'...Lo.l..-_ ~_______~______~__Tille: _~~andqer
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF kmlw ("'I Ft-- ~__ 55
011 this, ttle __~!_~lb. day of . Novembel~ __~________, J 9 2!2._~, before me, ~41 ~. /I c- 5.':'; ___.__.___
the undersigned officer, personally appeared _.B.is:!:!arc1~~!2QrclojL8.n[LJ'at["~ll_,...Gorc1illL..-.______ _.~_____~._
___________~___ ,known to me (or satisfactorily proven)
to be tile pelson(s) wtlOse name(s)__~~~_ ,____ subscribed as Owner to the within instrument, and acknowledged
that ~ ----.th~_--__-~__- execuled the same for the purposes herein contained and desired it to be recorded as 5111:11
IN WITNESS WHEREOF, (have hereunto set my halld and official seal. My Commission Expires:
_(--:;l:!riLJ~,~) ____
fillenfOfficer
NOlar1alSeal
Gall F. Hass. NOlary Public
Camp lIillBoro, Cumballand County
My Conunlsslon Expiras Apr. 15, 2002
Memher, Pennsylvania Association ot Nolaries
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BOul1497 PAGE. '. 22
)fIX 110, liii2312910
p OS
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.0.11 'I'HAT CBRTAIN 'Xuct of iand situate in lIompden Township shown as
95.00 feet to Lot No. 38 and J(;.75 feet to Lot No. 40 on FInn ot
Ilrentl'later, East Pe1lfJsboro and Hanlpden Township, Cumberland County,
Pennsylvania, recorded in the OfUce of the Recorder Of Deed., Carlisie,
Pennsylvania, in Plan Dook NO.4, Paqa 93, bounded and deBcribed as
fallows, to wit:
BEGHINHIG at a point, on the center line of Neadow Lane at the inter.ectior
of the Western line of ~ fivB (5) foot wide path now or lat~ of
flarold A. Monoeo, et UXI thence along the Western line of said path,
South l~ degrees 1, minutes East, two hundred forty-three and oighty
one IlUndredths (~4l.80) feet, more or ies., to the tence and property
Jina of land now or iate of r,awrence H. Walker, et UXI thence along
.aid fonce and property Itne, South n degree. 47 minutes WeBt, One
hundred eleven and eighty-three one /lundredths (I1L83) feet, more or
ie.a, to. point: thence l'/orth 1. degreea 13 mrnuto5 West, two hundred
forty~thre" .nd eighty one hUndtedths 1243.80) feet. more or leas, to
a point on the center line of Neadow I,alle, thence l;orth 77 degrees 47
minutes Ea.t, one hundred eleve" ami eigilty.theee one hundredtha 111),.83)
tae., more or less, .long .aid centee line to the point of 8EGINNING,
CONSIS'rlUG of 95.08 feet of Lot #36.rut e.. tern 16,;'5 feet of Lot #40.
HAVrNG theeeon erected a aingie brick and aluminum dwelling known and
numbe~ed 8B &]6 Meadow Lane.
B~U~ 1497 rAGE,
23
HARRIS SAVINGS BANK OF PENNSYlVANIA
PRIME LINE OF CREDIT
FEDERAL TRUTH-IN-LENDING DISCLOSURE STATEMENT. PART ONE
ACcourHNumber_ 0407002761 . ..__.__ D~te:N"overriter 11, 1998
THIS DISCLOSURE STATEMENT IS GIVEN TO THE BORROWER WITH. AND IS PART ONE OF. THE ACCOUNT AGREEMENT, THE ACCOUNT AGREEMENT, -THIS DISCLOSURE ~;TATE-
MENT AND THE DISCLOSURE STATEMENT OF THE REVERSE SIDE SHOUI.D BE READ TOGETHER AS ONE DOCUMENT
TERM OF THE ACCOUNT. During Ihe Draw Phase, BorrOWM Can obtain advances of ADVANCE OF CREDIT. Borfower may obtain IMns on tll" Account during the Dmw
creelit, the Draw Phase will end on the anniversary date which Occurs __lJ!_ years Phase. LemlM agrees ro make loans on the Account so long ss the outstanding halanr.~
does not e"ceed the Authorized Cr~dit Limit shnwn on the front side of the Prime Lirll'
of Credit Agreement, Each Bormw~r agrees 111at any nnB or more Borrowers ma~ ()bt~in
loans on rhe Account without the consent 0' signatwe of 'my olh~r BOrrowe" for an~
purpos~. All loans obtained by any Borrowe" a"d all other Charges to the Account a, to
which any Borrower agreoos, shall be propercherge~ to the Account
Sorrower may oblain loaM on the Account in the following ways,
SPECIAL CHECKS. Borrower may obtain loans by writing nne of the Prime Lin~ 01 Croodit
change as desctibed beiowin the "Variable Rate" section
METHOD OF CALCULATING BALANCE ON WHICH FINANCE CHARGl:: IS COMPUTED.
lander will compute the Finance Charge by using ttJe "aCluai daily balance" "n tbe
Account, To get the actlJal daily I,aiance, the lender takeslhe beginnin g baianceot' the
Account each day and adds any new loans or other charges posted to the Account that
day; then the lender ,ubtracts any payments or credits posted to tl1e Account thil1 day
and, if applicable, any unpaid Finance Cherges, unpaid insurance premiums, unpaid late
chargesMd lInpaldannLJal fe~s, Tl1e roosultisthe "actual daily balance" /or that day
METHOD OF COMPUTING FINANCE CHARGE. lender will compute the Finance Charge
for the Billing Cycle by tllultiplyin{:l the actual daily baiance fo' each day of the Billing
Cycle by the daliy Periodic Rate, The Finance Cha,ge for me Billing Cycle is the sum of
the Finance CI1arges for each of the days in that Billing Cycle
VARIABLE RATE. The Annual PerclIntage Rata al any time will be determined by adding
the "mar'lin," which will nOI change during Ihe term of the Acco()n!, 10 Ihe "inde~" .Jalue,
which will change from time to lime
The Annual Percentage Rate does not inClude costs other than interest. The Annual
Percentage Ram can change on the first day o/eachBilllng Cycle ("Rate Change Dat'l'I,
The m~'gin for the Account is 1. 75% percefllllge points.
The in(je~is the highest Prime Rale publishad in The Wall Street Journal and in elflocl as
01 the 16tl1day of ooach month prior to the Rale Cbange Date
The ANNUAL PERCENTAGE RATE will never exceed ~ % r1uring the term "I the
Accourl!
Any ch8ngeintheAnmlalP~rcentageRatewill ba applicable 10 the then outstanding
balance on the Account and to any ~ubsequent loans or extMsions 01 credit, untilth!'
Annual Percentage Rate changas ag~ln.
Any incl~a~e in thoo Annual percenfage Rate may result in a cPfresponding increase in the
Minimum Monthly Paymem.
lATE CHARGE. Borrower agrees to pay ~ iate cnarRe of 10% 01 the payment amount but
notlooss tllen S20.00, if any paymeot is not made on its due date shown on the montbly
statement. A late charge will be assesse<;! far each late payment, but o~ly once. IluI a
paymenl m~y be considered late because of the appllcatl~n of paVmlInt priorilies 9S
setforth as agreed to belOw. No late charge will be due il the reason the paymenl i!:late
is a continUing rletinquency 01 a prior payment Of because, atter default, the oontire "ut-
standing bal~nce became dUll.
PAVMENTS: During the Draw Period, the Borrower promises 10 pay a Minimum Monthly
Payment whid1 will equal the g,eater of $100.00 or .25% 01 the outstanding principal
halance as of thoo loSl d"y of tha billin!'! cycle as shown on Ihe momhly statement plus the SIgnature ot lJOrrower'-' - - ------;---.-- '/'ge"7r5"-
accrued F,nance Charges voiuntary Group life insurance If elected be greater than llC _-e\.llSAGREEMENf CONTINUES ON THE REVERSE SID!yYOU ACKNOWLEDGE RECEIV
enttre balance on the Account /./ ING A fpMPlETE COPY OF THIS AG~EI;MENT AND 'A'GREE TO BE lEGAllY BOUND
APPUCAT10NOFPAYMENTS Payments made on the Accour1!wlll be applred In Ihel" 7Ji~~~ '-L ' ~~
follOWing order Frnance Charges late charges any fees optional Credotllle Ins",anc' l~n"lt:,()'Bo.'rowr7 // I -;r----.--
el~cted and then to tile prrnclpal baiance Wt.1.1f} f/1/111A'"'-/
CLD 146A i4/9BI Signature of Borrower
from thoo d~te 01 Ihe Agreement
The Draw Phase will end witbout any requiremenl of
the nOliceto the 80r'ower, The Draw Phasamay end earlierlhan that date in ac.:ordance
wilh the "Termination" section of the Agreement. The paymenl 01 the all amounlS d()e on
the Account will be due 15 days from the last day 01 the Draw Phase.
FEES AND CHARGES
CLOSING COSTS. To open and maintain the Account. Borrower must pay certain fees
and charges, The lollowing lees must be paid to other'
De.cription
PropenyReplUt
Appral.a1
Other COIl. D::::curtEntation $99.00
Amounl PlIid In Cash
AmounlFlnancetl
Tilffl E~a",in..tign
Tillulnsuranca
s...wiceFee
Notary Fee
RucordingFee
Attorney'. Fee
S..ti.luctionF....
$25.50
Olherliens
DEFINITIONS: As used in this Agreement: "Annual Percentage Rale" means the cost of
your loans as a yearly ,ale: "Finance Charge" means the dollar amount your loans will
cost VOll; "Periodic Rat~" means the COSI of you, loan aa a daily rate: and "Statement-
ma.."s the monthly statement of the outstanding balance of vow toan~ and OUr chafges
for your lIse of the Accounl
FtNANCE CHARGE. At all limes that this Agr~ement is in effect. inCluding any period af1er
terminaliOn in whiCh there remains an outstanding balance on the Account, the F'irlance
Charge on this Accou"l will be calculated as of the laSlday in the Biillng Cycle, in the
tollowing way.
WHEN FINANCE CHARGE BEGINS. The Finance Charge on each ioan or advance on the
Account will begin t"accrue from the day the loan or advance i,posted to the Accollm.
TheFinanceChargewntinuesuntiltheoulstandingprfncipalbalanceis paid in tuil. There
Is not time du,ing whiCh ctedit is extended witlloul the Borrower incurring a Finance
Cl1arge.
PERIODIC RATE AND ANNUAL PERCENTAGE RATE. The Finance Charge will be
0.028082
compUled at a sta'ting Periodic Rate of._% per day, whichcorres pond. 10 a
starting ANNUAL PERCENTAGE RATE of 10. 2?% per yea.. The rate is subject to
checks,a supply of which will be provided by the lender for that purpose, Theminimurro
advance is 100
ORDER OF WITHDRAWAL. Borrower may obtain loans 011 the Account by usillq the
Order ot Withdrawal. Orders 01 Wilhdrawal are available from Lender as need~d
Borrower agrees nOt to request a loan or obtain an advance on the AccolJnt for on
amollntless than_J..QL___
TELEPHONE OR INTERNET TRANSFER. Borrowoor may obtair1 loans on the Account by
using informatlolltechnology transfer methods to move funds to otller accounts held
with the lender. The minimum advance iS~O~
PERIODIC REVIEW. Borrower specificallv autborize~ Ih~ Leoder, at Lendef', e~p'~nse to
periodically prCIcurecurrent crooditreporlS on BOrrower. Borrowe.r further agrees 10 pro-
vide to lender al lender's rooquest, current copies of Feder~llncome Tax RetlJnls lall
,chedulesl or (l(ber proof of il1cornoo and emplovmenl. BOrrowoor will permit the leoder's
Apprais~rlProperty Evaluator access to tile ProperlY upon 10 noVs notice.
PROPERTY INSURANCE: You must obtain and maimain adeQuate insurance against fir~,
flood alldsuch othoor reasonable risks 10 the premises as werequi reo This insurance pro-
teels yourinteresls and Our interest. in the Pfemises while this Agfeement Is in etfecl
YOU MAY DeTAIN SUCH INSURANCE FROM ANY AGENT, BROKER OR INSURANCE
COMPANY OF YOUR CHOICE which is licensed 10 do business in the state wl,ere thoo
P,emises are located,but we reserve the right to retuse to accept any insurance company
or policy lor reasooablecause, The poliCY must name us as "mortgage~" and provide us
wllh not less than 10days nOlfce 01 any cancellation or reduction in r-overage. Ynumus!
providoo us with evidence of such insurance coverageprolTlptly afler OLJr request. in tile
event 01 an insur~d loss, you agree fO piOmplly advi"e us of rhe loss and file a proof of
loSS with theinsuranCB company. You appoinl LJS your attorney-in-Iact, in vour"ome ']r
in ours, to file e prool of loss il YOll lail or r~luse to do so, ond to endorse ya"r narne to
any check, draft or other in.~trument in payment of an in,ured loss, We wili allow you
and the Own~rs to appiy Ihe insurance proceeds to repair tllOO Premises, but onlv If we
have nOt previouslV declared your Account to be in default, ..nd the r~pai," Br~ none
properly
SECURtTY INTEREST. Borrower is giving the lender a secufitv interest in '~al estfite and
monooy Or property Oil deposit with Ih~ lcnder to secure this Account. Colloteral secur.
ing other obligations 10 the Lender may i1lso securl!this Account.
TAX DEDUCTIBILITY. Borrower ShOlJld consult a 10" adviser regMding the deduGtibilitv
,,/intereSland c!largeS for the Account
TAXES; REPAfRS: You agree to pay all taxoos on the Premises a'1d to maintain th~
Pre,,-ioses in '1ood condition alld repair
OTHER ADVANCES:II you Inil to pu,chese property insurance, or do not pay ta_e,; wilen
they come due,or do not properly maintain the Pr~mls~"wa may,il we choos~ (but with-
out any obllgalion On our p~rtl, advance sums on your b~half lor thoose purposes in order
10 protect our interest in the Pr~mises. Any such advances w~ n1~ke On your behalf will
not e~C(Jse you from your failLJre Ie honor your p'omise~ ann obligations in this
Agreement. The amounts we advance on your behallwill be rharged to vour acCClu"t as
loans
CREDIT INSUFtANCE, CREDIT LIFE INSURANCE IS NOT REQUIRED IN ORDER TO
Df3TAIN AN ACCOUNT. IF PURCHASED. THE COST CAN CHANGE WHENEVER THE
INSURANCE COMPANY CHANGES THE PREMtUM OF OUR GROUP POLICY IF
PURCHASED, YOU MAY CANCEL THIS COVERAGE AT ANY TIME'-. THE MAXIMUM
Cf1EOITlIFE INSURANCE AVAilABLE IS $50,000
Subject to acceptance by Ihoo Insurance com~any named below. Single or Joint
~;~~~n~i~~ ~~;u~~~~~ B~rr~~e~~ 6$~~r~~ or~Qder, IS ~va,labla on your
Joint Credillife In.urance costs. $ n/a per month per $1,000.00 01 ,he
Actual Dally Bala~e mrtstanrhnQ In yourAccounl.. The nrem,um Is payatli~ eacll m0'1111
as part 01 vour MJnlmum Pavmant. Coverage begins when your Account IS opened or,
il late'" whan we receive your signed 'eQuest lorinsumnce,ond ends on the last da\' of
th"blll'ngcyclewhen~ithef1ns,u'ed Borrowarreaches tlm ageol 66 ye.rs, ordl"', 01
coverage IS. cancelled, Except Hl tbe CQU ot canceilaHon bv bnth Insured Borrowoo,",
SingleCredrt lIte Insuranc~wlll then b~ prOVided to the other Borrower
Sinllle Credit Life Insurance costs $, n/a per month per 51,000.00 of the
Average Dally llalance o~IManding 1t1 your Account. The. premium IS payebl~ each
month as pari of your M,nlmum Peymenls. Coverage beg'ns when you' Accounr IS
n~ened or, if later. when woo receive your signed ,equest for Insurance, or when
Joint Cred;t Life losu,anca "nds.sprovided ahove,and ends on tile las 1 <1avcflhe
billing cycle in which Iha Insuted Borrower reaches !hoo age o! 66 ya8r~ or electood
to cancel this cpverag~, if sooner
See the certificate uf inSUfAnca fo,more into,malion ahoutthl, rovera'l"
Insurer: UnlClnfid9lityU/elnsuranceCotrtpany, TtevOSe, PA
If you dnir.. CreditUle Insurance you n"Iuslsign beiow.
Slpiiiliiii'eofHorrowef
~~-
WARRANTIES AND REPRESENTATIONS: Borrower wBrr~nts ~nd ,epreslmt~ theT TERMINATION UPON OEFAULT: The Borrower will be in delault and the Arco\lnt will
tI,e ftHlds IC"llaterall Bre nbtain~rl ~nd will be used in connecTion with l~wlLJI activities, pur. terrninale, elfective upon Lender's Notice Termination to Borrowef, il any of the
SlJ't~. €"d~nvnrs, ",entwes Or busines"es, and Bmrnwer will nn! use Ih,~ runds lollowing occur:
ICollaTe'all 10 violate any lAW thet <'ol,ld ,esull in fmleiture proceeding. being instiTuted.
If Borrowar i~ in default tinder this section during a period when further e~ten,i('nsor
III i~~et~:I~~f~'~~:~o~~;)telJ~reend P~~~~~t~~le~~nae~i~i~i~:~i~,~;'~I:C?i~I~~ ;~~ ~~~~~II:~~~~~i~ ~~~~:d:;~:e;~i~rt~;i~y~~~~i~~~ted, Le"der may nevertheless, lerminate the Accouf1l in
'y in exc~ssof the credit limil" aI the tirne ot the appr~isallslessThat 50% 01 the
"available equity in e~cessof the credit limit" shall be the dlffelenclIbetwellnla) the
IIppraisalvalueir the Mortgaged Property and Ibl the 5Lim of thll credit limit of the
Arr.ollnt,pl\Js lhe r.reditlirT\its 01 ail other aeeollntssectuedby prior mortga.eson
the Mortga!llldProperty, plu. the then outstanding balances 01 aU other prior liens
am! enr.umhfances. III its discretion, Lende, may obtai" appraisalslrom time to
lime at Lender's ~~pen5e, II Lerlder has prohibited extem,ions of cmdit and I or
reduced the crlldit limit and the value 01 the Mortgagea PrOperty subsequently If Borrower Inr any onll of them il the,e is mOre than one) is not Of becomes ill the
".,creases, Borrower may prOVide Lellder w'th a wntten 'equest to remove the Juture an e~ecutlve ot/lcer of Lende, with respect to whom lederallaw reqUl,esthalal1
restriction The request shall bll accompanIed by an appraIsal obtained at cred,t granted by LellderIJy due and payable 011 demand, then, dunng such tllnes as
130rlowlI"s expense tederallaw so reQuires, all Credit granTed under this AccOl.ntshall be due and payable 0'1
dllOlllnd.lfthecreditisdueandpayableandelnand,Lendercanatsuchti,nesrequire
thatthll entiraoutstandingbalancebe paid immediately in onepaymentand,stlbjectlo
applicable law, Borrower will be in delsurt 01 this Agreement if payment is nOT made s.<;
13) Lender re~sonablv believes thet Borrower witl be unable to fulfill the lep<r~me!lt 'equired,
obligatiuns l"lder Ihis Agreement because 01 ~ m!lterial Ghange in Borrcwer's
linanciillcircumstances
CONTlNUEO EFFECTIVENESS: If we hon(l' speCial Accollntchecks Dr other requests fOf
PROfilBITlON OF ADDITIONAL EXTENSIONS OF CREDIT AT THE REOUESr OF ildval1C6S alter your death or declaralion of legal incornnetenc~, but belore we feceive
BORROWER, Bor",w~1 'nay direct 1I1e Lenderto prohibit fllrther ext<;nsiol1s ot cfedit m, aettlar written notice of eithef event, those ~dvances will be vaiid, iegal end binding
:~~':I~~~:~~tonAI~~~cCec~::::lsYh:~r~~,:~rn~:d~~~~':t;~~:1~~~~~op~~h~~il;~~~~~~~~:;~Yr'~i~~~ obligations on you and your estate, heirs and personal representatives
of credit. The prohibition shall become effective as SOon as Lende, carl reasonably act
to SlOpnewlOanslrorn being made. Any Borrowef who joined ill the ,eQuesttoprohibit
lurtherexten~io"snf credit must join in any reQuest TO reactivate tl",crf'ldit line lor such
request to be ~ffective
Borrowp.r .gree. '0 prornptly inform Lp.nder 01 .ny propo.ed proceeding. or ~crual
proceeding wlli~h would oubiect tile fundslCollaterai)ro forleiture to any qovemmental body.
PROHIBITION OF ADDITiONAL EXTENSIONS OF CREDIT AND lOR REOUCTION OF THE
CREDIT LIMIT, II any nl the Gonditionslisted in this section occur, LendermJy t~",-
porerily rlfohibll "tJdilionalextensionsol credit and!or reduc ethecreditlimit. lenderwili
nntofy Bmrowel of lhe reason lor such action within Ihrtle 13) b"sinessday~ 01 the sus-
pension. The suspension is effective when Lender mails rile notice to Borrower.
Stlspl'ndillq th€' Account will 'tol aflect Borrr;lwer's ot>ligalions 10 Lender under this
Ag'€''''",ent, II ~ircunlstancessubseQllemrychange 50 th~t thll cOrldltlon Wllich gave rise
to IhepmhibiTiollno longer exists, lender shall be obfigsledto ag~i"ailowextensio,'sol
nedit rltl the Accounl and I Dr 'estofeThl! credit limit. This obligatiot1shail cornm~nce
riftee" 1151 hlls,nes5days aHar tile Lender receives a wrillen requestl",m Bcrrower,
"ccompaniedby 'eason~bleevidence thatthe condition which g~ve rise to the prohibi-
I'on lto longer "XlstS. No COndItion listed In thi~ sectIon or the fact thet such cllnditton
no ronger e~ists, sh81f extend or in any way affect the termination 01 thll ~.ceoum
according to any other section or provision 01 this Agreement. Any 01 (he following
condiTions will be grounds tor lender to temporarity prohibit addition extellslo nsofcredit
and lor reduce the credit limit:
{21 E3orr"w~f is ill def~ult of any Malerial Obligation listed in thE' Agreement.
Borrower speciricarly aulhorizes Lender, at Lender's e~rense 10 periodiC<llly plOCllre
nrrre"t cl~dit reports on Borrower. Borrower lurthe, ijgreesto provide to Lender, at
i.enilef'ile(1l1est,copil!sDI BOHOWI!r'SmosttecentFedl!rallncome-rax i1etllrnsm other
proof of inCOHleandernploymentsuchasW-2 forms, pay stubs or at Lender'sreQul1st
awritlenstatenwntlrom Bot/Ower'seOlployer
YOUR OBLIGATIONS CONTINUE ON TEMPORARY SUSPENSION: Upon lemporar\, sus.
pe"sionOf yourctetlil "vailability,whethetby your or by us, YOU remain obligated to
repay arl "lno"nt owed to "s as provided in this Agreement, including our Finance
ChaffleS and oti,er charges.TI1;smeans you must continue to make at least tha Minimum
PaYlnellts each 'nonth under the terms 01 the Agreement
I11Any Borrower Or Owner has commilled any fraud or made any meteriar miSlepre-
senlaTiOrls in cOl'l1ection with the Account. the ~pplication for the Account, Ihe
Mortgage, or any inlormation provided or representation made during the temT 01
ThaAccount
12)The Borrower Of Owne, faiis to pay the payments or a"y othef amOllnts which ~re
due in conneCTion with the ACCOLlnt as promisad in the Agreement
(3)The Borrower or Owner takes a"y action or lails to lake any action which was
prornisedln the Agreement or in the Mortgage,whir.hadverselyatlp.ctsthe Lender's
security, orany right of the Lender In the security.
14)11 further e~let1sionsol credit on the ACCOUnt are prohibited for a period of item
beC<luseol a circumstarlcelisted below, and subse(1UenllYlhat circumstance no
longer e~ists, the Lender may terminaTe the AccolJnl il Ihe Borrower or Owner h"S
caused or allowed a mortgage or other Hen to be ,eco'deuagainstUw Mortgaged
Property at any time, unless that mortgage or rien is subordinate to the Lend~r's
Mortgage as to past and future advances 01 cfedit 0'1 the Account
151The 80lroweror Owner sells, gives away, transfers, or takes any action 10f lails to
take any action) whiCh causes Or allows co"veyanceof the MortgagedPropefty, or
8nypart!hereoforintefestthereil1
ACCELERATION OF THE OUTSTANDING BALANCE. Uniess prohibited by law, il Ihe
Account is te,minated upon defaulL Lender may, at its option, aher notice requir8d by
law, dedare due and payable the entire balance owing the Account. If thiS happens,
Borrower will be reQuiredtn pay the olltstandingbalanceontlle Accountin one payment
at that t'me.
If Borrower is In delault under the section above titled "Terminalion Upor, Oefaull"
during the Repayment phase or durinqa time when the Account is alreadYlerminated,
Lender may, after notice reQuired by law, declare due and payeblethe entire balance
owing on The Account.
II lendllf declares the enti,e balance due and p~yable, Lendef can bring suit for thi"
amounts due, foreclos<!the Mortgage Dr take olher ~ction as permitted or providsd by
lawlo collect the barance owing.
GOVERNING LAW, Terms checked is applicable.
[ZJ
1/ the Mortgaged Property i~ located within the COMMONWEALTH Of
PENNSYLVANiA, Ihen This egreemllnT shail be govPrned by the laws of thB
Cornmonwealthof Pennsylvania,exceplto the exlent that such laws have
heen preempted Or supersedad by F..deral Law
o
II the Mortgaged P,operty is loceted within the STATE OF MARYL.AND,
then this agreement shall IJe governed by the laws of the Stale 01 Mar \'Iand,
except to the extent that such laws have been preempted or sLJpersed edby
Federal Law. If the Agreement Is governed by the IflWs 01 Ihe Stete of
Maryland, then the Ll!nderelects to l1ave this Agreementgovernedby Titl~
12 01 the Commercial Law A,ticle of the Anl10teted Code of Maryland,
Subtitle 9 Credit Gralltors Ope". End Provisions.
Rein~tetemllnt'So long asthe Draw Period has not expired, you may reQtJestre.inslate-
men! 01 tile credit privilp.geson your AecO\lntat any time <liter the conditiof'that
permitted liS to rernporarilYfeduce your Cfedll limiT or suspendyonr Ability to cbtain
loans ceflses 10 e~ist, II you reQuest r",instatement you Inay be required to pay any
re~sonabieappraisalandcreditr",portfeeSwlI aclltaily incur i" investigating wl1eth!lr the
GO"dltinn permitting th" freera continues '.0 exist. We will rein5tate credit privileges em Ihi""Of",e Co"M;", linrlG".'" i,'/o,m"iM .~o'" I'OW fiqi"'.M O"f1~'Mrt,;o"i""s un~" 'io. fa;' C,.dir 8'""'9 ,w,
YOllr Accotmt for th~ rernalnlllg portro,1 ot Draw Perrod when we Ilnd that I.ho~e
condilions have ceased to exist, If arlY one 01 you or <,my Owner of the Premises Notify Us In Castl ot Error or Questions About Your Bill
lequestsa temporary freeze ot the ACCOUnT, we wiil reinstate your Acco\!ntfo' the
remAininltlJorlio" 01 the Draw Period if all 01 you ad.vise l1S in writing of II desi,e to II you think your bill is wrong, or if you "eed mOre informetion about a Transaction on
IFlnst,"e your AC~OI)'H: However, we may reluseto fe",state your Account''"tll we are your bill, write us on a separete sheet at the addre~sli5led on vour bill. Wrtle to liS a'i
aSSLJledthatotHrlQhtsln flnyseCurltyloryouraccounthavenotheenadverselyaffllcted~oonas possible_ We must hear from you no laterlhan60 daysafler we sent you thf!
hy t,,~ temporary Iree'e. We w,11 not extend the OrawPerlod hecl!ilse your loa" pnvlleges first bifl on Which the error Or problem appeamd_ YOlT Can telephone us, but doing so Will
ll1"y Ilave lemporarrly been froz"". not preserv~ your rights
YOUR BILLING RIGHTS. KEEP THIS NOTICE FOR FUTURE USE
PROHIBITION OF ADDITIONAL EXTENSIONS OF CREDITS - ADDITIONAL CIRCUM, In YOllr letter give the following information.
STANCES, rf ~"y of the conditions fisted irl this seclion occur, Lendefmay t"mpotflliiy
!"'lhibit addit;,)!1alext~(1_<;ionsol rredit and I or reduce the credit limit. Lendefwill give
Rorrow..r "otic~ of the prohibition. If circulTIstances stlbsl:'Quently change so thaI tile
'.onditi'll\notiingerp.xists,lendershallb!lobiigatedtO<lQ9In afiowextensionsol credit
on Th~ Acc..,,,,,r ~tld wiil give Borrower nollce thai the crediT is again available.
ItlTtle Lender is p,ed",!ed by !Jovernment action lro'n imposing th~ An"uar
Pl!n~ent"\le Rale providerJ tor in the Agreement.
12lTlll'p,io,ityol Illeletlder'ssecurltylntef6stisadvelselyalfectedbygovernnlent
"r.tiun t(1 (1\1'. ~xt~nt tllat the v8lu~ (It The securitv intelanis less I.h~n 120 lie'cento/
ti1ec,edirllmir
{3lThe Len<Jeris notified by its requlatory agency that contlnuedadV8nCesConstitut,~an
un,afeflndu"soundjJractlce.
141Tlre maximum An"ual Perce"tII\<e Rate is reached,
. Your name and accOtJnt ournbef
. Till! rJollar amollrll 01 !he suspected error
. Oescribe the eHorand explain, it you car:, why you beiieve (hRre 15 all enor, "
you need rnore informatiOll describe the Item you arR Ilot Sure about
II you I,ave authorized us to pay your biil aUTomaticallylrom yotlr savirlQsor ch~cking
accourll,youcan stopHle payment 011 anv,amountyolJ think is wro"g._To stop the
pAyment your letterlt,ust reach us three busmessdaYs belorethe a uwmatlcpayment's
scheduled to OCCUL
Your Right!! and Our Re9pllnsibilitie$ After We receiv/l Your Written Notice
i;;:r;~~ft~~I~~~Or%I;~,g~~o~'lrul:/~;h~;t~~;r~~t ~~~s~;~~lre~~ :xepr~~I~:,~,o:'~~t~~i1:~ee;;,o: ~~
Creditor"s Option Oil Default, It any circumstance exists which wouid be cause for was correct.
l.enderto temporarilyprohibitl\Jrthere~le(lsionsof credit on the Accoum flndlor reduce
thecreditll",iT' Alter we receive your felter, we cannot try to collect any amount you question:orleport
YOlt AS delinquent, We c""contlnueto bill you lor the amounT you que5tw~"ncludlng
I,,) Sud, "ction m"y be tAken by Lender al any lime during whi<:h the r.ifcumslan,;e linance ~harges, and we can apply any unpaid ar:nount agall1st YOLJ~ check limit You do
~ontin"es rO'"ist; not have to pay any questIoned amount whlie we are InvestIgating, hut are still
lill A"d tile cirr,LI'nSlanc~ would elso be en"se fOf the Lende' to terminate Ille ACCOUfll. obllg;<tod to P~l' the parts 01 your bill that ~re not in question
II we find that we made a rnistekeon your biil, you wiU noT have to pay flny ti"ance
lender mAY, at ils oplion take eiTller action al the time durl"g which li'e circumstance chargesrelaled to any Questionedamount.lf we didn't meke a 'nistake,you may h1'lveto
continues to exi,!: Lemter's remedies st1all be cumulative and not alfernalive. pay linance charges, and you will have to make up arty miss~rt p~ymenls orr rrle ques-
tioned amollnt. In either r.~se, we will send yOU a statement of the amount you owe "nd
POSSIBLE ACTIONS WHICH MAY BE TAI<EN BY lENOER. Under Ihe circumstan,;es tile date rhar is dlle
rlesc,ib~dbelow, I.e"dercan III re'minale fhe line of credit; 12) leqLlir~ Borrower to pay II you rail ro p"v tI,e amount that we think you owe, we may ..eporl you as delinquent.
ti,e enwe outstand"'qhalance on the Account:'''. <Jne payment; 13) ref Lise to.,:,ake addi- However, il our explanalion does not satisly you and you write to u~ within ten days
~:~~~a,~;e~~~~Sj'~;:~O~e~~~'t: (41 reduce the credlll1ll1Ot, and lor j51 makll spec'frcchan(;es terlinq us lI'at you still r.elu~e 10 paV,we must teft anyone we feport you !O that you have
~ questfon about YOIJ' bIlL We must tell anyone we report you to that the melle, h~s been
settled betweenu, when it finally is
TERMINATION. If tile Accountis lelminilled, Borrower shall no lonqer Ileve the rigln to
obt~in r(1ans from, tlf makp. any "Ilarges 1.0 the Account aud Lender shall no longer ~e
obii\lallld to make advances On the Account
II we dun'l follow these rules, we ca"'t collect the fi,st $50oi thequestionedamoot)r,
evenil yOUf bill was correct.
Date
Novemhf'r 11. 1998
Account No. 0407002761
A SEPARATE DISCLOSURE STATEMENT, PART ONE AND PART TWO, HAS BEEN GIVEN TO BORROWER WITH AND IS PART OF THIS AGREEMENT, THE OISCLOSURE
STATEMENT, PART ONE AND PART TWO, AND THIS AGREEMENT SHOULD BE READ TOGETHER AS ONE DOCUMENT . ,
_ Authorized Credit Limit $
ht;nnn nn
As used in this Agreement, the following definitions apply:"Borrower" meallS each person ~igning this Agreement as a Borrower, individualiy, and, il more than One
80rrowersogros, all Borrowe", collectIvely.
HARRIS SAVINGS BANK. 2nd and Pine Streets. Harrisburg, Pennsylvania 17105
alld
"Lender" means
anypersoll or institution to whom the Lender assigns its imerest in this Agreement,
"Mortgage Property" means the real estate located at PA 836 ~ lane, Camp Hill, FA 17011
upon which the Owners l1ave given the Lendar a Mortgage to secure paym.,nt a"d performanca 01 Borrower's obligations ullder this Agreement
"Owner" means eacll person sigf1ing the Mortgage upon the Mortgaged Prooerty, if1dividually, and, if more than one Owner signs, all Owners, collectively
Owners may alsO be Borrowers
One or more
"Account" means the "'lIolving loan Account which is the subject of this A.reemem,
"Authorized Credit Limit" means tI1e total dollar amount ot credit available t.) Borrower On the Account, and is stated above.
"Termination" 01 the Account me<lns that Borrower will no I(mger be permitled to obtain loans or advances 01 ~redit on the Account, Termination allects tile Account
permanently
GENERAL DESCRIPTION OF THE ACCOUNT, This A~count is a revolving loan
aCCOUllt, se~urecl by a Mortgage on the Mortgaged Property. Durillg the DraW Phase,
Borrower may obtaif1loarls on the Account in the ways described in the "Advances
of Credit" section, up to the Authorized Credit Limit. L031"1S will be added to the
balance Of1 the Accouf1t to be ,epaid by monthly payments. As the principai on the
Accoull! is repaid during the Draw Phase, the credit will again be made available to iil
Borrower, up to the Authorized Credit Limit. Any baiance remaining on Account at
the end of the Oraw Phase will be repaid within 15 days of the end of the Draw
Ph~se, No lurther loans will be made alter the end of the Draw Phase, The Draw
Phase will begin alter Lender notifies BOrlower that the credit has been approved
and the Borrower's and, if applicable, Owner's right to cancel the Agreement has
expired.
"Billing Cycle" means the interval between the dates each month when the monthly billing statement is prepared,
Igl Borrower will permit, Or cause to be permitted, Inspections of the Mortgaged
Property by agents of Lender, upon r~asonable f10lice
[lli Borrower will ~ot sell. give or transfer oWl1ership ot the Mortgage Property or
any right therein, or permit such sale, ortral1sfe" in whole or H1 part,wrthout
Lender's prior written consent
BorrOwer will not commit lral.'d or make any fllisrepresentations if1 cormectloll
with the Accourll, any personal linancial statement~, appraisals, or oT.hN
information provided to Lender during the term of the Account
IjI Borrower wiil nOt enter into or be placed ill Bankruptcy,
[~I Borrower will provide proof 01 income, certilied copies of fiied tax returns,
and linancial statements 10 lender within 15 days 01 demal1d lherelore.
Interest will be charged on the outstanding principal balanCe at a ratel:hal may
change from tima to time, The method ot calculating the interest is described in the
Disclosure Statement-Part One,
BORROWER'S PROMISE, Borrower promiseS to repay any extel1sions of credit and
proper charges to the Accoul1t, with interest calculated if1 accordance with this
Agreement. Each month during the Draw Phase, sa long as any amount due on the
Accoum remail1s unpaid, Borrower will pay each month at leasl the minimum
payment due within 15 daYs 01 the billing date, Borrower promises to Pay, at the end
of the Draw Phase, all amounts owed on the Account, including principai, unpaid
interest, and other proper charges to the Account in One payment to be made within
15 days ot the last day ot the Draw Phase, Borrower will pay all other fees, costs
and charges required by tbis Agreement, including, if Lender files suit or takes other
legal action 10 collect the amount due On the Account Or to protect any Coilaterai
securil1g the Account. all costs incurred a"d a reasonable attorney's fee of not less
than 15% of the amourll due, Borrower promises to repay lIpon demand arlY
extension of credit on the Account to the extent that the outstsnd irlgprincipal
baiance on the account exceeds the authorized credit limit: payment Linder this
sentence will be due in addition to the minimum payment dU(l on the Account_ II the
Lender temporariiy prohibits further extensions of credit, Borrower promises 10
continue to make the minimum payments due on the Account. unaflected by the
temporaryprohibilion
!II These are promises 80rrowermakes on the Account
FEES AND CHARGES
CLOSING COSTS: In order to opel1 and m~intain the Account, Borrower must pay
certain fees and charges which are itemized in tile Oisclosure StatemenT-Part One
ADVANCES OF CREDIT. Each Borrower aqrees that anyone or more 80rrowers
may obtain loans on the Account wlthollt the COil sent or signature 01 any Jther
Borrower, for any purpose. All loans obtained by any Borrower, al1d all ~ther
charges to the Account as TO which any Borrower agrees, shall be proper charges
to the Account,
Borrower may obtain loans on the Account in the ways described in the
Disclosure Statement.Part One
Lender is not respof1Sible if, for any reaSOn, anyone fails (l( lefuses 10 horlor th~
Special Checks, oril any other device Lender provides to Borrower to nbtain loans
on the Accounl or if any automated teller machine IiI appiicablel laiis to opera1l1
or operates improperly al the time Borrower attempts to obtain a loan. Anv,:laim
that Borrower has against a third party mllst be resolved directly with thM party.
PREPAYMENT, Borrower may prepay the outstanding balance On the Aceoll"!. in
whole Or in part, without penalty
A payment on the Account in any Billing Cvcie of an amount grl'ale' than the
MATERIAL OBLIGATIONS minimum monthly payment due, but less than the entire outstanding balance, WIll
be considered a partial payment.
I"i ~~;~~~:; ~il~~~r~~he~'~~;i~gc~~:1 ~r~~~~~~,onIY for personal, family and household ~C~~~t~l~~ b~~P~YI~~~~ :C;~tg~n:Pg,I~e~i~~~~~u~:o~~~I/~~~t,~~~itn~u~ai~~Cfolf~~:~~
month af1d will not change the way it is computed.
Ibl Borrower will make ail payments on the Account when due, and wiil ll1ake the
payments at the place and in the manner set forth on the billing statement. LENDER'S OBLIGATION TO EXTEND CREDIT, Lender agrees to'
iel Borrower will payor Cause to be paid all ta~es and assessments lincluding
condominium or similar assessments, il applicabiel which may obtain priority over
the Mortgage, when and as they become due
[dl Borrower will cause the improvements existing on the Mortgaged Property to be
il1swed against loss by fire, other hazards and cesualties and,i I applicable, flood
namage, with an insurance company acceptable to Lender. All policies shaUbe if1
a form acceptable to Lender and shall. name Lender a "Ios~-payee" or"addltionai
loss-payee", as appropriate, and provrdll that Lender be grven not lass than 10
days written notice prior to cancellation or rllduction 01 coverage, The insurance
shall il1surethe Mortgaged Property ,in amounts reasonablY,determined bvLender
10 be necessary to protect Lend9r'smterest,lf Borrowel falls orr9fuS9s to obtarn
the required insurance, Lender may purchase required Insurance On Borrower'S
behalf and the COSt wlil be added to the principal balan~e 01 the Account
It I during the Draw Phase, extend credit on the Accol1f1t in reSflonseto any
proper request lor credit Inade by Borrower: and
121 atterthe DraW Phase, and before the linal payment is due, extend cre(iit On
the Account in response to any proper request for credit made by Borrower il
lhe proper request was initiated and dated during the Draw Phase
A request lor credit Shall not be considered a proper request if
i1] it would cause theoutstaf1ding balance on the ACCOllflt to exceed the
Authorized creditiimit; or
121 itisreceived tty the Lel1der, illitiated ordateu uurlng a time when \heAccOun\
Is terminated in accordance with the "Termination" sllr:tion 01 this AQreement:
"
[31 it is received by the Lender, initiated or dated during a time wt1enfurrher
extensions 01 credit are prohibited IJnderthe "Prohibition of Additiol1al
Extensions of Credit" section of the Disclosure Statement - Part Two: or
itis not made in accordance wilh the "Advances of Credit" section 01 this
Agreement
111 Borrower will keep, or cause to be kept, the Mortgaged Property in gorld ordel In the event of Bortowers death _or legal incapacity, a request for credit ~v
and repair. shali not permit waste or deterioretion of the Mortgaged Properly and Borrower wlil be a proper ~equest If the loa" 'S made and P?sted 10 Borrower s
shail "ot use or allow tile Mortgaged Property to be used lor any megal purpose. Account ttelore lender receIves written nouce of the death or Illcapaclty,
If lhe Mortgaged Property is a condominium or part, 01 a, planned unit OTHER PROPER CHARGES TO THE ACCOUNT. Lender may, at its optiof1, ey.tend
development. Borrower shall comply, or caused to be complred, WIth all. by-laws, credit on l.he Account in response to any other request lor credit made bv
regulations or restrict,ons 01 record, Borrower M any time, Such extensions 01 emdlt sh~1I also be considered proper
charges to tile Account
lei Borrower will payor perform ail obligations ul1der any mortgage or security
:~~~~~~nt~i~~C~;un~,Orlgage Property which has priority over tM Mortgage i41
THE ADDITIONAL TERMS ON THE REVERSE Sf DE ARE PART OF THIS AGREEMENT
ACKNOWLEDGMENT OF RECEIPT. Each person signif1g this Agreement acknowledges receipt 01 ~ completed copy 01 this Agreement.
Borrower's Name RIamRD OORIXJN' Borrower's Name PATRICIA QJRI::C:X'\J
836 MEAlXW IN 836 MEAlXW IN
CAMP HILL, PA 17011 and AddresS CAMP HIIL, PA 17011
and Address
Borrower's Name
Borrower's Name
and Address and Address
INTENT TO BE LEGALLY BOUND. Each Borrower signing this Agreementntends to be legally bound by its terms, if1c[uding the/ 'rms stated 1f1 the Dlsciosllr8
Statement. Lender, by approving thil credit end establishing the Account, ha~ evldeng~jtsjlJle.nt to he legally bound by the terms of Agreement, . A
'8o,,&tju~r/l1ffiIJl^J . j~ C;:z~~~~5 ~::0'i 91
Each oWner SIgning this Agreement who IS not a Borrower, and does not have We right to obtain loans on the Accoun,t. I~ "weel,ng ,o~IY to be legally' bO~"d bY tile _lellns
of lha Agreement a"d the Clisclosure Statement relatif1g to the Mortgage and to the Mortgage Property; the Owner s liability rs Ilmrted to the Owner s Interest 'n the
Mortgaged Property,
Owner
Date
NOTICE:SEE Of HER SIDE FOR IMPORTANT INFORMATION
Owner
Date
AMENDMENT5 OF niE TERMS OF THE ACCOUNT. Lender may amend Ihe terms 01 FIIlI" for a Sum less Ihan the balance due On tlls ACCOUllt, Lender may aces",t the
the ACWlmt by prior nntice to Borrower under the follnwiniJ circurnstal'lces: check il'l partial payment of. the bal~nce due on the Account, am! Ilot be bound by
111 If t~,,, inrlt>~ on which changes ,in Ihe Annual Perr.enrage Rate are base,d no :~eh:I~~~~~~~:no~~I~'~ ~~i:~~~'d~,::,~~rt~~IIAnC~ro~~td~~~~~et;ti:~~v:U;~'~I~~C':s n(lhTS
loniJer IS publtshed or is utherwlse una variable, Lender may change the Index
and ITm'gin ']sed. . Lend~r, will choose a new, index that has an historicill DELAY IN ENFORCEMENT. lender can delay enlorci"g any 01 its rlgllls.under Th,s
Illnvement subslanllally SImilar to tllat of Ihe orrglnal Index, and Ihe new margin Agreement without losing them, Any waiver by lender of any prOVISIon 0/ Ihls
will l)" chos"n so that ti,e new, margin ~nd il'ldex would result in an Annual Agreemenl will not be a waiver 01 the same Or any otller provision on any other
Percentage Rate substantially similar to the rate In eff!lct at the time the original occasion,
ind",xhecomesunavailabie
CHANGE OF ADDRESS AND NOTICES. Borrower agrees to notrly Lender
inlmediately in writing 0/ any change in Borrower's address, All nOlices and
monthly statam9J1IS wHl be delivered to Bo""wer at Borrower's last address
appearing in Lender's records. Notices sent to that address will be eltective tor ali
purposes under this Agreemenl, II Borrower sends a notice or lener to lender, it
m"st be sent to lender at the address appearing Ol'l the most recent billing
slatement.
12) Lender may make an insignilir.ant change in the terms of th.. Accoullt it
pe..I11itted by leclr;>ral law
t31 lef1der rn~y make a r.hanl16 in the te'mS of the Account whidl will benefit
Borrower.
Any othM amendmerll ollhe termS of the Accoul1t must he contained in a written
agreement between Len,Jer and BOrTower,
Borrower waives any presentml'nt. demand, protest, rlotice nf protest and dishonor
STATEMENTS, lender will mail to Borrowe, a periodic statement of the Accoont at and any other notice to which Borrower may be entitled and may, by law, be
the end of each Billing Cycte, unless such a statement is nOI required by 111W, The waived,
statement wiU, show the, activity in the Account during the Billing Cycle. Unless JOINT AND SEVERAL OBLIGATION. Each Borrower who signs this Agr~~m~nt, and
Borrower notIfies Lender In wfltrng 01 errors '" the Statement WIthin 60 d,IYs !rom the heirs and pe,sonal representatives 01 each, will be equally responsible,
the ,jate It IS mailed. the statement shall be cons,dered co"ec~ and accf,pted ~y individually and together, for payment 0/ the totel amount owed
Bo,rower. If there IS more thall one Borrower, each ag'ees that ,I the stat'lment rS
serll to a"d accepted by any BOrrower. it shall be considered correct as 10 and ASSIGNMENTS. Borrower 'nay not assign or otherwise transfef Borrower's ri(lfllS
acce(Jted by ~II Borrowers. and privileges under this Agreement.
SECURITY. To secure the payment of sums due on lhis AccoLlnt, Borrower andlor lender may assign allY and ail of ia rights and obligations under this Agreement
Owner have exer.uted a Morlgage in Lender'S favor dated Ihe same dare as this and Ihe Morlgage at any time without Borrower's consent. The personlsl to wllor11
Aqrsement. Lender hereby waives Igives up) its security inlerest in the Mortgaged lenrter assigns this Ag,eement and MOrTgage si,all be entitl~d to all 01 lender's
PrOperTy as to ~ny extension of credit to the exte"t that it would cause the rights and be subject to all lender's obligations under this Agreement ~I'ld the
(\UISlanding Ilalanr.e 10 exceed tile Authorized Credit limit. Borrower also grants Mortgage, None of Borrower's riRhts shall be altected by such assignment
Lender ~ sec(rrity intereST in
SPECIAL CHECKS.
OWNERSHIP OF CHECKS, The Special Checks are at all times lender's property.
12) All creclit inSUllmce proceeds alld relt."n insurance pfBmiuf115 which any ~er;;~,~~e~ra3~~~s t~~m:~~~;~rl a~lf ~~i~s~~res~~~~atl b~h:ft~~r t~arli~nd~h~~O;~eL~~~~~~~
Borrower eler.IS to obtail'l. Checks have been paid by Lender, Lender has no obligation to ratum them to
131 Afl proceeds (\f il1surance whiCh Lender requires Borrower to obtain On the BOllowe..
Mortgaged Property in accordance with Ihe Mortgage ;U1dlor Ihis Agreement. PROHIBITION OF PAYMENT WITH SPECIAL CHECKS. Borfower agrees nOt to make
payment to Lender on this Account with a Special Check lumished by Lender
Coll~teral securir19 o(!1er obligatiol1s to Lender may ~iso sscure the paymen.: of this under this Agreemenl
Account
111 Any ot Anrrower's properly wllich is in Lend8r's possessioll ~t any time
POSTDATEO STALE DATED, CERTIFIED, AND STOP PAYMENT OF CHECKS
TERMINATION, If this Ac<:o\Jnt is tettTlil1ated, Borrower shait 110 longe' have the fight Procedufes, laws. and fees applicable to comparabie transactions On 'e!lui~r
to obtain loans /rorn m make any charges to the Account and Lender shall rl.~ longer checking accounts shall apply to Special Checks Linder ti,is Agreement with
he (\hllQated to m~ke advances On the Account. It lender, al lIS opllon, chooses to respect to llostdated checks. stale dated checks, and cemfYlnp checks ann ~Ioll
make ("nller ~c1vances on Ihe Account. slJch advances shall be propP.r charges to paym!!nt or<lers. Borrower agr~es not to issue postdated Speciai Checks. Certifl"d
the Ar;count 1m wlll~h Borrower shall be hable to repay. If the AC:-OLJnt is termrnated, Special C!recks will b.. posted to the Account on the day the Spec'al Ch~ck IS
unless Lel1dmexerclse:; Its "\lht to requrre the balance to ile paid sooner, Borrower ce,lifled
prorni,cs to "nl'lt,nue t? make the inini11lum payment due ~ach month find t.o make SEVER~BLlLlTY. fl it is delermined lor any reaSOrl Il1at a p~It ot this Agreemenl is
the Irnal payrnlln\ WithIn 15 days 01 the date when the Oraw Phase was otherWIse il1valid 01 unenforceable, this shall 1101 allect th!! validity or eMorcement 0/ ~ny
~Lheduled to end oth!!r provision 01 Ihis Ag'~em"nt. This Agreement wilt the" read as II the invalid
COLLECTION COST: Borrr>wer agrees to pay all court costs and fees, as well as or unenforceallle part ware "Ot there.
'eason~ble. atlom",y 5 fees, as permitted by I~w, Incurred In connection I'\;~th any ENTIRE AGREEMENT, This Agreement. the Disclosure St~tell1el'lt, allY Rider
actlOl1 mstotu!t!!d to collect on tillS account or to prole';t any collateral secu Ing the hereto. Ihe Mortgage, ~nd the Application Form related to tl1;s loan contain the
nccour)t. entire agreament between Lender and 80rrower. ThiS Ag'eerne~)t supers,edes all
PAYMENT MARKED "PAYMENT IN FULL:' Borrower agrf.les nOI to subnit any previOUS agreements. oral or Written, belweel'l the parlles relatrng to thr~ Home
cher.ks to Lender in payment of Borrower's ACCOUnl marked "Payment in Full'" Equity Line 01 Credit
u"less lh€ amour1T ollhe check is at least equal to !helotal baianceth(Oll1 owing on
Borrower'S Accollnt. If 80rrower does submit a ched to Lender marked "Pavment in
GOVERNING LAW, Terms InllowinQ"D op"ly wl'''f1 ch"c~ed
W If the Mmtgoqe,l ProQerty i. I(jC"("~ ",i(l,i" (I'" Cornmo"worllth of Ponn.yl~onio, II,~" Ihl< ''l'ftament "Mil be governed bv the low. of lhe
(umrn""",eairh "I Pen".ylvel1i', oxceot In ",. extanT 'haT s"ch I""" 110vft be"" rreempt!!d (jr supsrseded Iw Federal Law
o 11111" MnrtqoQed Property i, I"c",ed witilin tl1~ Smt& of Maryt&nd. r.hen Ihi~ fO!Ireemem .hllltbe IJOve,nlld by the law, of th, Ste!eot Mltfylend,
excftrl 10 (he e~!e!lltha! .uch taw. hrw8 been preertlfltad 0( ."""r.1Id1ld by Feder'" L"w. U lht. AgrfMlmanl Is governed by tho 18W. of Ihe
SIBle of M"'yl_, l~"" llle La"der et""l. '0 hevo lhl. Ag'8ef1l",,1 tlOVernud by Ti.lo 12 of I~e Commercilll Law Arttcte 01 !he Annot81ed Cooo
01 Morvlond.
~S"lJtitl"9,CreditGranTo"Opef1.fl1drrOYiSiQ"S
o Sllblill~ IO,Cr~ditGrantn"CloSI'd Enrlrrovisions
fy..../tt ~ t f3
VI Way~qi!lKt
April 28. 2004
ACT 91 & ACT 6 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an ofticialnotice that the mortgage on vonr home is in default. and the lender intends
to foreclose. Specific information about the natnre of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSIST.<Ll\TCE PROGR~ i'HEMAP) mav be able to help to
save vonr home. This uotice explains how the program works.
To see if HEMAl' can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING
AGENCY VI'ITHIN 30 DAYS OF THE DATE OF TillS NOTICE. Take this Notice with von when
vou meet with the Counseling Agencv.
The name. address and phone number of Consumer Credit Counseling Agencies
serYing vour County are listed at the end of this Notice. If vOU have anv Questions. vou may
call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with
impaired 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, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASk SI NO COMPRENDE EL CONTENIDO
DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO
ESTA AGENClA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL
PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A
REDIMlR SU HIPOTECA.
PO, Box 1711. HARRISBURG, PENNSYLVANIA 17105-/711
__~._,__..~~::,,:::-,,:_:.:...l .....-.- \",."....~,.,.... If oc.c. o.::JC_7CAc:.\. )"IVnol/ l:J.or::.t:J. 717/~1t:;;_A.t:;;nn . \N\NWw~u1)ointh;::anlr r.........
HOMEOWNER'S NAME (8): _Richard.l Gordon
l'IWPERTY ADDRESS:
_836 Meadow Lane. Camp Hill, PA 17011
MAILING ADDRESS:
_836 Meadow Lane, Camp Hill, PA 17011
LOAN ACCT. NO.:
0407002761
OR1GINAL LENDER:
_ VVaypoint Bank_
CUR1{ENT LEl'mER/SERVlCER: Wavpo!nt Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINA,NClU ASSISTANCE WHICH C<lu1\i SAVE YOUR HOME
FROM FORECLOSURE AND HELl' YOU MAla: FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELlGlllLE FOR
ElVIERGENCY MORTGAGE ASSIST.<lu"l"CE
. IJ1 YOUR DEFAULT IL<\S BEEN CAUSED BY CIRCUMSTANCES BEY01'iD YOUR
CONTROL,
. IJ1 YOU IL4..VE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
. IJ1 YOU MEET OTHER ELIGlllILITY REQUIREMENTS ESTABLISHED BY THE
TEMPOR4..RY STAY OF FORECLOSURE---Under the Act you are entitled to a temporary
stay of foreclosme on your mongage for thirty (30) days from the date ofthis Notice, During that time you
must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed
at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE N'EXT THIRTY (30)
DAYS. IF YOU DO NOT A1'PL Y FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST
BRlNG YOli'R MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES---If you meet with one of the consumer
credit counseling agencies 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 aQencies for the county in which the property is located aTe set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lendeT immediatelv of
your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default tor the
reasons set forth later in this Notice (see following pages for specific information about the nature of your
default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply
for fmancial 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
___..'~_~.~.M".""""_~_"._,_
appli!,;aLlon to the Penns)l]-n.!l1ia I-lousing Fmance Agency. '\{ollr application rvrusT be filed or postmarked
withm thmy (3D) days of your face-to-Jace meeting.
YOll MUST FtLE YOUR API'LICATJON PROMPTLY. IF YOU FAIL TO DO SO OR IF
YOV DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH LN TillS LETTER.
FORECLOSURE MAY PROCEED AGAlNST YOUR HOME IMMEDlATELY~1\!D YOliI{
APPLICATION FOR MORTGAGE ASSISTAu"lCE '\\'ILL BE DENIED.
AGENCY ACTION---Available funds for emergency m011gage assistance are very limlted. Thev
,,'i]] be dlsbursed by the Agency under the eligibiEty criteria estabEshed by the Act. The Pem1sy]vania
Housing Fmance Agency has sixty (60) days to make a decision after it receives your application. Dunng
that time. no foreclosure proceedmgs will be pursued against you if you have met the time requirements sel
forth above, You w1l1 be notified directly by ihe Pem1sy]vama Housing Finance Agency of its decision on
your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BA.c"fKRlJPTCY, THE FOLLOWLNG PART OF TillS NOTICE IS FOR INFORl\iATION
PlJRPOSES O]l,'LY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT. (If you have med bankruptcy you can still applv for Emergency Mortgage Assistance.) I
HOW TO CURE Y01J'R MORTGAGE DEFAULT (Bring it UP to date).
NATURE OF THE DEFAVLT---The MORTGAGE debt held by the above lender on your pToperry
located at: _ 836 Meadow Lane, Camp Hill, FA 170 II
IS SERIOUSLY W DEFALJLT because:
A. YOU HA VB NOT M..WE MONTHLY MORTGAGE PA \'"MENTS for the following months
and the fol1owing amounts aTe now past due: _A payment of $91.58 due for July 2003, $458.57
due for August 2003, $496,92 due for September 2003, $465.96 due for October 2003, $476.12
due for November 2003, $476.12 due for December 2003, $455.81 due for Janumy 2004,
$486.28 due for February 2004, $476.12 due for March 2004 then $445.65 due for Apri12004._
B. Other charges: Laie Fees $472,89
TOTAL AMOUNT PAST DUE: $5,752.02
YOU HA VE FAILED TO TAKE THE FOLLOWING ACTlON:
HOW TO CURE THE DEFAllLT---You may cure ihe default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$5,752.02 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURlNG THE THIRTY (30) DAY PERlOD. Pavments must be made either bv cash. cashier's check,
certified check or money order made payable and sent to:
Waypoint Ban1e
449 Eisenhower Blvd.
Harrisburg. P A 17111
IF YOll DO NOT CURE THE DEFAULT---Ifyou do not cure the default within THIRTY (30) DAYS
ofthe date of this Notice, the lender intends to exercise its rie;hts to accelerate the morte;ae;e debt. This
means that the entire outstanding balance of this debt will be considered due immediately and you may lose
the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
-~_._._-"--'-"-~"'-_.
made WitJl1l1 THIRTY (30 i DA \~S,' the lender also intends to instruct its atW111eys to start legal actJon 10
foreclose upon your Inort!:~a!!.ed prnpert\'.
IF THE MORTGAGE IS FORECLOSED lII'ON---The mongaged property will be sold by the Shenff
10 pay 01T the mortgage debt. If the lender refers your case to its anonleys, but YOll cure the delinquenc\'
before the lender begms legal proceedings agamst you. you will stll] be required to pay the reasonable
attorney's fecs that \Vere actually incurred, up to $50,00, However if lega] proceedings are started against
you, you wlI1have to pay all reasonable attorney"s fees actually incurrecl by the lender even if they exceed
$50,00, AllY attorney's fees will be added to the amount you owe the lender. which may also include other
reasonable costs, if vou cure the default within the TffiRTY (301 DAY period. vou will not be
required to pav attorney's fees.
OTHER LEN"DER REMEDIES--- The lender may also sue vou personally for the unpaid principal balance
m1d all other sums due under the m0l1gage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE---Ifyou have not cured the default
within the THlRTY DO) DAY period and foreclosure proceedings have begLill, you still have tl1e 11;!ht to
cure the default and prevent the sale at anv time up to one hour before the Sheriffs sale, You mav do so bv
pavin~ the total amount then past due. plus anv late or other char;!es then due, reasonable attornev's fees anci
costs connected with the foreclosure sale and anv other costs connected with the Sheriff s Sale as specified
in "''TltinQ 111' the lender m1d bv 1Jerformm~ any other reqUiTements under the mort;!a;!e, Curing your
default in the manner set forth in this notice will restore yonr 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
Sheriff's Sale of the mortgaged property could be held would be approximately four months from the
date of this Notice. A notice of the acmal date of the Sberiff's Sale will be sent to you before the sale. Of
course, the amount needed to cure the default will increase the longer you walt. V ou may fmd out at any
time exactly what the Tequired payment or action will be by contracting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Wavpoint Bank
Address: 449 Eisenhower Blvd" Harrisburg. P A lllll
Phone Number: (7171 909-2790 or 1-866-929-7646 ext. 2790
Fax Number: (7]7) 909-2780
Contact Person: Taunia Ouercia
EFFECT OF SfIERIFF'S SALE---You should realize that a Sheriffs Sale will end your ownership of the
m0l1gaged 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---Vou _X_mayor _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 alId costs are paid prior to or at the sale and that the other
requiTements of the mortgage are satisfied.
'I'm' 1\1 A Y ALSO HAVE THE RIGHT:
. TO SELL THE PROPERTY TO OBTiJN ]VlCiNEY TO PAY OFF THE MORTGAGE DEBT
OR TO BOPJ{C)W MONEY FROM "",""OTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT
. TO HAVE THIS DEFAULT CURED BY .'IJ'.l,' THIRD PARTY ACTING ON YOlJR
BEHALF.
. TO I'IAVE THE MORTGAGE RESTORED TO THE SAJvIE POSITION AS IF NO
DEFAULT HAD OCCURRED. IF YOU CURE THE DEFAULT, (HO\^-,'EVER. YOU DO
NOT HAVE THIS RlGHT TO CURE YOTJR DEFAULT MORE THAN THREE TIMES IN
A.:NY CALENDAR YE.AR.)
. TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSIJRE
PROCEEDING OR l'\NY OTHER LA WSlJIT INSTITUTED CINDER THE MORTGAGE
DOCUMEl\rrS.
. TO ASSERT A},,' OTHER DEFENSE YOU BELIEVE YOU MA. Y H.'\ VE TO SUCH
ACTION BY THE LEl'.mER.
. TO SEEK PROTECTION lJ1\TIJER THE FEDER.i\l B."u'lK.RUPTCY LAW,
Very truly yours,
Taunia Quereia
Collection Counselor
TQinek
-~"~--<..._.~..._".~"' .
If funds are received and negotiated in less than
the total amount due including legal fees and
costs; "\i\Taypoint Bank reserves the right to
return the funds to you and continue \vith legal
proceedings pending receipt or the total mnount
due.
V1WaYI{qipJ
CUMBERLAND COUNTY
CREDIT COUNSELING AGENCIES
:CCS of West em Pennsylvania, Ine.
000 Linglestown Road
~
r~l..,..;sburg, PA 17102
-888- 511-2227
'}\.-,-X (717) 541-4670
Financial Counseling Services of Franklin
31 Wiest yd Street
Wlaynesboto, PA 17268
('""'1-) '""'6? ~"'8-
,I / .: __-.J...::.., J
Jrban League of I:vferropolitan Harrisburg
oJ. 6th Street
hmsburg, PA 17101
(17) 234-5925
;il.-,-X (717) 234-9459
Adams Coumy HoushJ.g }~uthority
139-143 Carlisle StreeI
Gettysburg, FA 17325
(717) 334-1518
F~~X (717) 334-8326
=oromunity Action Corom of the Capital Region
514 Derrv Street
,
-Iarrisburg, Pa 17104
717) 232-9757
"_AX (717) 234-2227
p.o. Box 1711. HARRISBURG, PENNSYLVANIA 17105-1711
-"--'_._-"""~-'-'-~-'.'--""-"'~-"".
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Y'lWay~qi!lt
April 28, 2004
nle subscriber below of the U. S. Post Office located at 5120 Derry Street. Harrisburg, PA
17111, does hereby certijjJ that an envelope was mailed with postage prepaid by First Class j\1ail
Ji'om the Way point Bank addressed to Richard J Gordon, 836 Meadow Lane, Camp Hill, PA
17011, proper(v deposited U. S. }'lailfor delivery this 28th day of April, 2004.
u. S Post Office
..
By:
~ .'" ~..."
<( "I
l/') ,n,
:J
5120 Deny Street
Harrisburo- PA
""
"\0
P.O. 80x 1711. HARRISBURG. PENNSYLVANIA 17105-1711
Toll FrEE 1-866-WAYPOINT (1-866-929-7646) . IN YORK AREA 717/815-4500 . www.wallPointbank.com
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VI. Waynoint
.. ." .....8 A N K
April 28,2004
ACT 91 & ACT 6 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on vour home is in default. aud the leu del' intends
to foreclose. Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGR<\.M (}lEMAP) mav be able to help to
saye- vonI" home. This notice e:\fJlains hm.y the program ,yorks.
To see if HEMAl' can help. YOU must MEET WITH A CONSUMER CREDIT COl1NSELING
AGENCY WITHIN 30 DAYS OF THE DATE OF TillS NOTICE. Take this Notice with YOU when
vou meet with the Counseling Agencv.
The name. address and phone numher of Consumer Credit Counseling Agencies
serving vour County are listed at the end of this Notice. If YOU have anv Questions. vou mav
call the Pennsylvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with
impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If yon have any questions,
representatives at the Consumer Credit Counseling Agency may be able to
help explain it. Y oumay 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 AD.nJNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO
DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO
ESTA AGENClA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGffiLE 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.
P.O. Box 1711. HARRISBURG. PENNSYLVANIA 17105-1711
__,_.,_,,,_.,=.,._','_,::~,~".~._~ ......,-.- ""A~''''''''''''''''''' {1,OC::C::_Q,::)C~_7~A.r;::;\. IN YnRK AREA 717/815-4500 . www.waypointbank.com
HOMEOWNER'S NAME (S): ~l'atricia A Gordon
PROPERTY ADDRESS:
_836 Mcadow Lane, Camp Hill, l'A 17011
MAILING ADDRESS:
_836 Mcadow Lane, Camp Hill, PA 17011
LOA.N ACCT. NO.:
0407002761
OlliGINAL LENDER:
_ ~!aypOillt Bank_
CURRENT LENDER/SERVICER: Wavpoint Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOlT MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYME"<TS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWl'<'ER'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 PA\'MENTS, AND
. IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
TEMPOR-'\RY STAY OF FORECLOSURE---Under the Act. you are emitled to a temporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you
must arrange and attend a '"face-to-face" meeting with one of the consmner credit counseling agencies listed
at the end of tIns Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30)
DAYS. IF YOU DO NOT A.PPL Y FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST
BRlNG YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT", EX.PLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COIJNSELING AGENCIES---If you meet with one of the consumeT
credit counseling agencies 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 desi!!Dated
consumer credit counseling agencies for tbe countv in which the property is located are set forth at the end
ofthis Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of
your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature of your
default.) If you have !lied and are unable to Tesolve this problem with the lender, you have the right to apply
for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you
must fill out. sign and file a completed Homeowner's Emergency Assistance Program Application with one
ofthe 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 PelIDsylval1la Housmg Fmance Agency. Your applicatlOn MUST be filed or postmarked
vnthm thirty (30) days of your face-to-face meeting.
YOlT MUST FILE YOUR AI'PLICATION PROMPTLY. IF YOlT FAIL TO DO SO OR IF
YOU DO NOT FOLLo\Y THE OTHER TIJVIE PERIODS SET FORTH L"I THIS LETTER
FORECLOSURE MAY PROCEED AGAINST YOUR HOME Ml\1EDIATELY k";"D YOUR
APPLICATION FOR MORTGAGE ASSISTA.NCE WILL BE DENIED.
AGENCY ACTlON---Available funds for emergency mortgage assistance are very limited. They
will be disbursed bv the Agency under the eligibility criteria estabhshed by the Act. The Pennsylvania
- -'
Housing Finance Agency has SlXty (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 uOlified directly by the Pennsylvania Housing Finance Agency of its decislDn On
your anplication.
NOTE: IF YOU ARE Cur~NTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLUWING PART OF THIS NOTICE IS FOR INFOR.M:ATION
PURPOSES OI\'LY ."..."ID SHOULD NOT BE CONSIDERED AS ."..."1 ATTEMPT TO COLLECT
THE DEBT. (If you have frIed bankruptcy you can still apply for Emergency Mortgage Assistance.) I
HOW TO CURE YOD'R MORTGAGE DEFAULT (Bring it np to date).
l\ATURE OF THE DEFAULT ---The MORTGAGE debt held by the above lender on your property
located at: _ 836 Meadow Lane, Camp Hill, PA 17011
IS SERIOUSLY IN DEFAULT because:
A. YOU RA. VE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
- ~
and the following amounts are now past due: _A payment of $91.58 due for July 2003, $458.57
due for August 2003, $496.92 due for September 2003, $465.96 due for October 2003, $476.12
due for November 2003, $476.12 due for December 2003, $455.81 due for January 2004.
$486.28 due for February 2004, $476.12 due for March 2004 then $445.65 due for April 2004.
B. Other charges: Late Fees $472.89
TOTAL AMOUNT PAST DUE: $5,752.02
YOU HAVE FAILED TO TAKE THE FOLLOwmG ACTION:
HOW TO CURE THE DEFAULT---You may cure the default within THJRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$5,752.02 PLUS ANY MORTGAGE PAYMENTS .AND LATE CHARGES WHICH BECOME DUE
DURlNG THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's check.
certified check or money order made pavable and sent to:
WayPoint Bank
449 Eisenhower Blvd.
Harrisburg. PAl 7111
IF YOU DO NOT CURE THE DEFAULT---Ifyou do not cure the default within THIRTY (30) DAYS
ofthe date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This
means that the entire outstanding balance of this debt will be considered due immediately and you may lose
the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THlRTY (30) DAYS. the lender also intends to insn'ucl its attomeys to start kgal action to
foreclose upon vour mortgaged llropert\'.
IF Trill MORTGAGE IS FORECLOSED UPON---Tbe mmigagecl property wll1 be sold by tbe Sheriff
IO pay ofT the 1110ngage debt. If the lender refers your case to its attOll1eys. but you cure the delinquency
before the lender begins legal proceedings against you. you will still be requlred to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However. if legal proceedings are starred 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 vou cure the default within the THIRTY (30) DAY period. vou will not be
required to pav attorney's fees.
OTHER LENDER REMEDIES---The lender may also sue YOl1 personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE---Ifyou have not cured the default
withm the THlRTY (301 DAY period and foreclosure proceedings have begun, vou still have the right to
cure the default and prevent the sale at am' time up to one hour hefore the Sberiff s sale. You may do so by
paving tbe total amount then past due. plus any late or other charges then due. reasonable attomev's fees and
costs connected witb the foreclosure sale and any other costs connected with the Sheriffs Sale as specified
in wntnlg bv the lender and bv perforrninQ: am' other requirements under the mortgage. Curing your
(lefault in the manner set forth in this notice will restore yonr mortgage to the same position as if you
had never defaulted.
EARLIEST POSSffiLE SHERIFF'S SALE DATE.--It lS estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately four months from the
date ofthis Notice. A notice oftbe actual date of the Sheriffs Sale will be sentto you before the sale. Of
course, the amount needed to cure the default will increase the longer you wait. You may fmd out at any
time exactly what the required paymelt or action will be by contractmg the lender.
HOW TO CONTACT THE LEN"DER:
Name of Lender: Wavpoint Bank
Address: 449 Eisenhower Blvd.. Harrisburg. P A 17111
Phone Number: (717) 909-2790 or 1-866-929.7646 ext. 2790
Fax Number: (7171909-2780
Contact Person: Taunia Ouercia
EFFECT OF SHERIFF'S SALE---You should realize that a Sheriffs Sale will end your ownership oftbe
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s
Sale, a lawsmt to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE---You _X_mayor _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 ofthe mortgage are satisfied.
YOI' MAY ALSO HA YE TI-IE mGHT:
. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF TI-IE MORTGAGE DEBT
OR TO BORROW MONEY FROM i\.NOTHER LENDlNG INSTITUTION TO PA 'y' OFF
THIS DEBT
. TO RAVE THIS DEFAULT C1.JRED BY A.NY Tl-IlRD PARTY ACTING ON YOUR
BEH.ALF.
. TO RA.VE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT RAD OCCURRED, IF YOU CURE THE DEFAULT. (HOVveVER YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEF AUL T MORE TRA...'i THREE TIMES IN
.A...1\JY CALENDAR 'YEAR.)
. TO ASSERT THE NONEXISTENCE OF A DEFAULT IN A."ry FORECLOSURE
PROCEEDING OR A.N"Y OTHER LA WSlJIT INSTITCTED UNDER THE MORTGAGE
DOCUMENTS.
. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY RAVE TO SUCH
ACTION BY THE LENDER
. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
,\7 erv nulv vours
...' ~ w ,
Taunia Quercia
CoIlemion Counselor
TQ/nek
"----~-.-......~_.
If funds are received and negotiated in less than
the total amount due including legal fees and
costs; Vvaypoint Bank reserves the right to
return the funds to you and continue \vith legal
proceedings pending receipt of the total alllOunt
due.
--'-~~"-' "---~-.._.._._-_.".
.... Way:noint
.... .@r-B A N K
CUMBERLAND COUNTY
CREDIT COUNSELING AGENCIES
:CCS of\l(Testem Pennsylvania, Ine.
000 Lin~lestown Road
u
:ram.' b cr P ^ 1710'/
..L S urb, ..:.J.. . _ .....
-888-511-2227
;AX' (71-\ ~.i!.1-J.670
...;..L..::. \ I I).J. _ I ,
Financial Counseling Services of Franklin
31 West 3rd Sueet
Waynesboro, PA 17268
(717) 762-3285
]rban League of MetropohIaD Harrisburg
-J. 6th Street
-Iarrisburg, PA 17101
717) 234-5925
:;l0-:: (717) 234-9459
Adams County Housing Amhmity
139-143 Carlisle SUeeI
Gettysburg, PA 17325
(717) 334-1518
FlL.X (717) 334--8326
:::onununity Action Comm of the Capital Region
l514 Derry Street
:..:r.arrisburg, Fa 17104
:717) 232-9757
F.AX (717) 234-2227
P.O. Box 1711. HARRISBURG. PENNSYLVANIA 17105-17/1
T....1l ~r>.cc I_Rc:::.&::_W.dVDnU\.lT (I_Rc:::.&::...q,::::>>q,_7~.d.&::.\ ' IN Vncll' ~ct::.r. 717/J=Ut::._..1..E::::nn . \Afl.""^'\M=>IIf'"..""in+h::.nk- .-....rn
V, Way~qjrtt
April 28, 2004
The subscriber below of the U S. Post Office located at 5120 Deny Street, Han-isburg, PA
17111, does hereby certifjl that an envelope was mailed with postage prepaid by First Class Mail
ji-orn the Waypoint Bank addressed to Patricia A Gordon, 836 Meadow Lane, Camp Hill, PA
17011, properZv deposited U S. Mail for delive1Y this 2811, day of April, 2004.
U S. Post Office
By:
5120 Derry Street
Harrisburg, P A
'\~
P.O. Box 1711, HARRISBURG. PENNSYLVANIA 17105-1711
Toll FrEE 1-866-WAYPOINT (I-B66-929-7646) . IN YORK AREA 717/815-4500 . www.waypointbank.com
~'i~N')~:Mlei.}I~':.I.=-.:a':I"''''''i::(''''.J~'_
. Complete items 1, 2, and 3. Also complete
item 4 jf Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front jf space permits.
1. Article Addressed to:
Ageni
ddn:
. --;ved 9f{ Printed Name) I C,. te of Del
/ Cf ~zr-G
D. Is delivery address different from item 1? 0 Yes
If YES, enter delivery address below: 0 No
fu.-rr'u:"'" if GoKclon
g 3 io /IA N)..d C.0 Lv'LL
CUl1I.f 11-[{ fA nO if
3. ~ic;e Type
.KJ Certified Mail
o Registered
o Insured Mail
4. Restricted Delivery? (Extra Fee)
&is.Trfijf'T
g=~~~~;so.c
~Yes
2. Article Number
(Transfer from service,
PS Form 3811 . February 2004
7004 0550 0001 1666 1237
Domestic Return Receipt
102595-02~M
~11~,!,l;i1.~
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Vi WaYl{qint
April 28. 2004
ACT 91 & ACT 6 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. Specific information about the natnre of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSIST.A.NCE PROGR.4M (REMAP) may be able to help to
save Your home. This notice explains how the program works.
To see if HEMAP can help, vou mnst MEET WITH A CONSUMER CREDIT COllNSELING
AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when
YOU meet with the Connseling Agencv.
The name. address and phone number of Consumer Credit Counseling Agencies
serving YOUr Countv are listed at the end of this Notice. If von have anv Questions. vou mav
call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with
impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If yon 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 IMPORT.A.NCLA., PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO
DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INNEDITAMENTE LLAMANDO
ESTA AGENClA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL
PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A
REDIMIR SU HIPOTECA.
P.O. Box 1711. HARRISBURG. PENNSYLVANIA 17105-1711
. ....-- .. ...---...- /I ~,....- .-...""')~ ~c.... C\ . I.., V.......n'... ^~c:^ "'71"'7 !l:::l'1t::_AE::nn . \^n^n^"^f:::lII'nnin+h:;::tn~ r-nm
HOMEOWNER'S NAME (S): _llichanl J Gordon
PROPERTY ADDRESS:
_836 Meadow Lane, Camp Hill, PA 17011
MAILING ADDRESS:
_660 Boas St Apt 2018, Harrisburg, PA 17102
LO,A.N ACCT. NO.:
0407002761
ORIGIKAL LENDER:
_ W aypoin t Bank _
ClffiRENT LENDER/SERVICER: Waypoint Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
yon !VIA Y BE ELIGIBLE FOR FINANCIAL ASSISTA..NCE WHICH CA.N SAVE YOUR HOME
FROM FORECLOSURE ."..."ID HELP YOU MA.KE FUTURE MORTGAGE PA"\'MEl\TS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOVVNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
E!\fERGENCY MORTGAGE ASSISTANCE
. IF YOU'll DEFAULT HAS BEEN CAUSED BY CIRCUMST.A.NCES BEYOND YOUR
CONTROL,
. IF YOV R4.VE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
. IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
TEMPOR4.RY STAY OF FORECLOSURE--Under the Act, you are entitled to a temporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you
must arrange and attend a "face-to-face" meeting with one ofthe consumer credit counseling agencies listed
at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT TBlRTY (30)
DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST
BRING YOUR MORTGAGE UP TO DATE. THE PART OF TI-JIS NOTICE CALLED "HOW TO CURE
YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES.-If you meet with one of the consumer
credit counseling agencies hsted at the end of this notice, the lender may NOT take action against you for
thlrty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated
consumer credit counselin~ agencies for the county in which the property is located are set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of
your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE---Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature of your
default.) If you have ttied and are unable to resolve this problem with the lender, you have the right to apply
for fmancial 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 deslgnated consumer credit counseling agencies listed at the end ofthis Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in submitting a complete
applrcatlOn lD the Pennsylvania Housmg Fl11ance Agency. Your applrcatlOn IvlUST be filed or postmarked
w1th111 thin:y (30) days ofynur face-to-face 111eeting.
YOU M1JST FILE YOUR APPLICATION PROMPTLY. IF YUC FAIL TO DO SO OR IF
YUV DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER.
FORECLOSURE MAY PROCEED AGALNST YOUR HOME IMMEDIATELY AND YOUR
Al'PLICATION FOR MORTGAGE ASSIST.A.NCE WILL BE DENIED.
AGENCY ACTION---Available funds for emergency mortgage assistance are very limned. They
will be disbursed by the Agency under the eligibility cnteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During
that tnne, 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 Pelmsylvania Housing Finance Agency of its decision on
your application.
NOTE: IF Y01J ARE CllRRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLO\VING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS "A.N ATTEMPT TO COLLECT
THE DEBT. (If you have filed bankrnptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAL'LT (Bring it up to datet
NATh'RE OF THE DEFAULT---The MORTGAGE debt held by the above lender on your property
located at: 836 Meadow Lane, Camp Hill, PA 17011
IS SERlOUSL Y IN DEF AUL T because:
A. YOU RA.VE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due: _A payment of $91.58 due for July 2003, $458.57
due for August 2003, $496.92 due for September 2003, $465.96 due for October 2003, $476.12
due for November 2003, $476.12 due for December 2003, $455.81 due for January 2004,
$486.28 due for February 2004, $476.12 due for March 2004 then $445.65 due for April 2004._
B. Other charges: Late Fees $472.89
TOTAL AMOUNT PAST DUE: $5,752.02
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION:.
HOW TO CURE THE DEFAULT---You may cure the default within 1HIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, VVHICH IS
$5,752.02 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either bv cash. cashier's checl;;,
certified check or money order made payable and sent to:
Wavpoint Bank
449 Eisenhower Blvd.
Harrisburg, PA 17111
IF YOU DO NOT CURE THE DEFAULT---Ifyou do not cure the default witliin THIRTY (30) DAYS
of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This
means that the entire outstanding balance of tliis debt will be considered due il11111ediately 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 wIthm Tl-lllZTY (301 DA'{S, the lender also intends to 1l1S1Tuct its anomeys to starl legal action to
fnrecJosC' upon vour mort!!aged propertv.
IF THE MORTGAGE IS FORECLOSED [TI'ON--.The mortgaged property will be sold by the Sheriff
Lu pay oft the mortgage debL If the lender refers your case to its attOlTleys, but you cure the delinquency
before the lender begms legal proceedings against YOLI. 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
YDLl, YOlI will have to pay all reasonable anorney'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 "on cure the default within the TIDRTY (301 DAY period. "ou will not be
required to pav attorne"'s fees.
OTHER LE.NDER REMEDIES--- The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CLJRE THE DEFAlJLT PRIOR TO SHERIFF'S SALE---Ifyou have not cured the default
within the THIRD' (30) DAY period and foreclosure proceedings have begun. vou still have the ri!!ht to
cure the default and prevent the sale at anv time up to one hour before the Sheriffs sale. You mm' do so bv
J2Q.vin!! the total amount then past due, plus any late or other charges then due. reasonable a(tomev's fees and
costs cOlllJected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified
in writin~ bv the lender and bv Derfonning an" other requirements under the mort!!age. Cnring your
clefault in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSffiLE SHERIFF'S SALE DATE---1t is estimated that the earliest date that such a
Sheriff s Sale of the mortgaged property could be held would be approximately fonr months from the
date ofthis 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 fmd out at any
time exactly what the requITed payment or action will be by contracting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: W'avnoint Bank
Address: 449 Eisenhower Blvd.. Harrisburg, PA 17111
fllOne Number: (717) 909.2790 or 1-866-929.7646 ext. 2790
Fax Nnmber: (717) 909-2780
.!=ontact Person: Taunia Ouercia
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 Sheriff s
Sale, a lawsuit to remove you and your fumish1l1gs and otber belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE--.You _X_mayor _may not (CHECK ONE) sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that alJ tbe outstanding
payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other
requirements afthe mortgage are satisfied.
YOU MAY ALSO HAVE. THE RIGHT:
. TO SELL THE PROPERTY TO OBTAIN MONTY TO PAYOFF THE MORTGAGE DEBT
OR TO BORROW MOl\IEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF
THIS DEBT.
. TO HAVE THIS DEFAULT CURED BY ANY THIRD PiillTY ACTING ON YOUR
BEI-LliF.
. TO I.1A VE THE MORTGAGE RESTORED TO THE Silli1E POSITION AS IF NO
DEFAULT Hiill OCCURRED. IF YOU CURE THE DEFAULT. (HOWEVER. YOU DO
NOT HAVE THIS RIGHT TO CURE YOUR DEF AUL T MORE n-LAN THREE TIMES IN
ANY CALENDAR IT'\.R.)
. TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR AN',," OTRER LAWSU1T INSTITUTED lJ!'\'DER THE MORTGAGE
DOCUMENTS,
. TO ASSERT AN'{ On-IER DEFENSE YOU BELIEVE YOT..; MA.Y Ri\VE TO SUCH
ACTION BY THE LENDER.
. TO SEEK PROTECTION UNDER THE FEDER.li BA.."NKRUPTCY LAW.
Very truly yours,
Taunia Quercia
Col1ection Counselor
TQl11ek
. ~.__._"".."-,-,,- ..__._,._...".~
.
If funds are received and negotiated in less than
the total amount due including legal fees and
costs; \Vaypoint Bank reserves the right to
return the funds to you and continue vv-ith legal
proceedings pending receipt of the total an10unt
due.
------.. ~"----"'--'",.,,,-,.
~.Waynoint
. .@ '18 A N K
CuXBERLAND COUNTY
CREDIT COUNSELING AGENCIES
=CCS ofWTestem Pennsylvania, Inc.
~OOO Linglestown Road
-ranisburg, PA 17102
-888-511-2227
~A x (717\ "i41-467n
--- \ - / - .. -
Financial Counseling Services of Franklin
31 \\7 est 3xO Street
\\Taynesboro, PA 17268
(717) 762-3285
Jrban League of Metropolitan Hanisburg
'\J. 6tD Street
1anisburg, PA 17101
'717) ')o4-~9')~
. ~.J J_J
=iAX (717) 234-9459
Adams C01J..fJ.ty Housing Authority
139-143 Carlisle Street
Gettysburg, PA 17325
(717) 334-1518
FA...X (717) 334-8326
=::ommunity Action Corom of the Capital Region
1514 Derry Street
Hanisburg, Pa 17104
(717) 232-9757
Fl0{ (717) 234-2227
PO. Box 1711, HARRISBURG. PENNSYLVANIA 17105-1711
~~:.:_--.~-- , .....,...,... '''''~,.~-.,~,.... II occ::::. o.':)CL "7'CA t::.\ . I..., Vnov ,6,CJ::i\. 717/RIC:::_Llt::::.nn . \1\T\Al\I\I\Al::::illln,nin+t-':::o.nlr ....nlTl
VlWay~qi!'Kt
April 28, 2004
The subscriber below of the U. S. Post Office located at 5120 Den)' Street, Harrisburg, PA
17111, does hereby certifY that an envelope was mailed with postage prepaid by First Class Mail
from the Way point Bank addressed to Richard J Gordon, 660 Boas St Apt 2018, Harrisburg, PA
17102. properly deposited Us. Mailfor dehvel)' this 28th day of April,2004.
U S. Post Office
By:
----~-"""''''{~"'''', !
<( ;'
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5120 Den)' Street
Harrisburg, PA
~
PO. Box /711. HARRISBURG. PeNNSYlVANIA 17105-1711
Toll Free 1-866-WAVPOINT (/-866-929-7646) , IN YORK AREA 717/815-4500 . www.waypointbank.com
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· Complete items 1, 2, and 3. Also complete A. Signature f A'l
item 4 jf Restricted Delivery is desired. JJ' / It / i, ~gen1
. Print your name and address on the reverse X /1fA~-:Jt1l!"'/IJ,' -. {~rlJ:.-, Xl Addre
so that we can return the card to you. B," Received by (Printed Name) I C. ~a f'
. Attach this card to the back of the mailpiece, ~, ('J _ -7 I, ~.... j .
or on the front if space permits. "-IUU-/'1fi]!) v. IJ;OfGvwv ..:,
D. Is delivery address different from item 1? 0 Y, s
If YES, enter delivery address petow: 0 No
:a I ( N IJ\l;J..s I
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1. Article Addressed to:
;0'chcdJ J. GMJtJ/1
6/;.0 Boas Sf fl1rI c20/8
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Certjfied Mall
egistered
o Insured Mail 0 ~~ IVF-RV
4. Restricted Delivery? ~ F~- 9 Yes
~ ~r.aJaI~g~
2. Article Number
(Transfer from service label) ,
PS Form 3811, February 2004
7004 0550 0001 1666 1220
Domestic Return Receipt
102595-02.M
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r-=I Certified Fee /F \ G.
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C1 (Endorsement Required) 1 7 c J) \ ....::-s Hate:;::O );0
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C1 Total Postage & Fees $ 8 1 f) ~~//
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'ExJlIbefG
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA Harrisburg
InRe:
RICHARD JOSEPH GORDON
PATRICIA ANN GORDON
Debtors
"-'1
\ I
--.--....---.-.
"." 2 3
l'IIMn
iDOl
'.)J~
\
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No. 03-03788
WAYPOINT BANK F/KfA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION AND
HARRIS SAVINGS BANK
Movant
1)3. ;:;;:1:
vs.
RICHARD JOSEPH GORDON
PATRICIA ANN GORDON
Respondents
CHAPTER 13
PROCEEDING
AMENDED 0 R D E R
AND NOW, this a 3 day of manh, 2004, in consideration of the
Motion for Relief from Automatic Stay tiled by Waypoint Bank and of any
response thereto, and after any hearing held thereon and the Court having
determined that cause exists to lift the stay, IT IS HEREBY ORDERED that the
automatic stay in this matter as it applies to Waypoint Bank is hereby lifted to
permit Waypoint Bank to exercise all of its rights under the loan documents and
pursue all state law remedies, including the right to foreclose on the subject
property located at 836 Meadow Lane, Camp Hill, Pennsylvania, 17011, to
otherwise enforce its rights under its Mortgage. Rule 4001(a)(3) of the Federal
Rules of Bankruptcy Procedure does not apply to this Order.
BY THE COURT
Iii MARY D. FR,"J-~CE
BANKRUPTCY JUDGE
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct
to the best of my knowledge, information, and belief. I further verify that I am a Default
Specialist " of Waypoint Bank, and that as such, I am authorized to make this
Verification on its behalf. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities.
WAYPOINT BANK
Dated: (p- 2/- of
'~j;Jw)j)f)))kil!JjuW!c-
Barbara L. Householder
Default Specialist"
!'---'
~ c., c;;,
c- -.
.-,
( :r
- ~ ,
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Go.; '-./
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-02896 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WAYPOINT BANK
VS
GORDON RICHARD J ET AL
ROBERT BITNER
Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
GORDON PATRICIA A
DEFENDANT
was served upon
the
at 836 MEADOW LANE
, at 1730:00 HOURS, on the 28th day of June
, 2004
CAMP HILL, PA 17011
PATRICIA GORDON
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
10.35
.00
10.00
.00
26.35
Sworn and Subscribed to before
me this /S~ day of
C}L ~'1 A.D.
h ---- (2 {'.1.:.u.., AJrJ:'
~otary j TJ \
So Answers:
R. L~~YJ ~
07/07/2004
WAYPOINT BANK
~
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2004-02896 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WAYPOINT BANK
VS
GORDON RICHARD J ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
GORDON RICHARD J
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE
On July
7th , 2004 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Dauphin County
So
.-' .->
18.00
9.00
10.00
30.00
.00
67.00
07/07/2004
WAYPOINT BANK
R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this Ie::- day of ~JlI
il-otJ't . A.D.
~gt~y~'
@ttitt of tltt~ ~4~riff
William T. Tully
Solicitor
J. Daniel Basile
Chief Deputy
Mary Jane Snyder
Real Estate Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255.2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
WAY POINT BANK
vs
County of Dauphin
GORDON RICHARD J
Sheriff's Return
No. 5148-T - -2004
OTHER COUNTY NO. 04-2896-CIVIL
AND NOW:June 29, 2004
at 12:14PM served the within
NOTICE & COMPLAINT
upon
GORDON RICHARD J
by personally handing
to RICHARD GORDON DEFT
1 true attested copy(ies)
of the original
NOTICE & COMPLAINT and making known
to himlher the contents thereof at 2971 N 2ND STREET
HBG, PA 17110-0000
Sworn and subscribed to
before me this 30TH day of JUNE, 2004
So Answers,
Jt~
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. 1, 2006
~,y,~
~A/
Sheriff's Costs:$O.OO PD 00/00/0000
RCPT NO
W SNYDE
In The Court of Common Pleas of Cumberland County, Pennsylvania
Waypoint Bank
VS.
Richard J. Gordon et al
SERVE: Richard J. Gordon
No.
04-2896 civil
Now,
June 24. 2004
, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deput~ze the Sheriff of
Dauphin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
~{?/ /~.
-r ~~~-<' 4 _R---'R
Sberiff of Cumberland County, PA
Affidavit of Service
Now,
,20_, at
o'clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this _ day of ,20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION -- MORTGAGE FORECLOSURE
WAYPOINT BANK, F/K1A
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
vs.
No. 04-2896 (Cumberland Co.)
No. 5148-T-2004 (Dauphin Co.)
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
CERTIFICATE OF SERVICg
I HEREBY CERTIFY that on July 20,2004, a 10-Day Default Notice in the
above-captioned matter was mailed to Defendant, Richard J. Gordon, by regular mail,
postage prepaid. A true and correct copy of the 10-Day Default Notice is attached
hereto and incorporated by reference.
Dated: July 20, 2004
By / "i-
~Ri99, .
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
Phone: (717) 815-4518
1.0. No. 72030
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION -- MORTGAGE FORECL.OSURE
WAYPOINT BANK, F/K1A
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
vs.
No. 04-2896 (Cumberland Co.)
No. 5148..T-2004 (Dauphin Co.)
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
TO: Richard J. Gordon
2971 North Second Street
Harrisburg, Pennsylvania 17110
DATE OF NOTICE: July 20, 2004
NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
WITH THE COURT YOUR DEFENSES OR OBJECTIIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE
OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE 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.
Dated: July 20, 2004
LAWYER REFERRAL SERVICE OF THE
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
By: J '~
~Ri9 .
Attorney for Plaintiff
P.O. Box 17'11
Harrisburg, PA 17105-1711
Phone: (717) 815-4518
I.D. No. 720:30
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION -- MORTGAGE FORECL.OSURE
WAYPOINT BANK, F/K1A
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
vs.
No. 04-2896 (Cumberland Co.)
No. 5148-T-2004 (Dauphin Co.)
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 20,2004, a 10-Day Default Notice in the
above-captioned matter was mailed to Defendant, Patriclia A. Gordon, by regular mail,
postage prepaid. A true and correct copy of the 10-Day Default Notice is attached
hereto and incorporated by reference.
Dated: July 20, 2004
BY~'
Benjamin F. iggs,
Attorney for Plaintiff
P.O. Box 1'711
Harrisburg, PA 17105-1711
Phone: (717) 815-4518
1.0. No. 72030
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION -- MORTGAGE FORECLOSURE
WAYPOINT BANK, F/K/A
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
vs.
No. 04-2896 (Cumberland Co.)
No. 5148-T-2004 (Dauphin Co.)
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
TO: Patricia A. Gordon
836 Meadow Lane
Camp Hill, Pennsylvania 17011
DATE OF NOTICE: July 20,2004
NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
WITH THE COURT YOUR DEFENSES OR OBJECTIIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE
OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE 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.
LAWYER REFERRAL SERVICE OF THE
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 ,
Dated: July 20, 2004 BY:- -. n / All ~
~1i99/~
Attorney for Plaintiff
P.O. Box 17'11
Harrisburg, PA 17105-1711
Phone: (71i') 815-4518
I.D. No. 72030
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KlA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
vs.
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
PRAECIPE TO ENTER JUDGMENT
To the Prothonotary:
ENTER JUDGMENT in the above case for failure to file, or enter, a timely
Answer to Plaintiff's Complaint in Mortgage Foreclosure against Richard J. Gordon and
Patricia A. Gordon in favor of Waypoint Bank, flk/a York Federal Savings and Loan
Association and Harris Savings Bank for the following:
Amount Due Per Complaint. . . . . . . . . .
$ 71,900.09
I nterest from 6/16/04 through 12/8/04
(inclusive) at $10.1585 per diem. . . . . .
$ 1,787.90
Late Charges from 6/16/04 through 12/8/04
(inclusive at $52.15 per month). . . . . . . .
$
92.18
TOTAL AMOUNT $ 73,780.17
with interest from December 9,2004 at such rate or rates established by Plaintiff
pursuant to the terms of the Note currently $10.1585 per diem, from December 9, 2004,
late charges from December 9, 2004 at 5% of the monthly payment amount, currently
$52.15 per month, attorney's fees, costs of suit and other charges collectible under the
Mortgage; and for any and all other relief as the Court deems appropriate.
DATE:
g/""O~
By:
Benjamin F. Iggs, r
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
I.D. No. 72030
rAu,uU :l )' , 2004 Judgment entered by the Prothonotary this day
accordin~ to the tenor of the above statement.
~~ R R~,~
Prothondta1y
--
.
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION -- MORTGAGE FORECLOSURE
J'\ease Time-Stamp
end Return to me.
Thank You.
WAYPOINT BANK, F/K/A
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
vs.
No. 04-2896 (Cumberland Co.)
No. 5148-T-2004 (Dauphin Co.)
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 20, 2004, a 10-Day Default Notice in the _:
above-captioned matter was mailed to Defendant, Richard J. Gordon, by regl.lll:i:f maiP,
postage prepaid. A true and correct copy of the 10-Day Default Notice is attacned ~::
hereto and incorporated by reference. -
Dated: July 20, 2004
By: . ;/ (/J /' ...J
Benja~. ~~7
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
Phone: (717) 815-4518
I.D. No. 72030
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION -- MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KJA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
vs.
No. 04-2896 (Cumberland Co.)
No. 5148-T-2004 (Dauphin Co.)
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
TO: Richard J. Gordon
2971 North Second Street
Harrisburg, Pennsylvania 17110
DATE OF NOTICE: July 20,2004
NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE
OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE 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.
LAWYER REFERRAL SERVICE OF THE
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3J 66
Dated: July 20, 2004 By: -t./}~71.~
Benjaminof'. R~~
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, P A 17105-1711
Phone: (717) 815-4518
1.0. No. 72030
i..::::;::....
..
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KJA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
Please Time.Stamp
and Return to me.
Thank You.
vs.
No. 04-2896 (Cumberland Co.)
No. 5148-T-2004 (Dauphin Co.)
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 20, 2004, a 10-Day Default Notice in the
above-captioned matter was mailed to Defendant, Patricia A. Gordon, by regular mail,
postage prepaid. A true and correct copy of the 10-Day Default Notice is attached
hereto and incorporated by reference.
Dated: July 20, 2004
By: ~dL.lL
Benjamin F. Ri~~iN
Attorney for Plaintiff \
P.O. Box 1711
Harrisburg, PA 17105-1711
Phone: (717) 815-4518
I.D. No. 72030
.
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION -- MORTGAGE FORECLOSURE
WAYPOINT BANK, F/K/A
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
HARRIS SAVINGS BANK
Plaintiff
vs.
No. 04-2896 (Cumberland Co.)
No. 5148-T-2004 (Dauphin Co.)
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
TO: Patricia A. Gordon
836 Meadow Lane
Camp Hill, Pennsylvania 17011
DATE OF NOTICE: July 20, 2004
NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE
OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE 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.
LAWYER REFERRAL SERVICE OF THE
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Dated: July 20, 2004 BY:,;/ ~ t~A
Benjamtnig9S,7!U
Attomey for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
Phone: (717) 815-4518
I.D. No. 72030
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OFFICE OF THE PROTHONOTARY
Cumberland County Court House
One Courthouse Square
Telephone: (717) 240-6195
Richard J. Gordon
Date:
2971 North Second Street
Harrisburg, Pennsylvania 17110
No: 04-2896 Civil Term
RE: WAYPOINT BANK, F/KJA YORK FEDERAL SAVINGS AND
LOAN ASSOCIATION AND HARRIS SAVINGS BANK, Plaintiff
VS. RICHARD J. GORDON and PATRICIA A. GORDON, Defendant(s)
( X ) Notice is hereby given that a judgment in the above-captioned matter has been
entered against you in the amount of $73,780.17 on ()~ :Is, :lMJ'{
( X) A copy of all documents filed with the Prothonotary in support of the within
judgment is/are enclosed.
r~ I?/?r.. ~
Prothonotary Civil Dlv. {J
by:
If you have any questions concerning the above case, please contact the following
party:
Benjamin F. Riggs, Jr.
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
J.D. No. 72030
(This Notice is given in accordance with Pa.R.C.P. 236.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KJA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
vs.
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
Commonwealth of Pennsylvania
County of York
No. 04-2896 Civil Term
AFFIDAVIT OF NON.MILlT ARY SERVICE
Before me, a Notary Public for York County, Pennsylvania, personally appeared
Benjamin F. Riggs, Jr., Attorney for the Plaintiff in the above entitled case, who being
duly sworn or affirmed according to law deposes and says, that the Defendant(s) above
named is/are not in the military service of the United States of America, that he has
personal knowledge that the said Defendant, Richard J. Gordon's last-known address is
2971 North Second Street Harrisburg, Pennsylvania 17110, and Defendant, Patricia A.
Gordon's last-known address is 836 Meadow Lane, Camp Hill, Pennsylvania 17011.
Sworn and SUbSCribnubr:t
me this 2 ~\f-t, day of .
2004
~^
Nota
My Commissi
Dawn M Notarial Seal
City ;"Gutierrez. NOIllly Public
My Comml . YOI!<, York Counly
"'on Expires Apr. IS. 2006
MIiiitiiii', PEIr1nS}1iianla AssoCiationot Notaries
By:
Benjamin F. R ggs, J .
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
I.D. No. 72030
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KlA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
vs.
RICHARD J. GORDON
PATRICIA A, GORDON
Defendants
Commonwealth of Pennsylvania
County of York
AFFIDAVIT OF MAILING
Before me, a Notary Public in and for said County and Commonwealth, the
undersigned officer, personally appeared Benjamin F. Riggs, Jr., Attorney for Waypoint
Bank, f/kla York Federal Savings and Loan Association and Harris Savings Bank, the
Plaintiff in the above-captioned judgment, who, being duly sworn according to law,
deposes that on the2at!'day of M-~~i~r ' 2004, a Notice of Sheriff's Sale in the
above-captioned case was mail~(j,-~iafirst class mail, postage prepaid, to the following:
Cumberland County Tax Claim
Bureau
One Courthouse Square
Cumberland, Pennsylvania 17013
Federal National Mortgage Association
2415 Vision Drive
Columbus, Ohio 43219
Federman and Phelan, LLP
Francis S, Hallinan, Esquire
One Penn Center Plaza, Suite 1400
Philadelphia, Pennsylvania 19103
Copy of Proof of Mailing is attached hereto.
Sworn and sUbscribOrre
me this ZOcU1 day of ,
2004 (
cDJr!fl~a PUb~
My Commiss n Expires
By: ~ ce j .J
Benjami:'r=~i99;71
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
1.0. No. 72030
f Notarial Seal I
Dawn M. Gutierrez, NoIllIy Public
City of York, York COOaty
My Commission Expires Apr. IS, 2006
Member, PElnnsyIvaniaAssociationotNotartes
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KlA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
vs.
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
PRAECIPE FOR WRIT OF EXECUTION P.R.C.P. 3101 TO 3149
TO THE PROTHONOTARY: Issue Writ of Execution in the above-captioned matter.
(1) Directed to the Sheriff of Cumberland County, Pennsylvania
(2) Against Richard P. Gordon and Patricia A. Gordon
(3) And index this writ against Richard P. Gordon and Patricia A. Gordon,
Defendants
As a lis pendens against the real property of the Defendants as follows:
ALL that certain tract of land, with the improvements thereon erected,
situate in Hampden Township, Cumberland County, as more fully
described in Exhibit A, attached hereto and made a part hereof.
(4) Amount due $73,780.17
with interest from December 9, 2004 at such rate or rates established by Plaintiff
pursuant to the terms of the Note currently $10.1585 per diem, from December 9, 2004,
late charges from December 9, 2004 at 5% of the monthly payment amount, currently
$52.15 per month, attomey's fees, costs of suit and other charges collectible under the
Mortgage; and for any and all other relief as the Court deems appropriate.
DATE: ~'/'cloi BY:.-4:.. () 1...A
Benjamin F. ~~rf
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
1.0. No. 72030
Exhibit A - Legal Description
ALL THAT CERTAIN tract of land situate in Hampden Township shown as 95.08 feet to
Lot No. 38 and 16.75 feet to Lot No. 40 on Plan of Brentwater, East Pennsboro and
Hampden Township, Cumberland County, Pennsylvania, recorded in the Office of the
Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No.4, Page 93, bounded and
described as follows, to wit:
BEGINNING at a point on the center line of Meadow Lane at the intersection of the
Western line of a five (5) foot wide path now or late of Harold A. Monaco, et ux; thence
along the Western line of said path, South 12 degrees 13 minutes East, two hundred
forty-three and eighty one hundredths (243.80) feet, more or less, to the fence and
property line of land now or late of Lawrence H. Walker, et ux; thence along said fence
and property line, South 77 degrees 47 minutes West, one hundred eleven and eighty-
three one hundredths (111.83) feet, more or less, to a point; thence North 12 degrees
13 minutes West, two hundred forty-three and eighty one hundredths (243.80) feet,
more or less, to a point on the center line of Meadow Lane; thence North 77 degrees 47
minutes East, one hundred eleven and eighty-three one hundredths (111.83) feet, more
or less, along said center line to the point of BEGINNING.
CONSISTING of 95.08 feet of Lot #38 and eastern 16.75 feet of Lot #40.
HAVING theron erected a single brick and aluminum dwelling known and numbered as
836 Meadow Lane.
BEING the same premises which Shirley J. Green, single woman, by deed dated
October 7,1976 and recorded in the Cumberland County Recorder's Office in Deed
Book 26-V, Page 526, granted and conveyed unto Richard J. Gordon and Patricia A.
Gordon, his wife.
SUBJECT to restrictions as contained in prior deeds.
TOGETHER with all and singular the hereditaments and appurtenances thereunto
belonging or in anywise appertaining and the reversions and remainders, rents, issues
and profits thereof; and all the estate, right, title, interest, property, claim and demand
whatsoever of the said part of the first part, in law, equity or otherwise of, in and to the
same and every part therof.
Tax 1.0. # 10-18-1312-009
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTHOFPENNSYLVANlA)
COUNTY OF CUMBERLAND)
N004-2896 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due W AYPOINT BANK FIKlA YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff (s)
From RICHARDJGORDON AND PATRICIA A GORDON
(I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon all subject to attachment is found in the possession
of anyone other than a I1amed garnishee, you are directed to notify himlher that helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due$ 73,780.17
Interest 12109104 $10.1585 PER DIEM
L.L. $0.50
Atty's Comm
%
Due Prothy $1.00
Atty Paid $ 175.35 Other CostsLATE CHARGES 12109104 5%
MONTHLY PAYMENT CURRENTLY $52.15 PER MONTH
Plaintiff Paid
Date: AUGUST 25, 2004
(Seal)
CURTIS R. LONG
Prothonotary ,
By: 071 _ O. /hdf'~
Deputy
REQUESTING PARTY:
Name BENJAMIN F RIGGS JR ESQ
Address: P O. BOX 1711, HARRISBURG, PA 17105-1711
Attorney for: PLFF
Telephone: (717)815-4518
Supreme Court ID No. 72030
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KlA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
vs.
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
AFFIDAVIT PURSUANT TO RULE 3129.1
Waypoint Bank, f/kla York Federal Savings and Loan Association and Harris
Savings Bank, Plaintiff in the above action, sets forth as of the date the praecipe for the
writ of execution was filed to following information concerning the real property located
at
836 Meadow Lane, Camp Hill, Pennsylvania 17011
1. Name and address of Owners or Reputed Owners:
Name
Richard J. Gordon
Address
2971 North Second Street
Harrisburg, Pennsylvania 17110
Patricia A. Gordon
836 Meadow Lane
Camp Hill, Pennsylvania 17011
2. Name and address of Defendants in the Judgment:
Name
Richard J. Gordon
Address
2971 North Second Street
Harrisburg, Pennsylvania 17110
Patricia A. Gordon
836 Meadow Lane
Camp Hill, Pennsylvania 17011
3.
Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name
Address (if address cannot be reasonably
ascertained, please do indicate)
Federal National Mortgage
Association
2415 Vision Drive
Columbus, Ohio 43219
Francis S. Hallinan, Esquire
One Penn Center Plaza, Suite 1400
Philadelphia, Pennsylvania 19103
4. Name and address of the last recorded holder of every mortgage of
Record:
Represented by Federman
and Phelan, LLP
Name
Waypoint Bank, f/k1a
York Federal Savings and
Loan Association and
Harris Savings Bank
Federal National Mortgage
Association
Address (if address cannot be reasonably
ascertained, please do indicate)
P.O. Box 1711
Harrisburg, PA 17105-1711
2415 Vision Drive
Columbus, Ohio 43219
5.
Name(s) and address of every other person who has any record lien on
their property:
Name
N/A
Address (if address cannot be reasonably
ascertained, please do indicate)
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:
Name
Cumberland County Tax Claim
Bureau
7.
Address (if address cannot be reasonably
ascertained, please do indicate)
One Courthouse Square
Cumberland, Pennsylvania 17013
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:
Name
N/A
Address (if address cannot be reasonably)
ascertained, please do indicate
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. Sec. 4904 relating to unsworn
falsification to authorities.
DATE:
~lwll1{
B"Be"~~~~
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
1.0. No. 72030
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KJA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
vs.
RICHARD J. GORDON
PATRICIA A GORDON
Defendants
NOTICE PURSUANT TO PA. R.C.P. 3129.2
NOTICE IS HEREBY GIVEN to the following parties who hold one or more mortgage,
judgment or tax liens against the real estate of Richard J. Gordon and Patricia A
Gordon.
Cumberland County Tax Claim
Bureau
One Courthouse Square
Cumberland, Pennsylvania 17013
Federal National Mortgage Association
2415 Vision Drive
Columbus, Ohio 43219
Federman and Phelan, LLP
Francis S. Hallinan, Esquire
One Penn Center Plaza, Suite 1400
Philadelphia, Pennsylvania 19103
You are hereby notified that on December 8,2004 at 10:00 AM., prevailing local time,
by virtue of a Writ of Execution issued out of the Court of Common Pleas of
Cumberland County, Pennsylvania, on the judgment of Waypoint Bank, flk/a York
Federal Savings and Loan Association and Harris Savings Bank vs. Richard J. Gordon
and Patricia A Gordon, No. 04-2896 Civil Term the Sheriff of Cumberland County,
Pennsylvania will expose at Public Sale in the Court House, One Courthouse Square,
County of Cumberland real estate of Richard J. Gordon and Patricia A Gordon and
numbered as 836 Meadow Lane, Camp Hill, Pennsylvania 17011 (Cumberland
County). A description of said real estate is hereto attached.
You are further notified that a Proposed Schedule of Distribution will be filed by
the Sheriff of Cumberland County on January 7, 2005, and distribution will be made in
accordance with the Schedule unless exceptions are filed thereto within ten (10) days
thereafter.
You are further notified that the lien you hold against said real estate will be
divested by the sale and that you have an opportunity to protect your interest, if any,
by being notified of said Sheriff Sale.
DATE:
~ J~lo'1
By: d t7 J~,~
Benjam~~;g?l;f
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
1.0. No. 72030
Exhibit A - Legal Description
ALL THAT CERTAIN tract of land situate in Hampden Township shown as 95.08 feet to
Lot No. 38 and 16.75 feet to Lot No. 40 on Plan of Brentwater, East Pennsboro and
Hampden Township, Cumberland County, Pennsylvania, recorded in the Office of the
Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No.4, Page 93, bounded and
described as follows, to wit:
BEGINNING at a point on the center line of Meadow Lane at the intersection of the
Western line of a five (5) foot wide path now or late of Harold A. Monaco, et ux; thence
along the Western line of said path, South 12 degrees 13 minutes East, two hundred
forty-three and eighty one hundredths (243.80) feet, more or less, to the fence and
property line of land now or late of Lawrence H. Walker, et ux; thence along said fence
and property line, South 77 degrees 47 minutes West, one hundred eleven and eighty-
three one hundredths (111.83) feet, more or less, to a point; thence North 12 degrees
13 minutes West, two hundred forty-three and eighty one hundredths (243.80) feet,
more or less, to a point on the center line of Meadow Lane; thence North 77 degrees 47
minutes East. one hundred eleven and eighty-three one hundredths (111.83) feet, more
or less, along said center line to the point of BEGINNING.
CONSISTING of 95.08 feet of Lot #38 and eastern 16.75 feet of Lot #40.
HAVING theron erected a single brick and aluminum dwelling known and numbered as
836 Meadow Lane.
BEING the same premises which Shirley J. Green, single woman, by deed dated
October 7,1976 and recorded in the Cumberland County Recorder's Office in Deed
Book 26-V, Page 526, granted and conveyed unto Richard J. Gordon and Patricia A.
Gordon, his wife.
SUBJECT to restrictions as contained in prior deeds.
TOGETHER with all and singular the hereditaments and appurtenances thereunto
belonging or in anywise appertaining and the reversions and remainders, rents, issues
and profits thereof; and all the estate, right. title, interest, property, claim and demand
whatsoever of the said part of the first part, in law, equity or otherwise of, in and to the
same and every part therof.
Tax 1.0. # 10-18-1312-009
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/K1A
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
vs.
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
PRAECIPE
Please withdraw the Writ of Execution in connection to the above captioned
case.
Dated: December 3,2004
BY:_~
Benja in . Rigg , J .
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
Phone: (717) 815-4518
1.0. No. 72030
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/K1A
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
vs.
RICHARD J. GORDON
PATRICIAA. GORDON
Defendants
PRAECIPE
Please dismiss the above-captioned case without prejudice and satisfy the
judgment that was entered on or about August 24, 2004 in the amount of
$73,780.17.
Dated: December 3,2004
By:
Benjamin F. Riggs, J .
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
Phone: (717) 815-4518
1.0. No. 72030
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AMENDED RETURN
Waypoint Bank f/kJa York Federal
Savings and Loan Association and
Harris Savings Bank
VS
Richard J. Gordon and Patricia A. Gordon
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2004-2896 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that e
made a diligent search and inquiry for the within named defendant, to wit: Richard J.
Gordon, but was unable to locate him in his bailiwick. He therefore deputized the Sh riff
of Dauphin County, Pennsylvania, to serve the within Real Estate Writ, Notice of Sal
and Description according to law.
Dauphin County Return: And Now: September 30, 2004 at I :00 pm served t
within Real Estate Writ, Notice of Sale upon Richard 1. Gordon by personally handin to
defendant one true attested copy of the original Real Estate Writ, Notice of Sale and
making know to him the contents thereof at Dauphin County Sheriff's Office, Harrisb g,
PA 17101. So answers: JR Lotwick, Sheriff of Dauphin County, PA.
CpI. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law,
states that on October 27,2004 at 7:57 o'clock PM, he served a true copy of the withi
Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled action,
upon the within named defendant, to wit: Patricia Gordon, by making known unto
Patricia Gordon, personally, at 744 Allenview Drive, Mechanicsburg, Cumberland
County, Pennsylvania, its contents and at the same time handing to her personally the
said true and correct copy of the same.
Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states tha
on October 07, 2004 at I :30 o'clock P.M., he posted a true copy of the within Real Est e
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Richard J. Gordon and Patricia A. Gordon located at 836 Meadow Lane, Camp Hill,
Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within named
defendant, to wit: Richard 1. Gordon, by regular mail to his last known address of2971
N. Second St., Harrisburg, P A 17110. This letter was mailed under the date of October
15, 2004 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to the within n ed
defendant, to wit: Patricia A. Gordon, by regular mail to her last known address of 7 4
Allenview Drive, Mechanicsburg, P A 17055. This letter was mailed under the date f
October 28, 2004 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states thi writ
is returned STAYED per instruction from Attorney Benjamin Riggs.
Sheriff's Costs:
Docketing
Posting Bills
Advertising
Law Library
Prothonotary
Mileage
Levy
Surcharge
Out of County
Dauphin County
Law Journal
Patriot News
Share of Bills
Poundage
30.00
15.00
15.00
.50
\.00
19.18
15.00
30.00
9.00
30.00
386.30
347.89
30.42
18.60
$ 948.69
Sworn and subscribed to before me
. / ,IV 07u J.
Thls~dayof I ,~~.)
2004, A.D. ~, (11h./;h, 0 ~
Protlio otary
So,A,9-!W?,J:".;Y ~'
- .. ,f,_". .'
~ ~~,;;.>;;t'-;,~,,~.:.~~ L~
R. Thomas Kline, Sheriff
BY J6~ JYVld~
Real Estat eputy
f~
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....,
ILL"--'
#
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS VANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KlA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
vs.
.j
-.,.(
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
( .
AFFIDAVIT PURSUANT TO RULE 3129.1
Waypoint Bank, f/kJa York Federal Savings and Loan Association and R~rris.
Savings Bank, Plaintiff in the above action, sets forth as of the date the praecipe for the
writ of execution was filed to following information concerning the real property cated
at
836 Meadow Lane, Camp Hill, Pennsylvania 17011
1. Name and address of Owners or Reputed Owners:
Name
Richard J. Gordon
Address
2971 North Second Street
Harrisburg, Pennsylvania 17110
Patricia A. Gordon
836 Meadow Lane
Camp Hill, Pennsylvania 17011
2. Name and address of Defendants in the Judgment:
Name
Richard J. Gordon
Address
2971 North Second Street
Harrisburg, Pennsylvania 17110
Patricia A. Gordon
836 Meadow Lane
Camp Hill, Pennsylvania 17011
3.
Name and address of every judgment creditor whose judgment is a r cord
lien on the real property to be sold:
Name
Address (if address cannot be reasonably
ascertained. please do indicate)
..
Federal National Mortgage
Association
2415 Vision Drive
Columbus, Ohio 43219
Francis S. Hallinan, Esquire
One Penn Center Plaza, Suite 1400
Philadelphia, Pennsylvania 19103
4. Name and address of the last recorded holder of every mort age of
Record:
Represented by Federman
and Phelan, LLP
Name
Waypoint Bank, flk/a
York Federal Savings and
Loan Association and
Harris Savings Bank
Federal National Mortgage
Association
Address (if address cannot be reasonably
ascertained, please do indicate)
P.O. Box 1711
Harrisburg, PA 17105-1711
2415 Vision Drive
Columbus, Ohio 43219
5.
Name(s) and address of every other person who has any record lien on
their property:
Name
N/A
Address (if address cannot be reasonably
ascertained, please do indicate)
6.
Name and address of every other person who has any record int rest in
the property and whose interest may be affected by the sale:
Name
Cumberland County Tax Claim
Bureau
Address (if address cannot be reasonably
ascertained. please do indicate)
One Courthouse Square
Cumberland, Pennsylvania 17013
Name and address of every other person of whom the plainti has
knowledge who has any interest in the property, which may be affec ed by
the sale:
7.
Name
N/A
Address (if address cannot be reasonably)
ascertained, please do indicate
I verify that the statements made in this affidavit are true and correct to the best f my
personal knowledge or information and belief. I understand that false statements erein
are made subject to the penalties of 18 PA C.S. Sec. 4904 relating to unsworn
DATE:
'5/2'- Ice{
..
falsification to authorities.
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSY VANIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KfA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
,.......
vs.
-;"1
---I
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
PURSUANT TO PENNSYLVANIA RULES OF CIVIL PROCEDURE 3129.2
TO: Richard J. Gordon
2971 North Second Street
Harrisburg, Pennsylvania 17110
TAKE NOTICE:
That the Sheriff's Sale of Property (real estate) will be held on December 8,
2004, in the SHERIFF'S OFFICE, Cumberland County Courthouse, One Courthous
Square at 10:00 A.M. prevailing time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
mainly consisting of a statement of the measured boundaries of the property, togeth
with a brief mention of the building and any other improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
836 Meadow Lane, Camp Hill, Pennsylvania 17011
THE JUDGMENT under or pursuant to which your property is being sold is
docketed to 04-2896 Civil Term.
THE NAME OF THE OWNERS or REPUTED OWNERS OF THIS PROPERTY
ARE:
RICHARD J. GORDON and PATRICIA A. GORDON
A SCHEDULE OF DISTRIBUTION, being a list of the persons, and or
governmental or corporate entities or agencies being entitled to receive a part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example t banks
that hold mortgages and municipalities that are owed taxes) will be filed by the heriff
within thirty (30) days after the sale and distribution of the proceeds of ale in
accordance with this schedule will, in fact, be made unless someone objects filing
exceptions to it within ten (10) days of the date it is filed. Information ab ut the
Schedule of Distribution may be obtained from the Sheriff of the Court of C mmon
Pleas of Cumberland County, Cumberland County Courthouse, One Cou house
Square.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE
YOUR PROPERTY.
It has been issued because there is a judgment against you. It may cause your
property to be held, to be sold or taken to pay the judgment. You may have legal rights
to prevent your property from being sold or taken to pay the judgment. A lawyer an
advise you more specifically of these rights. If you wish to exercise your rights, y u
must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO 0
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE U
CAN GET FREE LEGAL ADVICE:
LAWYER REFERRAL SERVICE OF THE
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a Petition with the Court of Common Pleas of Cumberland
County to open the judgment if you have a meritorious defense against the pers n or
company that has entered judgment against you. You may also file a petition wit the
same Court if you are aware of a legal defect in the obligation or the procedure u ed
against you.
2. After the Sheriffs sale you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price r for
other proper cause. This petition must be filed before the Sheriffs Deed is delive d.
3. A petition or petitions raising the legal issues or rights mentioned n the
preceding paragraphs must be presented to the Court of Common Pie s of
Cumberland County at one of the Court's regularly scheduled Business Court
sessions. The petition must be served on the attorney for the creditor or n the
creditor at least two business days before presentation to the Court and a pro osed
order or rule must be attached to the petition. If a specific return date is desired, uch
.'
date must be obtained from the Court Administrator, Cumberland County Courth use,
One Courthouse Square, before presentation of the petition to the Court.
DATE:
g/J01
7
By: t.
Benjamin F. Riggs, Jr
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
1.0. No. 72030
.'
"
Exhibit A - Legal Description
ALL THAT CERTAIN tract of land situate in Hampden Township shown as 95.0
Lot No. 38 and 16.75 feet to Lot No. 40 on Plan of Brentwater, East Pennsboro
Hampden Township, Cumberland County, Pennsylvania, recorded in the Office f the
Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No.4, Page 93, bound d and
described as follows, to wit:
BEGINNING at a point on the center line of Meadow Lane at the intersection of t e
Western line of a five (5) foot wide path now or late of Harold A. Monaco, et ux; t ence
along the Western line of said path, South 12 degrees 13 minutes East, two hun red
forty-three and eighty one hundredths (243.80) feet, more or less, to the fence a d
property line of land now or late of Lawrence H. Walker, et ux; thence along said ence
and property line, South 77 degrees 47 minutes West, one hundred eleven and ighty-
three one hundredths (111.83) feet, more or less, to a point; thence North 12 de rees
13 minutes West, two hundred forty-three and eighty one hundredths (243.80) fe t,
more or less, to a point on the center line of Meadow Lane; thence North 77 deg es 47
minutes East, one hundred eleven and eighty-three one hundredths (111.83) fee, more
or less, along said center line to the point of BEGINNING.
CONSISTING of 95.08 feet of Lot #38 and eastern 16.75 feet of Lot #40.
HAVING theron erected a single brick and aluminum dwelling known and numb
836 Meadow Lane.
BEING the same premises which Shirley J. Green, single woman, by deed dated
October 7, 1976 and recorded in the Cumberland County Recorder's Office in 0
Book 26-V, Page 526, granted and conveyed unto Richard J. Gordon and Patrie
Gordon, his wife.
SUBJECT to restrictions as contained in prior deeds.
TOGETHER with all and singular the hereditaments and appurtenances thereunt
belonging or in anywise appertaining and the reversions and remainders, rents, i sues
and profits thereof; and all the estate, right, title, interest, property, claim and de nd
whatsoever of the said part of the first part, in law, equity or otherwise of, in and t the
same and every part therof.
Tax 1.0. # 10-18-1312-009
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV NIA
ACTION- - MORTGAGE FORECLOSURE
WAYPOINT BANK, F/KJA
YORK FEDERAL SAVINGS
AND LOAN ASSOCIATION
AND HARRIS SAVINGS BANK
Plaintiff
No. 04-2896 Civil Term
vs.
RICHARD J. GORDON
PATRICIA A. GORDON
Defendants
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
PURSUANT TO PENNSYLVANIA RULES OF CIVIL PROCEDURE 3129.2
TO: Patricia A. Gordon
836 Meadow Lane
Camp Hill, Pennsylvania 17011
TAKE NOTICE:
That the Sheriff's Sale of Property (real estate) will be held on December 8
2004, in the SHERIFF'S OFFICE, Cumberland County Courthouse, One Courtho se
Square at 10:00 A.M. prevailing time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal descriptio
mainly consisting of a statement of the measured boundaries of the property, tog ther
with a brief mention of the building and any other improvements erected on the I d.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
836 Meadow Lane, Camp Hill, Pennsylvania 17011
THE JUDGMENT under or pursuant to which your property is being sold i
docketed to 04-2896 Civil Term.
THE NAME OF THE OWNER(S) or REPUTED OWNER(S) OF THIS
PROPERTY IS/ARE:
RICHARD J. GORDON and PATRICIA A. GORDON
A SCHEDULE OF DISTRIBUTION, being a list of the persons, nd or
governmental or corporate entities or agencies being entitled to receive a pa of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to ba ks
that hold mortgages and municipalities that are owed taxes) will be filed by the Sh riff
within thirty (30) days after the sale and distribution of the proceeds of sal in
accordance with this schedule will, in fact, be made unless someone objects by f ing
exceptions to it within ten (10) days of the date it is filed. Information about the
Schedule of Distribution may be obtained from the Sheriff of the Court of Com on
Pleas of Cumberland County, Cumberland County Courthouse, One Courth use
Square.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SAL
YOUR PROPERTY.
It has been issued because there is a judgment against you. It may cause our
property to be held, to be sold, or taken to pay the judgment. You may have egal
rights to prevent your property from being sold or taken to pay the judgment. A la er
can advise you more specifically of these rights. If you wish to exercise your ri hts,
you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO T
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE Y U
CAN GET FREE LEGAL ADVICE:
LAWYER REFERRAL SERVICE OF THE
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a Petition with the Court of Common Pleas of Cumb rfand
County to open the judgment if you have a meritorious defense against the per on or
company that has entered judgment against you. You may also file a petition w h the
same Court if you are aware of a legal defect in the obligation or the procedur used
against you.
2. After the Sheriff's sale you may file a petition with the Court of Co mon
Pleas of Cumberland County to set aside the sale for a grossly inadequate pric or for
other proper cause. This petition must be filed before the Sheriff's Deed is delive ed.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common PI as of
Cumberland County at one of the Court's regularly scheduled Business Court
sessions. The petition must be served on the attorney for the creditor or n the
creditor at least two business days before presentation to the Court and a pr posed
order or rule must be attached to the petition. If a specific return date is desired such
date must be obtained from the County Commissioner, Cumberland Cou ty
Courthouse, One Courthouse Square, before presentation of the petition to the Cou
DATE:
Y/z4)Y
By: Ji21r4-
Benjamin F. iggs, Jr.
Attorney for Plaintiff
P.O. Box 1711
Harrisburg, PA 17105-1711
(717) 815-4518
1.0. No. 72030
Exhibit A - Legal Description
ALL THAT CERTAIN tract of land situate in Hampden Township shown as 95.08 fe t to
Lot No. 38 and 16.75 feet to Lot No. 40 on Plan of Brentwater, East Pennsboro and
Hampden Township, Cumberland County, Pennsylvania, recorded in the Office of t e
Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No.4, Page 93, bounded nd
described as follows, to wit:
BEGINNING at a point on the center line of Meadow Lane at the intersection of the
Western line of a five (5) foot wide path now or late of Harold A. Monaco, et ux; the ce
along the Western line of said path, South 12 degrees 13 minutes East, two hundr d
forty-three and eighty one hundredths (243.80) feet, more or less, to the fence and
property line of land now or late of Lawrence H. Walker, et ux; thence along said f nee
and property line, South 77 degrees 47 minutes West, one hundred eleven and ei hty-
three one hundredths (111.83) feet, more or less, to a point; thence North 12 degr es
13 minutes West, two hundred forty-three and eighty one hundredths (243.80) fee,
more or less, to a point on the center line of Meadow Lane; thence North 77 degr s 47
minutes East, one hundred eleven and eighty-three one hundredths (111.83) feet, more
or less, along said center line to the point of BEGINNING.
CONSISTING of 95.08 feet of Lot #38 and eastern 16.75 feet of Lot #40.
HAVING theron erected a single brick and aluminum dwelling known and numb ed as
836 Meadow Lane,
BEING the same premises which Shirley J. Green, single woman, by deed dated
October 7, 1976 and recorded in the Cumberland County Recorder's Office in 0 ed
Book 26-V, Page 526, granted and conveyed unto Richard J. Gordon and Patri a A.
Gordon, his wife.
SUBJECT to restrictions as contained in prior deeds.
TOGETHER with all and singular the hereditaments and appurtenances thereu 0
belonging or in anywise appertaining and the reversions and remainders, rents, ssues
and profits thereof; and all the estate, right, title, interest, property, claim and de and
whatsoever of the said part of the first part, in law, equity or otherwise of, in and to the
same and every part therof.
Tax 1.0. # 10-18-1312-009
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
N004-2896 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due W AYPOINT BANK F/K/A YORK FEDERAL SAVING
AND LOAN ASSOCIATION AND HARRIS SAVINGS BANK Plaintiff(s)
From RICHARD J GORDON AND PATRICIA A GORDON
(I) 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 fro
paying any debt to or for the account of the defendant (s) and from delivering any property of the defend
(5) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon au subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as
garnishee and is enjoined as above stated.
Amount Due$ 73,780.17
Interest 12/09/04 $10.1585 PER DIEM
L.L. $0.50
Atty's Comm
%
Due Prothy $1.00
Atty Paid $175.35 Other CostsLATE CHARGES 12/09/04 5%
MONTHLY PAYMENT CURRENTL Y $52.15 PER MONTH
Plaintiff Paid
Date: AUGUST 25, 2004
CURTIS R. LONG
Prothonot!!TY
(Seal)
By:
Q
Deputy
REQUESTING PARTY:
Name BENJAMIN F RIGGS JR ESQ
Address: PO. BOX 1711, HARRISBURG, PA 17105-1711
Attorney for: PLFF
Telephone: (717)815-4518
Supreme Court ID No. 72030
Real Estate Sale #31
On September 01,2004 the Sheriff1evied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, P A
Known and numbered as 836 Meadow Lane,
Camp Hill, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: September 01, 2004
By: JM.L1.J: i-lt..
Real E;t~tiD~uty
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REAL ESTATE SALE No. 31
Writ No. 2004-2896
Civil Tltnn
Waypolnt Bank f/kla
York Federal Savings and Loan
Association and
Harris- SavIngs Bank
Vs
Richard J. Gordon and
Patricia A. Gordon
Atty: BenJamin Riggs
DESCRIPTION
AlL 'IHKf CERfAlN tract of land situate in
"~'lllwmibip shown .. 95.08 feet III Lot
No, 3&i.a\ld 16.75 f<<llll Lot No. 40 on Pbn of
Ill~, ..EaSt. I'l:Dnsllom a\ld Hampden
T~,CumberIaod Coonty,Pennsylvania,
.Iliorded in 1be Office of the Recorder of Deeds,
ClIIlisle,Pennsylvania, in Pbn Book No.4, Page
93. bwnderl a\ld described.. follow<, to wit:
BEGlNNlNG .... a point on the center line of
Meadow Lane at the intersection of the Western
line of a five (5) fOOl wide path now or late of
Harold A. Monaco, et ..!IX; thence along the
WesI<m line of said path. South 12 degroos 13
minutes East, two hundred forty-1hree and eighty
one-bundredths (243.80) feet, more or less, to the
fence and property line of land now or late of
Lawrence H. Walker, et !IX; thence along said
fence and property line, South 77 degrees 47
minutes West, one hundred eleven and eighty-
1hree ooo-bundredlba (111.83) feet, more Of less,
III a point; thence North 12 degrees 13 minutes
West, twu hundred forty-1hree and eighty one-
hnndredtbs (243.80) feet, more or less, to . point
on the center line of Meadow Lane; thence North
77 degrees 47 minutes F.ast, one hundred eleven
and eigbty-1hree olJe-hundredths (J 11.83) feet,
more or less, along said center line to the point of
BEGlNNlNG.
CONSISTING of 95.08 feet of Lot #38 and
eaatem 16.75 feet of Lot #40.
HAVING thereon ere<:ted a single brick and
aluminum dwelling known and numbered as 836
Meadow Lane.
BEING the same premises which Shirley J.
Green, single woman, by deed dated October 7,
1976 and recorded in the CumberlJmd County
Recozrler's Office in Deed Book 26- V, Page 526.
gnmted and conveyed unto Riclwd J. Gordon and
PatriciaA. Gordon. his wife.
SUBlECf to restrictions as contained in prior
deeds.
TOGETHER with all and singular the
hereditaments and appm1enances !hereunto
belonging or in' anywise appertaining and the
reversions and remainders, rents, issues and
profits thereof; and all the estate, righ~ title,
interes~ property. claim ond demand whatsoever
of the said part of the first part. in law, equity or
otherwise of. in and III the same and every pan
thereof.
Tax !D. #10-18-1312-009.
.
dred eleven and eighty-three one
hundredths (111.83) feet. more or
less, to a point; thence North 12
degrees 13 minutes West, two hun-
dred forty-three and eighty one hun-
dredths (243.80) feet, more or less,
to a point on the center line of Mead-
ow Lane; thence North 77 degrees
47 minutes East, one hundred
eleven and eighty-three one hun-
dredths (111.83) feet, more or less,
along said center line to the point of
BEGINNING.
CONSISTING of 95.08 feet of Lot
#38 and eastern 16.75 feet of Lot
#40.
HAVING theron erected a single
brick and aluminum dwelling known
and numbered as 836 Meadow Lane.
BEING the same premises which
Shirley J. Green, single woman, by
deed dated October 7, 1976 and
recorded in the Cumberland County
Recorder's Office in Deed Book 26-
V. Page 526. granted and conveyed
unto Richard J. Gordon and Patricia
A. Gordon, his wife.
SUBJECT to restrictions as con.
tained in prior deeds.
TOGETHER with all and singu-
lar the hereditaments and appurte-
nances thereunto belonging or in
anywise appertaining and the rever-
sions and remainders, rents, issues
and profits thereof; and all the es-
tate. right. title, interest. property.
claim and demand whatsoever of the
said part of the first part. in law,
equity or otherwise of, in and to the
same and every part therof.
Tax J.D. #10-18-1312-009.
REAL ESTATE SALE NO, 31
Writ No. 2004-2896 Civil
Waypoint Bank, f/k/a
York Federal Savings and
Loan Association and
Harris Savings Bank
vs.
Richard J. Gordon and
Patricia A. Gordon
Atty.: Benjamin Riggs
Exhibit A-Legal Description
ALL THAT CERTAIN tract of land
situate in Hampden Township shown
. as 95.08 feet to Lot No. 38 and
16.75 feet to Lot No. 40 on Plan of
Brentwater, East Pennsboro and
Hampden Township. Cumberla~d
County, Pennsylvania. recorded m
the Office of the Recorder of Deeds,
Carlisle, Pennsylvania, in Plan Book
No.4. Page 93, bounded and de-
scribed as follows, to wit:
BEGINNING at a point on the
center line of Meadow Lane at the
intersection of the Western line of a
five (5) foot wide path now or late of
Harold A. Monaco, et ux; thence
along the Western line of said path,
South 12 degrees 13 minutes East.
two hundred forty-three and eighty
one hundredths (243.80) feet, more
or less, to the fence and property
line of land now or late of Lawrence
H. Walker, et ux; thence along said
fence and property line, South 77
degrees 47 minutes West, one hun-
.
.'