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LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
1310 INDUSTRIAL BOULEVARD
1sT FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
-FiLEC-CFFICE
Crt T,°' F -tOTHCHCTARY
CCLIN"TY
ATTORNEY FOR PLAINTIFF
U.S. BANK NA ND COURT OF COMMON PLEAS
205 W. 4TH STREET, SUITE 500,
CN-TX 05-Fl CIVIL DIVISION
CINCINNATI, OH 45202
PLAINTIFF
VS.
JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
DEFENDANT
CUMBERLAND COUNTY
NO. 10 - (01081 alvIlTew
COMPLAINT IN
MORTGAGE FORECLOSURE
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the court
your defense or objections to the claims set forth against you. You are warned that if you fail to do
so the case may proceed without you and a judgment may be entered against you by the Court
without further notice for any money claimed in the complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
800-990-9108
Q
(+? '1980
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C § 1692 et seq.
(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY
PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30)
DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN
AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF
REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL
FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE
ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30)
DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO
COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER
TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS,
YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF
THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF
YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE
ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON
YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS
SUIT.
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
1310 INDUSTRIAL BOULEVARD
1 sT FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
ATTORNEY FOR PLAINTIFF
U.S. BANK NA ND
205 W. 4TH STREET, SUITE 500,
CN-TX 05-FI
CINCINNATI, OH 45202
PLAINTIFF
VS.
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
JEAN F. MILLER NO.
525 HARDING STREET COMPLAINT IN
NEW CUMBERLAND, PA 17070
DEFENDANT MORTGAGE FORECLOSURE
CIVIL ACTION MORTGAGE FORECLOSURE
1. U.S. Bank NA ND (hereinafter referred to as "Plaintiff") is an Institution
conducting business under the Laws of the Commonwealth of Pennsylvania with
a principal place of business at the address indicated in the caption hereof.
2. Jean F. Miller (hereinafter referred to as "Defendant") is an adult individual
residing at the address indicated in the caption hereof.
3. Plaintiff brings this action to foreclose on the mortgage between the Defendant
and itself as Mortgagee by Assignment. The Mortgage, dated March 17, 2006,
was recorded on March 22, 2006 in the Office of the Recorder of Deeds in
Cumberland County in Mortgage Book 1944, Page 907. Plaintiff is the
Mortgagee by Assignment by virtue of an Assignment of Mortgage recorded on
July 15, 2010 in the Office of the Recorder of Deeds in Cumberland County at
Instrument Number 201019054. A copy of the Mortgage and Assignment of
Mortgage are attached and made a part hereof as Exhibits `A' and `B',
respectively.
4. The Mortgage secures the indebtedness of a Note executed by the Defendant on
March 17, 2006 in the original principal amount of $124,720.00 payable to
Plaintiff in monthly installments with an interest rate of 7.50%. A copy of the
Note is attached and made a part hereof as Exhibit `C'.
5. The land subject to the mortgage is 525 Harding Street, New Cumberland, PA
17070. A copy of the Legal Description is attached as part of the Mortgage as
Exhibit `A' and incorporated herein.
6. The Defendant is the Record Owner of the mortgaged property located at
525 Harding Street, New Cumberland, PA 17070.
7. The Mortgage is now in default due to the failure of the Defendant to make
payments as they became due and owing. As a result of the default, the
following amounts are due:
Principal Balance $119,841.19
Interest to 10/14/2010 $9,308.24
Accumulated Late Charges $479.60
Property Inspections $95.00
Advances/Escrow $2,215.91
Cost of Suit and Title Search $550.00
Attorney's Fees
TOTAL
$1,300.00
$133,789.94
plus interest from 10/15/2010 at $24.62 per day, costs of suit and attorney's fees.
8. The attorney's fees set forth above are in conformity with the Mortgage
documents and Pennsylvania Law, and will be collected in the event of a third
party purchase at Sheriff's sale. If the Mortgage is reinstated prior to the Sale,
reasonable attorney's fees will be charged.
9. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a
defaulting mortgagor with a Notice of Intention to Foreclose ("Act 6 Notice")
41 P.S. Section 403 and Notice of Homeowners' Emergency Mortgage
Assistance ("Act 91 Notice") 35 P.S. Section 1680.403c.
10. The Notice of Intention to Foreclose and Notice of Homeowners' Emergency
Mortgage Assistance were required and Plaintiff sent the uniform notice as
promulgated by the Pennsylvania Housing Finance Agency to the Defendant by
regular and certified mail on June 1, 2010. A copy of the Notice is attached and
made a part hereof as Exhibit `D'.
WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale
of the mortgaged property in Plaintiff's favor and against the Defendant, in the sum of
$133,789.94 together with the interest from 10/15/2010 at $24.62 per day, costs of suit and
attorney's fees.
Law Offices of Gregory Javardian
BY:
Gdo , J a r jan
rney ID o 55669
Attorney fo aintiff
EXHIBIT `A'
00000
Prepared By:
Wilmington Finance, Inc.
401 Plymouth Road, Suite 400
Plymouth Meeting, PA 19462
Return To :
Wilmington Finance, Inc.
401 Plymouth Road, Suite 400
Plymouth Meeting, PA 19462
Parcel Number: 26 23 0543 081
,.,:111 7.1:: .. -JE i.ER
17 r. OR ME R V- I - r`1 F. '01 S
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LIDO MH 22 Pfd 3 15
Premises: 525 11ARDING STREET
NEW CUMBERLAND, PA 17070 ??
[Space Above This Line For Recording Data]
MORTGAGE
Loan Number: MIN 100372406032303015
DEFINITIONS
Words used in multiple sections of this document are d below and other words are deemed in Sections 3, 11, 13,
18,20 and 21. Certain rules regarding the usage of words used in this document arc also provided in Section 16.
(A) "Security Instrument" means this document, which is dated March 17, 2006 ,
together with all Riders to this document.
(B) "Borrower" is
JEAN F. MILLER,SINGLE PERSON
Burrower is the mortgagor under this Security Instrument.
(C) "ME ks" is Mortgage Electronic Registration Systems, Inc. MFRS is a separate corporation that is acting solely as
a nominee or Lender and Lender's successors and assigns. M ERS is the mortgagee under this Security Instrument.
MFRS is =anized and existing under the laws of Delaware, and has an address and telephone number of P.O. Box
2026, Flint Ml 48501-2026, tel. (888) 679-MFRS.
Single FamBy - Fannie Mae/Freddie Mae UNIFORM INSTRUMENT WITH MERS Form 3034 1101
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(D) "Lender" is
Wilmington Finance, Inc.
Lender is a Corporation
organized and existing under the laws of Delaware
Lender's address is 401 Plymouth Road, Suite 400
Plymouth Meeting, PA 19462
(E) "Note" means the promissory note signed by Borrower and dated March 17, 2006
The Note states that Borrower owes Lender
One Hundred Twenty-Four Thousand Seven Hundred'Twcnty and 001100 Dollars
(U.S. S 124,720.00 ) plus interest. Borrower has promised to pay this debt in regular Periodic
Payments and to pay the debt in full not laterthan April i, 2036
(F) "Property" means the property that is described below under the heading "Transfer of Rights in the Property."
(G) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges due under
the Note, and all sums due under this Security Instrument, plus interest.
(H) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to
be executed by Borrower (check box as applicable]:
? Adjustable Rate Rider ? Condominium Rider ? Second Home Rider
? Balloon Rider ? Planned Unit Development Rider ? 1-4 Family Rider
? VA Rider ? Biweekly Payment Rider ? Other(s) f specify]
(1) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances and
administrative rules and orders (that have the effort of law) as well as all applicable final, non-appealable judicial
opinions.
(J) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other charges that
are imposed on Borrower or the Property by a condominium association, homeowners association or similar
organization.
(K) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check, draft, or
similar paper instrument, which is initiated through an electronic terminal, telephonic instrument, computer, or
magnetic type so as to order, instruct, or authorize a financial institution to debit or credit an account. Such term
includes, but is not limited to, point-of-sale transfers, automated teller machine transactions, transfers initiated by
telephone, wire transfers, and automated clearinghouse transfers.
(1.) "Escrow Items" means those items that are described in Section 3.
(M) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by any
third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or
destruction; of, the Property; (ii) condemnation or other taking of all or any part of the Property; (iii) conveyance in lieu
ofcondemr?ation; or (iv) misrepresentations of, or omissions as to, the value and/orcondition of the Property.
(`) "Mort age Insurance" means insurance protecting Lenderagainst the nonpayment of, or default on, the Loan.
(O) "Perio is Payment" means the regularly scheduled amount due for (i) principal and interest under the Note, plus
(ii) any am unts under Section 3 of this Security Instrument.
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DDS-6PA
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11K I
(P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et scq.) and its implementing
regulation; Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or any additional or
successor legislation or regulation that governs the same subject matter. As used in this Security Instrument, "RESPA"
refers to all requirements and restrictions that are imposed in regard to a "federally related mortgage loan" even if the
Loan does not qualify as a "federally related mortgage loan" under RESPA.
(Q) "Successor in Interest of Borrower" means any party that has taken title to the Property, whether or not that parry
has assumed Borrower's obligations under the Mote and/or this Security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: (i) the repayment of the Loan, and all renewals, extensions and
modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this Security
Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as
nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS, the following
described property located in the County (Type of RecordingJunsdtetionl
of CUMBERLAND INarrncof ccordtngJurisdictionI:
LEGAL DESCRIPTION A'I'I'ACHED HERETO AND MADE A PART IIEREOF.
which currently has the address of
525 HARDING STREET IStreetl
NEW CUMBERLAND ICityl. Pennsylvania 17070 Izipcodel
("Property Address"):
TOGFI'HER WITH all the improvements now or hereafter erected on the property, and all casements,
appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered
by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." Borrower
understand$ and agrees that MERS holds only legal title to the interests granted by Borrower in this Security
Instrument, ?ut, if necessary to comply with law orcustom, MFRS (as nominee for Lender and Lender's successors and
assigns) has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell
the Prope ; and to take any action required of Lender including, but not limited to, releasing and canceling this
Security Instrument.
IntIW. J ? 1r ,
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DDS-6PA
BKI944PG0909
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to
mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record.
Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any
encumbrances of record.
TI [IS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with
limited variations by jurisdiction to constitute a uniform security instrument covering real property.
UNIFORM COVENANTS. Borrower and Lendercovenant and agree as follows:
1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Burrower shall pay
when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late charges
due under the Note. Borrower shall also pay funds for Escrow items pursuant to Section 3. Payments due under the Note
and this Security Instrument shall be trade in U.S. currency. However, if any check or other instrument received by
Lender as payment under the Note or this Security instrument is returned to Lender unpaid, Lender may require that any
or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following
forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's
check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency,
instrumentality, or entity; or (d) Electronic Funds'Transfcr.
Payments are deemed received by Lender when received at the location designated in the Note or at such other
location as may be designated by Leader in accordance with the notice provisions in Section 15. Lender may return any
payment or partial payment if the payment or partial payments are insufficient to bring the Loan current. Lender may
accept any payment or partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or
prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such
payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled duc date, then
Lcndcr need not pay interest on unapplicd funds. Lender may hold such unapplicd funds until Borrower makes payment
to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such
funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance
under the Mote immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future
against Lender shall relieve Borrower from making payments due under the Note and this Security Instrument or
performing; the covenants and agreements secured by this Security Instrument.
2. Apolication of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted
and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal
due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the
order in w*h it became due. Any remaining amounts shall be applied first to late ehargc-.N, second to any other amounts
due under this Security Instrument, and then to reduce the principal balance of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which include a sufficient amount
to pay any late charge due, the payment may be applied to the delinquent payment and the late charge. If more than one
Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of' the
Periodic Payments if, and to the extent that, each payment can be paid in full.
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To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments,
such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment
charges and then as described in the Note.
Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall
not extend or postpone the due date, or change the amount, of the Periodic Payments.
3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under the Note,
until the Note is paid in full, a sum (the "Funds") to provide for payment of amounts due for: (a) taxes and assessments
and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b)
Icaschold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Lender
under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of
the payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. These items arc called
"Escrow Itcros." At origination or at any time during the term of the Loan, Lender may require that Community
Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall
be an Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section.
Borrower shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds
for any or all Escrow Items. Lender may waive Borrowers obligation to pay to Lender Funds for any or all Escrow
Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly,
when and where payable, the amounts due for any Escrow items for which payment of Funds has been waived by
Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as
Lender may require. Borrowers obligation to make such payments and to provide receipts shall for all purposes be
deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement"
is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to
pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and
Borrower shall then.be_obligated under Section 9 to repay to.l.cndcr any such amount. Lender may revoke the waiver as
to any or all Escrow Items at any time by a notice given in accordance with Section 15 and, upon such revocation,
Borrower shall pay to Lender all Funds, and in such amounts, that are then required under this Section 3.
Lendet may, at any time, collect and hold Funds in an amount (a) sufficient to permit tender to apply the Funds at
the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESPA.
Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of
future Escrow Items or otherwise in accordance with Applicable Law.
The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity
(including, Lender, if Lender is an institution whose deposits are so insured) or in any Federal Home Loan Bank. Lender
shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge
Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items,
unless Lender pays Borrower interest on the Funds and Applicable Law permits Lender to make such a charge. Unless
an agreement is made in writing or Applicable Law requires interest to be paid on the Funds, Lender shall not be
required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however,
that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the
Funds as required by RESPA.
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If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the
excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA.
Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make
up the shortage in accordance with RE SPA, but in no more than 12 monthly payments. If there is a deficiency of Funds
held in escrow, as defined under RESPA, Lender shall noti fy Borrower as required by RESPA, and Borrower shall pay
to Lender the amount necessary to make up the deficiency in accordance with RFiSPA, but in no more than 12 monthly
payments.
Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any
Funds held by Lender.
4, Charges; Liens. Borrower shall pay all taxes, assessments, charge, fines, and impositions attributable to the
Property which can attain priority over this Security Instrument, leasehold payments or ground rents on the Property, if
any, and Community Association Dues, Fees, and Assessments, i f any. To the extent that these items are Escrow Items,
Borrower shall pay them in the manner provided in Section 3.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a)
agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender, but only so long
as Borrower is performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the
lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those
proceedings are pending, but only until such proceedings are concluded; or (c) secures from the holder of the lien an
agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part
of the Property is subject to a lien which can attain priority over this Security Instrument, bender may give Borrower a
notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or
take one or more of the actions set firth above in this Section 4.
Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting service used
by Lender in connection with this Loan.
5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property
insured against loss by fire, hazards included within the term "extended coverage," and any other hazards including, but
not limited to, earthquakes and floods, for which Lender requires insurance. This insurance shall be maintained in the
amounts (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the
preceding sentences can change during the term of the Loan. The insurance carrier providing the insurance shall be
chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised
unreasonably. Lender may require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood
zone determination, certification and tracking services; or (b) a one-time charge for flood zone determination and
certification services and subsequent charges each time remappings or similar changes occur which reasonably might
affect such determination or certification. Borrower shall also be responsible for the payment of any feces imposed by
the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting
from an objection by Borrower.
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If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage, at
Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of
coverage. "Therefore, such coverage shall cover Lender, but might or might not protect Borrower, Borrowee, equity in
the Property, or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser
coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained
might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender
under this Section 5 shall become additional debt of Borrower secured by this Security Instrument. "These amounts shall
bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from
Lender to Borrower requesting payment.
All insurance policies required by Lender and renewals of such policies shall be subject to I.cndce.; right to
disapprove such policies, shall include a standard mortgage clause, and shall name Lewder as mortgagec and/or as an
additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender requires,
Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any
form of insurance coverage, not otherwise required by Lender, for damage to, or destruction of, the Property, such
policy shall include a standard mortgage clause and shall name Lcnderas mortgagee and/or as an additional loss payee.
In the event of loss. Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof
of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, any insurance
proceeds, whether or not the underlying insurance was required by Lender, shall be applied to restoration or repair of
the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such
repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an
opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such
inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single
payment or in a series of progress payments as the work is completed. Unless an agreement is made in writing or
Applicable Law requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower
any interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not
be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not
economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums
secured by this Security Instrument, whether or not then due, with the excess, if any, paid to BOrrower. Such insurance
proceeds shall be applied in the order provided for in Section 2.
If Borrower abandons the Property, [.ender may file, negotiate and settle any available insurance claim and related
matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to
settle a claim, then Lender may negotiate and settle the claim. The 30-day period will begin when the notice is given. In
either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a)
Borrower's' rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this
Security Instrument, and (b) any other of Borrower's rights (other than the right to any refund of unearned premiums
paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the
coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay
amounts unpaid under the Note or this Security Instrument, whether or not then due.
i
40 8A(PA? t°sa°j
DDS-6PA
inmais =i_
Paps I d t B Form 3039 1101
BK 1944PG091 3-
6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within 60
days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal
residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent
shall not be unreasonably withheld, or unless extenuating circumstances exist which arc beyond Borrowees control.
9. Preservation, Maintenance and Protection of the Property; Inspections. Borrowershall not destroy, damage
or impair the Property, allow the Property to deteriorate or commit waste on the Property. Whether or not Borrower is
residing in the Property. Borrower shall maintain the Property in order to prevent the Property from deteriorating or
decreasing in value due to its condition. Unless it is determined pursuant to Section S that repair or restoration is not
economically feasible, Borrower shall promptly rerrair the Property if damaged to avoid further deterioration or
damage. If insurance or condemnation proceeds are paid in connection with damage to, or the taking of, the Property,
Borrower shall be responsible for repairing or restoring the Property only if Lender has released proceeds t'or such
purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress
payments as the work is completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the
Property, Borrower is not rel ieved of Borrower's obligation for the completion of such repair or restoration.
Lender or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable cause,
Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the time of
or prior to such an interior inspection specifying such reasonable cause.
8. Borrower's Loan Application. Borrower shall be in default if, during the Loan application process, Borrower
or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent gave materially
false, misleading, or inaccurate information or statements to Lender (or failed to provide Lender with'rnaterial
information) in connection with the loan. Material representations include, but arc not limited to, representations
concerning Borrower's occupancy of the Property as Borrower's principal residence.
9. Protection of Lender's Interest in the Property and Rights Under this Security Instrument. lf(a) Borrower
fails to perform the covenants and agreements contained in this Security Instrument, (b) there is a legal proceeding that
might significantly affect Lender's interest in the Property and/or rights under this Security Instrument (such as a
i proceeding in bankruptcy, probate, for condemnation or forfeiture, for enforcement of a lien which may attain priority
over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned the Property, then
Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest in the Property and rights
under this Security Instrument, including protecting and/or assessing the value of the Property, and securing and/or
repairing the Property. Lender's actions can include, but are not limited to: (a) paying any sums secured by a lien which
has priority over this Security Instrument; (b) appearing in court; and (c) paying reasonable attorneys' fees to protect its
interest in the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy
proceeding. Securing the Property includes, but is not limited to, entering the Property to make repairs, change locks,
replace or board up doors and windows, drain water from pipes, eliminate building or other code violations or
dangerous conditions, and have utilities turned on or off. Although Lender may take action under this Section 9, Lender
does not have to do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not
taking any or all actions authorized under this Section 9.
I,
dft b d3A(PA? (o5w
DDS-6PA
I.
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PagsE of 16 Form 3039 1101
BK 1944PG09 14
Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this
Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be
payable, with such interest, upon notice from Lender to Borrower requesting payment.
If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower
acquires fee title to the Property, the leasehold and the fec title shall not merge unless Lender agrees to the merger in
writing.
10. Mortgage Insurance. If Lender required Mortgage insurance as a condition of making the Loan, Borrower
shall pay the premiums required to maintain the Mortgage Insurance in effect. It; for any reason, the Mortgage
Insurance coverage required by Lender ceases to be available fmm the mortgage insurer that previously provided such
insurance and Borrower was required to make separately designated payments toward the premiums for Mortgage
Insurance, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage
Insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance
previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage
Insurance coverage is not available, Borrower shall continue to pay to Lender the amount of the separately designated
payments that were due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these
payments qs a non-refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be non-refundable,
notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower any
interest or earnings on such loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance
coverage (in the amount and for the period that Lender requires) provided by an insurer selected by Lender again
becomes available, is obtained, and Lender requires separately designated payments toward the premiums for
Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was
required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the
premiums required to maintain Mortgage insurance in effect, or to provide a non-refundable loss reserve, until Lender's
requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and Lender
providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects
Borrower's obligation to pay interest at the rate provided in the Note.
Mortgage Insurance reimburses Lender (or any entity that purchases the Neste) for certain losses it may incur if
Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter into
agreements with other parties that share or modify their risk, or reduce losses. 'T'hese agreements are on terms and
conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements. "[hose
agreements may require the mortgage insurer to make payments using any source of funds that the mortgage insurer
may have available (which may include funds obtained from Mortgage Insurance premiums).
As a result of these agreements, Lender, any purchaser of the Note, another insurer, any rcinsurcr, any other entity,
or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive from (or might be
characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange for sharing or modifying the
mortgage insurer's risk, or reducing losses. If such agreement provides that an affiliate of Lender takes a share of the
insurer's rink in exchange for a share of the premiums paid to the insurer, the arrangement is often termed "captive
reinsuranceh" Further:
(a) An such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage
Insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will owe for
Mortgage insurance, and they will not entitle Borrower to any refund.
enmais m
®-6A(PA? (05001 Paps 3 of t8 Form 3039 1101
DOS OPA
I
un ! 944I,G09 15
(b) Any such agreements will not affect the rights Borrower has - if any - with respect to the Mortgage
Insurance under the Homeowners Protection Act of 1998 or any other law. 't'hese rights may include the right to
receive certain disclosures, to request and obtain cancellation of the Mortgage Insurance, to have the Mortgage
Insurance terminated automatically, and/or to receive a refund of any Mortgage Insurance premiums that were
unearned at the timeof such cancellation or termination.
11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds arc hereby assigned to and
shall be paid to Lender.
If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if
the restoration or repair is economically feasible and Lenders security is not lessened. During such repair and
restoration period, Lender shall have the right to hold such Miscellancous Proceeds until Lender has had an opportunity
to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection
shall be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursement or in a series of
progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires
interest to be paid on such Miscellaneous Proceeds, Lender shall not be required to pay Borrower any interest or
earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security
would be lessened, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument,
whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be applied in the
order provided for in Section 2.
In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall be
applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to
Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the
Property immediately before the partial taking, destruction, or loss in value is equal to or greater than the amount of the
sums secured by this Security Instrument immediately before the partial taking, destruction, or loss in value, unless
Borrower and Lender otherwise agree in writing, the sums secured by this Security instrument shall be reduced by the
amount of the Miscellaneous Proceeds multiplied by the following fraction: (a) the total amount of the sums secured
immediately before the partial taking, destruction, or loss in value divided by (b) the fair market value of the Property
immediately before the partial taking, destruction, or loss in value. Any balance shall be paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the
Property immediately before the partial taking, destruction, or loss in value is less than the amount of the sums secured
immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in
writing, that Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether or not the
sums are thicn due.
If the property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing Party (as
defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to respond to Lender
within 34 days after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceeds
either to restoration or repair of the Property or to the sums secured by this Security instrument, whether or not then due.
"Opposing Party" means the third party that owes Borrower Miscellaneous Proceeds or the party against whom
Borrower has a right of action in regard to Miscellancous Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in Lenders
judgment, could result in forfeiture of the Property or other material impairment of Lender's interest in the Property or
rights under this Security Instrument.
M441s
f?4A(Pl l mwa) Payo :am 16 Form 3039 1101
DDS•6PA
BK 1944P6091 6
Borrower can cure such a default and, if acceleration has occurred, reinstate as provided in Section 19, by causing the
action or proceeding to be dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or
other malcrial impairment of l.cnder's interest in the Property or rights under this Security Instrument. The proceeds of
any award or claim for damages that arc attributable to the impairment of Lcndet's interest in the Property are hereby
assigned and shall be paid to Lender-
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in the order
provided for in Section 2.
12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or
modification of amortization of the sums secured by this Security instrument granted by Lender to Borrower or any
Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of
Borrower. Lender shall not be required to commence proceedings against any Successor in Interest of Borrower or to
refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by
reason of any demand made by the original Borrower or any Successors in Interest of Borrower. Any fbrbeardnce by
Lender in exercising any right or remedy including, without limitation, Lender's acceptance of payments from third
persons, entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver
of or preclude the exercise of any right or remedy.
13. Joint and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants and agrees
that Borrower's obligations and liability shall be joint and several. However, any Borrower who co-signs this Security
Instrument but does not execute the Note (a "co-signer"): (a) is co-signing this Security Instrument only to mortgage,
grant and convey the co-signet's interest in the Property under the terms of this Security Instrument; (b) is not
personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other
Borrower can agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security
Instrument or the Note without the co-signer's consent.
Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrowees obligations
under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's rights and benefits
under this Security Instrument. Borrower shall not be released from Borrower's obligations and liability under this
Security Instrument unless Lender agrees to such release in writing. Thc covenants and agreements of this Security
Instrument shall hind (except as provided in Section N)) and benefit the successors and assigns of Lender.
14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's
default, for the purpose of protecting Lenders interest in the Property and rights under this Security Instrument,
including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the
absence ofexpress authority in this Security Instrument to charge a specific fee to Borrower shall not be construed as a
prohibition on the charging of such fee. Lender may not charge fees that are expressly prohibited by this Security
Instrument or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the
interest orother loan charges collected or to be collected in connection with the Loan exceed the permitted limits, then:
(a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b)
any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may
choose to Onake this refund by reducing the principal owed under the Note or by making a direct payment to Borrower.
If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge
(whether or not a prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made
by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such
overcharge.
I In.7ab
Q?AIPA) 105-) Page 't of ie Form 3039 1101
DDS-GPA
9K 1944PGO9 17
15. Notices. All notices given by Borrower or lender in connection with this Security instrument must be in
writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have been given to
Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if sent by other
means, No(ice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requires
otherwise. The notice address shall be the Property Address unless Borrower has designated a substitute notice address
by notice to Lender. Borrower shall promptly notify Lender of Borrower's change of address. If lender specifics a
procedure tor reporting Borrower's change of address, then Rorrower xhal I only report a change of address through that
specified pjroccdure. There may be only one designated notice address under this Security Instrument at any one time.
Any notice to Lender shall he given by delivering it or by mailing it by first class mail to Lender's address stated herein
unless Leader has designated another address by notice to Borrower. Any notice in connection with this Security
Instrumcntlshall not be deemed to have been given to Lender until actually received by Lender. If any notice required by
this Security instrument is also required under Applicable Law, the Applicable Law requirement will satisfy the
corresponding requirement under this Securi ty Instrument.
16. Governing Law; Severability; Rules of Construction. T his Security Instrument shall be governed by federal
law and the law ofthe jurisdiction in which the Property is located. All rights and obligations contained in this Security
Instrument are subject to any requirements and limitations of Applicable Law. Applicable Law might explicitly or
implicitly allow the parties to agree by contract or it might be silent, but such silence shall not be construed as a
prohibition, against agreement by contract. In the event that any provision or clause of this Security Instrument or the
Note conflicts with Applicable Law, such conflict shall not affect other provisions of this Security instrument or the
Note which can be given effect without the conflicting provision.
As used in this Security Instrument: (a) words of the masculine gender shall mean and include corresponding neuter
words or words of the feminine gender, (b) words in the singular shall mean and include the plural and vice versa; and
(e) the word "may" gives sole discretion without any obligation to take any action.
17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument.
IS. Transfer of the Property or a Renefreial Interest in Borrower. As used in this Section 18, "Interest in the
Property" means any legal or beneficial interest in-the Property, including, but not limited to, those beneficial interests
transferred in a bond for decd, contract for decd, installment sales contract or escrow agreement, the intent of which is
the transfer of title by Borrower at a future date to a purchaser.
If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural
pcnon and a beneficial interest in Borrower is sold or transferred) without Lendces prior written consent, Lender may
require immediate payment in full of all sums secured by this Security Instrument. I lowever, this option shall not be
exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. 'ncc notice shall provide a period
of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay
all sums secured by this Security Instrument. if Borrower tails to pay these sums prior to the expiration of this period,
Lcnderrnay'imoke any remedies permitted by this Security Instrument without furthernotice or demand on Borrower.
14. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower shall
have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of.. (a) five
days before sale of the Property pursuant to any power of sale contained in this Security Instrument; (b) such other
period as Applicable Law might specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment
enforcing this Security instrument.
mae?
-tiA(PA tosoei °a9"7a'e Form 3039 1101
DDS-611A
SK i 944PG09 18
.
Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument
and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all
expenses incurred in enforcing this Security Instrument, including,-but not limited to, reasonable attorneys' fees,
property it{rspection and valuation fees, and other fees incurred for the purpose of protecting Lender's intcmt in the
Property and rights underthis Security Instrument; and (d) takes such action as Lender may reasonably require to assure
that Lenders interest in the Property and rights under this Security Instrument, and Borrowers obligation to pay the
sums secured by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such
reinstatement sums and expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money
order; (c) Certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an
institution whose deposits arc insured by a federal agency, instrumentality or entity; or (d) Electronic Funds'rransfcr.
Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall remain fully effective
as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under
Section 18,
20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the Note
(together with this Security Instrument) can be sold one or more times without prior notice to Borrower. A sale might
result in a hangc in the entity (known as the "Loan Scrvicer") that collects Periodic Payments due under the Note and
this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security
Instrument, and Applicable Law. There also might be one or more changes of the Loan Servicer unrelated to a sale of
the Note. Inhere is a change of the Loan Scrvicer, Borrower will be given written notice of the change which will state
the name tend address of the new Loan Scrvicer, the address to which payments should be made and any other
information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the
Loan is serviced by a Loan Scrvicer other than the purchaser of the Note, the mortgage loan servicing obligations to
Borrower will remain with the Loan Scrvicer or be transferred to a successor Loan Scrvicer and are not assumed by the
Note purchaser unless otherwise provided by the Note purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual
litigant or the member of a class) that arises from the other party's actions pursuant to this Security Instrument or that
alleges that the other party has breached any provision of, or any duty owed by reason of, this Security Instrument, until
such Borrower or Lender has notified the other party (with such notice given in compliance with the requirements of
Section 15) of such al lcgcd breach and afforded the other party hereto a reasonable period after the giving of such notice
to take corrective action. If Applicable law provides a time period which must elapse before certain action can be
taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and
opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower pursuant
to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section
20.
21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances defined
as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the following substances: gasoline,
kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials
containing asbestos or formaldehyde, and radioactive materials; (b) "Environmental Law" means federal laws and laws
of the jurisdiction where the Property is located that relate to health, safety or environmental protection; (c)
"fnvironmiental Cleanup" includes any response action, remedial action, or removal action, as defined in
F.nvironmotal Law; and (d) an "Environmental Condition" means a condition that can cause, contribute to, or
otherwise Nigger an Environmental Cleanup.
~Wb?
???P Il? ° 13of 16 Fortn3039 7101
DDS-6PA
SK 1944PG09 19
Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances, or
threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do, nor allow anyone clsc to do,
anything affecting the Property (a) that is in violation of any Environmental Law, (b) which creates an Environmental
Condition, or(c) which, due to the presence, use, or release of a Hazardous Substance, creates a condition that adversely
affects the value of the Property. The preceding two sentences shall not apply to the presence, use, or storage on the
Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal
residential uses and to maintenance of the Property (including, but not limited to, hazardous substances in consumer
products).
Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit or other action
by any goj cmmental or regulatory agency or private party involving the Property and any Hazardous Substance or
Environmental Law of which Borrower has actual knowledge, (b) any Environmental Condition, including but not
limited to any spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any
condition caused by the presence, use or release of a l lazardous Substance which adversely affects the value of the.
Property. If Borrower (cams, or is notified by any governmental or regulatory authority, or any private party, that any
removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly
take all necessary remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation
on LenderfPoran linvironmental Cleanup.
NON-UNIFORM COVENANTS. Borrower and Lender furthcrcovcnant and agree as follows:
22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's
breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under Section IS
unless Applicable Law provides otherwise). !Lender shall notify Borrower of, among other things: (a) the
default; (4) the action required to cure the default; (c) when the default must be cured; and (d) that failure to
cure the default as specified may result in acceleration of the sums secured by this Security Instrument,
foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to
reinstate 0:fter acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or
any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at
its option may require immediate payment in full of all sums secured by this Security Instrument without
further.demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to
collect all expenses incurred in pursuing the remedies provided in this Section 22, including, but not limited to,
attorneys" fees and costs of title evidence to the extent permitted by Applicable Law.
23. Release. Upon payment ofall sums secured by this Security Instrument, this Security Instrument and the estate
conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security
Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security
Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under
Applicable Law .
24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or defects in
proceedings to enforce this Security Instrument, and hereby waives the benefit ofany present or future laws providing
for stay of execution, extension oftimc, exemption from attachment, levy and sale, and homestead exemption.
15. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the
commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument.
26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is.lent to Borrower to
acquire titla to the Property, this Security Instrument shall be a purchase money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on
the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note.
i
I
:,-halt
-GA(P }(osoa) rbgnaof,6 ?s ?
40m Form 3039 1101
UDS-6)'A
BK ! 944 PGO920
f
BY SIGNING BELOW, Borrower accepts and agrees to the tcrms and covenants contained in this Security
Instrument and in any Rider executed by Borrower and rccordcd with it.
Witnesses:
(Scat)
v _AN F. MILLER -Borrower
(Seal)
. Borrower
_ (Seal) (Seal)
- Ronower -Borrower
(Seal)
- Borrower
I
-6A(P ) 105081
DDS.611A
8K 1 944PGO92 I
Pop 15 of is
_ (Seal)
-Borrower
_ (Scat) (Seal)
- Borrower -Borrower
Form 3039 1101
COMMONWEALTH OF PENNSVI.VANIA,
On this, the f 17 q+1 day of
under;ignCd officer, personally appeared
ad UCo
County ss:
before me, the
r.
known to me (or
satisfaprovcn) to be the person(s) whose name( i. re subscribed to the within instrument and acknowledged
that h ha/t cy executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official scat.
My Commission Expires:
COMWWRAIH OF PENNSYLVANIA
NOTARIAL SEAL
DANIEL M. HARTMAN. Notary Public
lzhw , _AjyL
New Cumbbe?rrland 8oro., Cumberland Co. T ticar0rflcer
My Commission Expires Jan. 21, 2009
Certificate of Residence
1, u / V • do hereby certify that
the correct address of the within-named Mortgagee is P.U. Box 2026, Flint, M148501-2026.
Witness my hand this / 71'?-
I
-6A(P4) (owe)
DDS.6PA
day of IIAVZ-1 ' v ?6
Agent ofMortgagee
Inrbp;S
PBae76of+e Form3039 1101
BKI944PGO922
LEGAL DESCRIPTION
l3- 1
sZrtc.:+er of Deeds
All THAT CERTAIN lot or An of land situate In the brp* of New Cumbcdeed, Cwtp of
Cat6arland and State of Pennt*anla, botntded and described as follow.
BUMMIG at a Point oa the North m One of Herding Street; :8111 point bet one Hur*W MY.
five 11551 feet In an Easterly direction from Maple Street; thsnce In a Northe ty diraction along a
Iltte pardlel with Ala* $tim fine Hundred Thirty (130) feet to a Twrenty (201 foot alhry: thonr:e in
a WesWy 0ectbn alagl tb8 Southem fine of said Twenty 130) foot aitelt, " 1501 feet to a
point; thOlm in a Southerh direction done a fine pareld with Mapla Street, One Hwtdred Thirty
(130) hot to Hu tl Street; tbence In an Easterly directioe along the Northern line of Martine
Street Arty (50) feet to the Place of BEGINNING.
BEING At Western Forty-fnre 145) feet of tot No. 114, Section Z and dd Eastem Fhm IM feK of
lot No. 1115. Section 2. of a Fla of LoU known as Cwnberfand Mmw, saW Plan being m orded in
the Record's Office at Caesle, PA, in Phan Book 2, page 73.
BEING THE SAME PREMISES WHICH Frances E. Fales, widow, by her
Attorney-in-Fact Deborah E. Pajak, by her Deed dated January 12,
2009, and recorded in the Office of the Recorder of Deeds in and
for Cumberland County, Pennsylvania, on January 13, 2004, in Deed
Book 2161, Page 1297, granted and conveyed unto Kristin L. Drum,
single woman.
ALSO BEING THE SAME ISES ICH Kristin L. Drum, single woman,
by her Deed dated , 2006, and about to be
recorded in the Off ce of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, granted and conveyed unto Jean
Miller Mortgagor herein.
BK 1944PG0923
EXHIBIT `B'
Prepared By:
Law Offices of Gregory Javardian
1310 Industrial Blvd., Ste. 101 Op2?3V
Southampton, PA 18966
Return to:
Law Office' of Gregory Javardian
1310 Industrial Blvd., Ste. 101
Southampton, PA 18966
CPN (UPI) 26-23-0543-081
ASSIGNMENT OF MORTGAGE
FOR VALUE RECEIVED, the receipt and sufficiency of which is hereby acknowledged,
the undersigned:
hereby sells, transfers, assigns, coveys and sets over to:
U.S. BAND NA ND
its successors, representatives and assigns, all its rights, title and interest in that certain Mortgage
executed by Jean F. Miller dated March 17, 2006 and recorded March 22, 2006 in book 1944 page
907 in the Office of Recorder of Deeds of Cumberland County, Pennsylvania.
Property: 525 Harding Street, New Cumberland, PA 17070
Mortgage Amount: $124,720.00
TOGETHER WITH THE REAL PROPERTY therein described and the indebtedness thereby
secured, having this date sold to the therein named assignee, the Note or Notes secured by said
Mortgage.
LEGAL DESCRIPTION i'A
r Of Deeds
ALL THAI CERTAIN lot or pie;e of land *u% In the Barouslr of New Cw&,,dand, Eoaty of
trntsb dmhd and State of Penns*anfa, bounded ad di Scribed a3 follaw.
.
B?BIAlIiSf?6 at a point an the Northern One of Herding Stress; said point being One Hundred rrfty-
five V 1551 feet In an Easterly &radon from Maple Street; thence In a Northam dimctioe along e
line perm with Maps Strom Qne Hundred Thirty V 301 test to a Tarty (20) foot alley; thence in
a Westy* direction Wong tttie Souttrem tine of said Twenty (20) foot aileyr,"150) feet to a
Point; thOm in a Sartherlr direction along a fine p'araQPl with Maple Street One Hundred Thirty
1130) feet to Harding St ass thi mee In an Easterly direction DIM the Norttrern line of Harding
Street #1i (50) feet to the Piece of BEGINNIN(j.
BEING the Wagam Forty-free (46) feet of tot No. 114, Section 2, acrd the Eastem FIVe M feet of
Lot No. 116. Section 2, of a Fla of Lou known as Sumberfand Mwor, Said Plan being reeordad in
the RecordW3 Office at Carfisle, PA, In Plan Book 2, page 73.
BEING THE SAME PREMISES WHICH Frances E. Fales, widow, by her
Attorney-in-Fact Deborah E. Pajak, by her Deed dated January 12,
2004, and recorded in the Office of the Recorder of Deeds in and
for Cumberland County, Pennsylvania, on January 13, 2004, in Deed
Book 261, Page 1297, granted and conveyed unto Kristin L. Drum,
single woman.
ALSO B ING THE SAME ICH Kristin L. Drum, single woman,
by her Deed dated , 2006, and about to be
recorde in the Off ce ?ofS?the Recorder of Deeds in and for
Cumberlland County, Pennsylvania, granted and conveyed unto Jean
Miller,IMortgagor herein-
I
BK 1944PGO923
TO EXERCISE the said rights, powers and privileges set forth therein in as full as a manner as the
undersigned is authorized to exercise the same.
IN WITNESS WHEREOF, the undersigned has caused this instrument to be signed in its behalf by
its duly aut4orized officers and caused its Corporate seal to be affixed this day
of r.%c , 2010.
MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC. (MFRS), AS NOMINEE FOR
WILMINGTON FINANCE, INC.
Name:-
Title:
STATE OF
COUNTY OF
BEFORE ME, the undersigned authority, on this day personally appeared
??
known to me to be the person and officer whose name is subscribed to the foregoing instrument and
acknowledged to me that the same was the act of the said MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, INC. (MERS), AS NOMINEE FOR WILMINGTON FINANCE,
INC., a Co oration and that he executed the same as the act of such corporation for the purposes
and consideration there in expressed, and in the capacity therein stated.
GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the
DNL , 2010.
My Commission Expires:
I hereby certify that the address of the assignee is:
205 W. 4' Street
Suite 500
Cincinatti, H 45202
d '!? day of
ROBERT HAMBERG
Notary NbUr., State 01 ONO
MY CommissM Ea INS
Mar& 24, 2015
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201019054
Recorded On 7/15/2010 At 11:07:59 AM
* Instrument Type - ASSIGNMENT OF MORTGAGE
Invoice Number - 69159 User ID - MSW
* Mortgagor - MILLER, JEAN F
* Mortgagee - U S BANK N A
* Customer - GREGORY JAVARDL4dN
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $23.50
JUSTICE
RECORDING FEES - $11.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $50.50
I Certify this to be recorded
in Cumberland County PA
?? c¢ CU O
RECORDER,OF 2D
?7so
* Total Pages - 4
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
iuuiaiufliidugiu
EXHIBIT `U
M ?
a, it
`
SEE TREPAYMENT RIDER TO NOTE' ATTACHED HERETO AND MADE A PART HEREOF.
Loan Number:: MIN: 100372406032303015
NOTE
March 17, 2006 NEW CUMBERLAND Pennsylvania
[Date] [city] [statel
525 HARDING STREET
NEW CUMBERLAND, PA 17070
[Prop-yAddr-l
1. BORROWER'S PROMISE TO PAY
In return for a loanthat I have received, I promise to pay U.S. $ 124,720.00 (this amount is called "Principal"),
plus interest, to the order of the Lender. The Lender is
Wilmington Finance, Inc.
I will make all payments under this Note in the form of cash, check or money order.
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is
entitled toreceivepayments under this Note is called the "Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate
of 7.500%.
The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of
this Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making a payment every month.
I will make my monthly payment on the l at day of each month beginning on May 1, 2006 1 will
make these payments every month until I have paid all of the principal and interest and any other charges described below that I
may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest
before Principal. If, on April 1, 2036 ,1 still owe amounts under this Note, Iwill pay those amounts in fill on
that date, which is called the "Maturity Date."
I will make my monthly payments at PO Box 209
Plymouth Meeting, PA 19462 or at a different place ifrequired by the Note Holder.
(B) Amount ofMonthly Payments
My monthly payment will be in the amount of U.S. $ 872.06
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a
"Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a
payment as a Prepayment if I have not made all the monthlypsyments due underthe Note.
I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my
Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment
to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of
the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless
the Note Holder agrees in writing to those changes.
MULTISTATE FIXED RATE NOTE-Single Family-Fannie MaelFredttle Mae UNIFORM INSTRUMENT
at-SNP207i Form 32001/01
VMPM0RrGAGEr0RM3-(800)521-7291
P"p 1 d3 Wtl94:
DDS-CN3
40 40
5. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other
loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge
shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me
which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refimd by reducing the
Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated
as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days
after the date it is due, I will pay a late charge to the Note Holder. The amount ofthe charge will be 5.000 % of
my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.
(C) Notice ofDefault
If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount ofPrincipal which has not been paid and all the
interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or
delivered by other means.
(D) No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above,
the Note Holder will still have the right to do so if l am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be
paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those
expenses include, for example, reasonable attomeye fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be. given to me tinder this Note will be given by
delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note
Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class
mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice ofthat different
address.
S. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, eachpersoa is frilly and personally obligated to keep all of the promises made in this
Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also
obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or
endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights
under this Nate against each person individually or against all of us together. This means that any one of us may be required to
pay all of the amounts owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor.
"Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the
right to require the Note Holder to give notice to other persons that amounts due have not been paid.
Form
o=
-SH lv?w) P6982013
DDS?.Tt3 '
10. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the
Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"), dated the same date as
this Note, protects the Note Holder frorn possible losses which might result if I do not keep the promises which I make in this
Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full
of all amounts I owe under this Note. Some of those conditions are described as follows:
If all or any pan ofthe property or any Interest in the property is sold or transferred (or if Borrower is not a
natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written
consent, Lender may require immediate payment in full of all sums secured by this Security Instrument.
However, this option shall not be exercisedby Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall
provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within
which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums
prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument
without further notice or demand on Borrower.
W]TNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED.
/ /- 0, //w - (Seal)
F. MILLER -Borrower
_ (Seal)
-Borrower
_ (Seal}
-Borrower
(Seat)
-Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
_ (Seal)
-Harrower
(Seal)
-Borrower
[sign OriginaIOnly J
4k-5N 10207) Pag.W3 Form 32001/01
DDS-CN3 '
4
PREPAYMENT RIDER TO NOTE
Loan No.: ?
TheNotedated March 17, 2006 between
Wilmington Finance, Inc.
JEAN F. MILLER
is hereby amended as follows:
(Borrower or l)
I. Additional Covenants. Notwithstanding anything to the contrary set forth in the Note or Security Instrument,
Borrower and Lender covenant, and agree, that the provisions of the section of the Note entitled "BORROWER'S RIGHT TO
PREPAY" or "BORROWER'S PAYMENTS BEFORE THEY ARE DUE" are amended to read as follows:
Subject to the Prepayment Penalty provided below, I have the right to make payments of Principal at any time before
they are due. A payment of Principal only is known as a "Prepayment." A "Full Prepayment" is the prepayment of the entire
unpaid Principal due under the Note. A payment of only part of the unpaid Principal is known as a "Partial Prepayment." When I
make a Prepayment, I will tell the Note Holder in writing that I on doing so. I may not designate a payment as a Prepayment if I
have not made all the monthly payments due under the Note.
If, within the 36 month period beginning with the date I execute the Note (the "Penalty Period "), I
make a Full Prepayment, or Partial Prepayment in any twelve (12)-month period that exceeds 10% of the original
Principal loan amount, I will pay a Prepayment charge as consideration of the Note Holder's acceptance of such
Prepayment. The Prepayment charge will equal 5.000% of the then Principal balance ofthe Note. No
Prepayment charge will be assessed for any Prepayment occurring after the Penalty Period.
The Rider will remain in full force and effect unless the Note is transferred by Lender and the Borrower is notified in
writing by the new Note Holder that such Note Holder, at its sole option, has declared the Rider null and void. If the Rider is
declared null and void, the original Note terms shall remain in full force and effect.
(' r 1 (Seal) (Seal)
-Borrower -Borrower
F. MILLER
_ (Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
_ (Seal) (Seal)
-Borrower -Borrower
DDS-BAF
(Lender) and
(03/03)
EXHIBIT `D'
(Rev. 9/2008)
ACT 91 NOTICE
CAKE ACTION TO SAVE
t YOUR HOME FROM
FORECLOSURE
Date: June 1, 2010
JEAN F. MILLER .
525 HARDING STREET
NEW CUMBERLAND, PA 17070
This is an official notice that the mortgage on your home is in default and the lender intends to foreclose
Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP„)may be able to
help to save your Lome. This Notice explains how the program works. To see if HEMAP can help, you must
MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF
THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR ENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION ??ENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCLA QPE S _ VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "I i WNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR s CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
This notice cuntaij is 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 fmd a lawyer.
'HOMEOWNER'S NAME(S): JEAN F. MILLER
PROPERTY ADDRESS: 525 HARDING STREET, NEW CUMBERLAND, PA 17070
LOAN ACCOUNT NUMBER:
ORIGINAL LENDER: MERS, AS NOMINEE FOR WILMINGTON FINANCE,
INC.
CURRENT LENDER/SERVICER: U.S. BANK, N.A. ND
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY,, WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY S]CAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your! mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing).
During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-
THREE 33 DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY
MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit
counseling agencie$ 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 a encie$ 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). You have the
right to apply for fiirancial 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 a encies have applications for the program and they will assist you in submitting a complete
application to the P nnsylvania Housing Finance Agency. To temporarily stop the lender from filing a
foreclosure action, our application MUST be forwarded to PHFA and received within thirty (30) days of your
face-to-face meetin with the counseling agency.
TOU SHOULD FILE A HEMAPAPPLICATIONAS SOONAS POSSIBLE. IF YOUHAVEA MEETING
WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE
AND FILE ANA1#PLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE
LENDER WILL BE TEMPORARILYPREVENTED FROMSTARTINGA FORECLOSUREAGAINST
YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF
FORECLOSURE":
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSUREACTION, BUT IF YOUR APPLICATIONIS EVENTUALLYAPPROVED ATANY
TIME BEFORE A' SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You
will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING, PART OF THIS NOTICE IS FOR INFORMATION PURPOSES
ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(HF YOU HAVE FIXED BANKRUPTCY YOU CAN STILL APPLY FOR EMERGENCY MORTGAGE ASSISTANCE.)
HOVE TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO DATE).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located
at: 525 HARDING STREET, NEW CUMBERLAND, PA 17070 is SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due from 11/1/09 through 6/1/10 in the amount of $1,077.42 per month:
Monthly Payments Plus Late Charges Accrued: $8,924.56
BPO/Appraisal: $95.00
Advances/Escrow: $941.66
(Suspense) ($0.00)
TOTAL AMOUNT TO CURE DEFAULT $9,961.22
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable.)
HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING
THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $9,961.22, PLUS ANY MORTGAGE PAYMENTS AND
LATE CHARGES WHICH MAY BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by
cash cashier's check, certified check or money order made payable and sent to: US Bank, N.A., 205 West Fourth Street, Cincinnati,
OH 45202. Contact: Kelly Rothert
You can cure any oer default by taking the following action within. THIRTY (30) DAYS of the date of this
letter. (do not use i not applicable.)
IF YOU DO NOT URE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the
date of this Notice, he lender intends to exercise its rights to accelerate the mortgage debt. This means that
the entire outstand' g balance of this debt will be considered due immediately and you may lose the chance to
pay the mortgage in monthly installments. If full payment of the total amount past due is not made within
THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon
your mortgaged orfonertv.
IF YOUR MORTGAGE IS FORECLOSED UPON - The Mortgaged property will be sold by the Sheriff to
pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees
that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have
to pay all the 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.
fees.
OTHER LENDE REMEDIES - The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure
costs
Curing your default in the
manner set forth in this notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs
sale of the mortgag d property could be held would be approximately NINE (9) months from the date of this
Notice. A notice of the actual date of the Sheriffs sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what
the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER -
UPS Bank, N.A.
215 West Fourth Street
C' cinnati, 01145202
Tel.: (513) 639-6540
A?tention: Kelly Rothert
EFFECT OF SHE FF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a
lawsuit to remove y u and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION O MORTGAGE - You _ may or XX may not sell or transfer your home to a buyer or
transferee who will sume the mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and osts are paid prior to or at the sale and that the other requirements of the mortgage are
satisfied.
A
ri
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF
• TO HAVE HE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCC D, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THE
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR
YEAR).
• TO ASSER THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEED G OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE NDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Very truly yours,
Gregory ,7avard-an
LAW OFFICES OF GREGORY JAVARDIAN
ATTORNEY FOR FENDER
CC: PENNSYLVANIA HOUSING FINANCE AGENCY - VIA EMAIL - Act9l @phfa M
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED
THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C § 1692 et seq. (1977),
DEFENDANT(S)1WIAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF
DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN
VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE,
IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL,SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR,
IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD
FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN
THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN
THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME.
FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE
EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER,
IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL
CIEUI-TOR WI'THr, N THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF' THIS
COMPLAINT, THE' LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR
OTHERWISE) TO'COLLECT THE DEBT UNTIL WE MAIL THE REQI TESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
r
CUMBERLAND COUNTY
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
Community Action Commission of Capital Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Ma-anatlaa
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
message from
Federal Trade Commission
Don't Get Hit by a Pitch.
"We can stop your foreclosure!"
"97% success rate!"
"Guaranteed to save your home!"
These kinds of claims are the tell-tale signs of
a foreclosure rip-off. Steer clear of anyone
who offers an easy out.
Don't Pay for a Promise.
Don't pay any business, organization, or
person Who promises to prevent foreclosure or
get you 4 new mortgage. These so-called
"foreclosure rescue companies" claim they
can help have your home, but they're out to
make a ck buck. Some may request hefty
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calls. Others may string you along before
disclosing their charges. Cut off all dealings if
someone' insists on a fee.
Send Payments Directly.
Some scammers offer to handle financial
arrangements for you, but then just pocket
your payment. Send your mortgage payments
ONLY to your mortgage servicer.
Don't Pay for a Second Opinion.
Have yo# applied for a loan modification and
been turned down? Never pay for a "second
opinion."
Imitations = Frustrations.
Some con artists use names, phone numbers,
and websites to make it look like they're part
of the government. If you want to contact a
government agency, type the web address
directly into your browser and look up any
address you aren't sure about. Use phone
numbers listed on agency websites or in other
reliable sources, like the Blue Pages in your
phone directory. Don't click on links or open
any attachments in unexpected emails.
Talk to a HUD-Certified Counseling
Agency.- For Free.
If you're having trouble paying your mortgage
or you've already gotten a delinquency notice,
free help is a phone call away. Call 1-888-995
-HOPE for free personalized advice from
housing counseling agencies certified by the
U.S. Department of Housing and Urban
Development (HUD). This national hotline -
open 24/7 - is operated by the
Homeownership Preservation Foundation, a
nonprofit member of the HOPE NOW
Alliance of mortgage industry members and
HUD-certified counseling agencies. For free
guidance online, visit v:'ww.hopenow.com.
For free information on the President's plan to
help homeowners, visit
www.maldnghomeaffordable.gov.
V ?„t Federal Trade Commission
` ` ftc.gov/MoneyMatters
.?°,
Facing foreclosure? Scammers are targeting people having trouble paying their mortgages.
Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan
modifications - for a fee. The Federal Trade Commission, the nation's consumer protection
agency, wants you to know how to avoid scams that could make your housing situation go from bad to
worse.
A
Call
1-8(-5 8?995E
for free personalized guidance from housing counseling agencies certified
by the U.S. Department-of Housing and Urban Development. The
Homeowner's HOPETM Hotline -'open 24/7 - is operated by the
Homeownership Preservation Foundation, a nonprofit member of the
HOPE NOW Alliance of mortgage industry members and
HUD-certified counseling agencies. Or visit
www,
For free information on the President's plan to help homeowners, visit
. rncea k inh0% m efforleeov
..a
77% HOP?NOW
Support & Guidance For Homeowners
R ]a WIN WSM
MAKING HOME AFFORDABLE.cov
A
JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
SENDER:
CW
REFERENCEt
MILLER V. US BANK
7160 3820 3530 0
PS Form 3800 January 2 5
0RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
Receipt for
Certified Mail
No Insurance Coverage Pmo
00 Not Use tot husn"wonal Ali
--------------------- ------- --- ---------
793 2070
?' r
ST R t3A 5?;
?U AN ,
? ? ar
---------- --------------- -- -- --
.4
VERIFICATION
The undersigned hereby states that the statements made in the foregoing pleading are true
and correct to the best of his/her knowledge, information and belief. The undersigned understands
that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unworn falsification to authorities.
- V? a4(2/)--
Name: Keith Hayes
Title: Foreclosure Specialist
SHERIFF'S OFFICE OF CUMBERLAND COUNTY" &`
Ronny R Anderson QD
Sheriff tr of cudt6rp?
Jody S Smith ?
hD
Chief Deputy
a?S
T i}
Richard W Stewart
,
'
Solicitor OM _E cf TAE S?ERIFF C7
US Bank NA
vs.
Jean F. Miller
Case Number
2010-6681
SHERIFF'S RETURN OF SERVICE
11/12/2010 04:55 PM - Timothy Black, Deputy Sheriff, who being duly swom according to law, states that on
November 12, 2010 at 1655 hours, he served a true copy of the within Complaint in Mortgage
Foreclosure, upon the within named defendant, to wit: Jean F. Miller, by making known unto Danielle
Hake, Sister of defendant at 525 Harding Street, New Cumberland, Cumberland County, Pennsylvania
17070 its contents and at the same time handing to her personally the said true and correct copy of the
same.
SHERIFF COST: $43.30
November 16, 2010
: - 006G-
TIMM L-XCK, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
(ai CountySUIte Shenff. Teleosott. Inc.
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE ID No. 55669
MARY F. KENNEDY, ESQUIRE ID No. 77149
JAMES P. KENNEDY, ESQUIRE ID No. 86614
MEGHAN K. BOYLE, ESQUIRE ID No. 201661
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
,(215) 942-9690
U.S. BANK, NA ND
205 W. 4TH STREET, SUITE 500,
CN-TX 05-F1
CINCINNATI, OH 45202
vs.
OF THE PROTHONOTARY
x:42
CUMB J'TY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 10-6681
JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against JEAN F. MILLER,
Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as
follows:
As Set forth in Complaint $133,789.94
Interest 10/15/10 to 01/12/11 2,191.18
TOTAL $135,981.12
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as
shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached.
Gre Javardia , quire Id. No. 55669
71Mary F. Kenned squire id. No. 77149
James P. Kennedy, Esquire Id. No. 86614
:]Meghan K. Boyle, Esquire Id. No. 201661
Attorneys for Plaintiff
Damages are hereby assessed as indicated.
DATE: Hq ' 01b i l
PRO PROTHY oe ?b a"
9.,a 3a9IV
Notice
U.S. BANK NA ND
In The Court of Common Pleas
Plaintiff
V.
JEAN F. MILLER
Cumberland County
No. 10-6681 Civil Term
Defendants
TO: JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
DATE OF NOTICE: DECEMBER 28, 2010
NOTICE, RULE 237.1
IMPORTANT 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 se
forth against you. Unless you act within ten (10) days from the date of this notice, a
judgment may be entered against you without a hearing and you may lose your property
or other important rights. You should take this notice to a lawyer at once. If you do not
have a lawyer or cannot afford one, go to or telephone the following office to find out
where you can get legal help.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800) 990-9108
(717) 249-3166 ]
Gi ory var , Esquire
1310 Indust ' Boulevard
I" Floor, Sul e 101
Southampton, PA 18966
(215) 942-9690
Attorney for Plaintiff
Usted se encuentra en estado de rebeldia por no haber tornado la accion requiida de su
parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de
esta notificacion, el tribunal podra, sin necesidad de compararecer usted en torte o
escuchar prueba alguna, dictar sentencia en su contra, usted puede perder bienes y otros
derechos importantes. Debe llevar esta notificacion a un abogado immediatemente si
usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o
flame por telpfono a la oficina, cuya direction se encuentra escrita abajo para averiguar
donde se puede conseguir assistencia legal.
"NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE"
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE ID No. 55669
MARY F. KENNEDY, ESQUIRE ID No. 77149
JAMES P. KENNEDY, ESQUIRE ID No. 86614
MEGHAN K. BOYLE, ESQUIRE ID No. 201661
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
U.S. BANK, NA ND COURT OF COMMON PLEAS
vs.
CUMBERLAND COUNTY
JEAN F. MILLER No.: 10-6681
VERIFICATION OF NON-MILITARY SERVICE
GREGORY JAVARDIAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of
the following facts, to wit:
(a) Defendant(s), JEAN F. MILLER, is not in the Military or Naval Service of
the United States or its Allies, or otherwise within the provisions of the Servicemembers' Civil
Relief Act of Congress of 1940, as amended.
(b) Defendant, JEAN F. MILLER, is over 18 years of age, and resides at 525
HARDING STREET, NEW CUMBERLAND, PA 17070.
(c) Plaintiff, U.S. BANK, NA ND, is an institution conducing business under the
Laws of the Commonwealth of Pennsylvania with an address of' 05 W. 4TH STREET, SUITE
500, CN-TX 05-F1, CINCINNATI, OH 45202.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Gre ory Javardia squire Id. No. 55669
Mary F. Kenned ,/Esquire Id. No. 77149
?James P. Kennedy, Esquire Id. No. 86614
? Meghan K. Boyle, Esquire Id. No. 201661
Attorneys for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO10-6681 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due U.S. BANK NA ND Plaintiff (s)
From JEAN F. MILLER
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $135,981.12
L. L..50
Interest From 01/12/11 to Date of Sale at $22.35 per diem
Arty's Comm % Due Prothy $2.00
Atty Paid $175.80 Other Costs
Plaintiff Paid
Date: 2/25/11
(Seal)
Davi D. Buell, Prothono
By:
Deputy
REQUESTING PARTY:
Name: GREGORY JAVARDIAN, ESQUIRE
Address: 1310 INDUSTRIAL BOULEVARD
I"' FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
Attorney for: PLAINTIFF
Telephone: 215-942-9690
Supreme Court ID No. 55669
1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
U.S. BANK NA ND COURT OF COMMON PLEAS
205 W. 4TH STREET, SUITE 500
CN-TX 05-F1 CUMBERLAND COUNTY
CINCINNATI, OH 45202
No.: 10-6681 CIVIL TERM
vs.
JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
PRAECIPE FOR WRIT OF EXECUTION
MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly issue Writ of Execution in the above matter.
Amount Due
Interest from 01/12/11 to Date of Sale
@ $22.35 per diem
$135,981.12
S
Subtotal
(Costs to be added)
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GVA IAN, ESQUIRE
orney for Plai' ff
I.D. #55669
1310 Industrial Boulevard
1 st Floor, Suite 101
Southampton, PA 18966
(215) 942-9690
d( . so c.L
Cl(4 I S7 to
Powns
ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows:
BEGINNING at a point on the Northern line of Harding Street, said point being 155 feet in an
Easterly direction from Maple Street; thence in a Northerly direction along a line parallel with Maple
Street 130 feet to a 20-foot alley; thence in a Westerly direction along the Southern line of said 20-
foot alley, 50 feet to a point; thence in a Southerly direction along a line parallel with Maple Street,
130 feet to Harding Street; in an Easterly direction along the Northern line of Harding Street 50 feet
to the place of beginning.
BEING the Western 45 feet of Lot No. 114, Section 2, and the Eastern 5 feet of Lot No. 115, Section
2, of a Plan of Lots known as Cumberland Manor, said Plan being recorded in the Recorder's Office
at Carlisle, PA, in Plan Book 2, page 73.
BEING known as 525 HARDING STREET, NEW CUMBERLAND, PA 17070
BEING THE SAME PREMISES which Kristin L. Drum, single woman, by Deed dated March 17,
2006 and recorded March 22, 2006 in the Office of the Recorder of Deeds in and for Cumberland
County in Deed Book 273, Page 3279, granted and conveyed unto Jean F. Miller, single person.
PARCEL No. 26-23-0543-081
U.S. BANK NA ND
COURT OF COMMON PLEAS
0
vs. CUMBERLAND COUNTY G
?.-
-ta .X -n rn c=_
JEAN F. MILLER No.: 10-6681 CIVIL TERM Z70 W ??
AFFIDAVIT PURSUANT TO RULE 3129.1
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ ecut}on-C) r,
was filed the following information concerning the real property located at 525 HA C-n
STREET NEW CUMBERLAND, PA 17070:
1. Name and address of Owner(s) or reputed Owner(s):
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
JEAN F. MILLER 525 HARDING STREET
NEW CUMBERLAND, PA 17070
2. Name and address of Defendant(s) in the judgment:
JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Plaintiff.
Mortgage Electronic Registration Systems,
Inc. (MERS) as Nominee for
Wilmington Finance, Inc.
P.O. BOX 2026
Flint, MI 48501-2026
Mortgage Electronic Registration Systems,
Inc. (MERS) as Nominee for
Wilmington Finance, Inc.
401 Plymouth Road, Suite 400
Plymouth Meeting, PA 19462
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
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
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Cumberland County Domestic Relations
Cumberland County Tax Claim Bureau
PA Department of Public Welfare
Bureau of Child Support Enforcement
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
7. Name and address of every other person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenants/Occupants 525 HARDING STREET
NEW CUMBERLAND, PA 17070
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are subject to the
penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities.
G ORY JA AN, ESQUIRE
orney for Plaint
February 22, 2011
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
U.S. BANK NA ND
vs.
JEAN F. MILLER
OTNONOTAR"
2011 FEB 25 pM 1: 56
CU PEN YLVA COUNTY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 10-6681 CIVIL TERM
CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY
AS TO THE SALE OF REAL ESTATE
I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action
and further certify this Property is:
O FHA
O Tenant Occupied
O Vacant
O Commercial
O As a result of Complaint in Assumpsit
(X) Act 91 complied with
RY JAVA y N, ESQUIRE
v for Plaintiff //
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
"
??? 1 FHB 25 P? 1 ? 55
c,uMBEANO COUNTY
P
U.S. BANK NA ND COURT OF COMMON PLEAS
vs. CUMBERLAND COUNTY
JEAN F. MILLER No.: 10-6681 CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
Your house (real estate) at 525 HARDING STREET, NEW CUMBERLAND, PA 17070, is
scheduled to be sold at Sheriffs Sale on JUNE 1, 2011 at 10:00 A.M., in the Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of
$135,981.12, obtained by U.S. BANK NA ND, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215)
942-9690.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale
for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling ("215) 942-9690.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened, you may call Gregory Javardian, Esquire at (215) 942-9690.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state
who will be receiving that money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within
ten (10) days.
7. You may also have other rights and defenses, or ways of getting your home back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
(800) 990-9108
ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows:
BEGINNING at a point on the Northern line of Harding Street, said point being 155 feet in an
Easterly direction from Maple Street; thence in a Northerly direction along a line parallel with Maple
Street 130 feet to a 20-foot alley; thence in a Westerly direction along the Southern line of said 20-
foot alley, 50 feet to a point; thence in a Southerly direction along a line parallel with Maple Street,
130 feet to Harding Street; in an Easterly direction along the Northern line of Harding Street 50 feet
to the place of beginning.
BEING the Western 45 feet of Lot No. 114, Section 2, and the Eastern 5 feet of Lot No. 115, Section
2, of a Plan of Lots known as Cumberland Manor, said Plan being recorded in the Recorder's Office
at Carlisle, PA, in Plan Book 2, page 73.
BEING known as 525 HARDING STREET, NEW CUMBERLAND, PA 17070
BEING THE SAME PREMISES which Kristin L. Drum, single woman, by Deed dated March 17,
2006 and recorded March 22, 2006 in the Office of the Recorder of Deeds in and for Cumberland
County in Deed Book 273, Page 3279, granted and conveyed unto Jean F. Miller, single person.
PARCEL No. 26-23-0543-081
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1 ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
U.S. BANK NA ND
vs.
JEAN F. MILLER
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 10-6681 CIVIL TERM
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1
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I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants'
certified and regular United States mail and all lien holders or judgment creditors of record as
required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below.
(See attached Exhibit "A")
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, PA 17013
Cumberland County Tax Claim Bureau
1 Courthouse Square
Carlisle, PA 17013-3387
Tenants/Occupants
525 HARDING STREET
NEW CUMBERLAND, PA 17070
JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
PA Department of Public Welfare
Bureau of Child Support Enforcement
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
Mortgage Electronic Registration Systems,
Inc. (MERS) as Nominee for
Wilmington Finance, Inc.
P.O. Box 2026
Flint, MI 48501-2026
Mortgage Electronic Registration Systems,
Inc. (MERS) as Nominee for
Wilmington Finance, Inc.
401 Plymouth Road, Suite 400
Plymouth Meeting, PA 19462
Dated: 317A
G? 1
G ORY JAV IAN, ESQUIRE
Attorney for Plai iff
TOTENANTS
OCCUPANTS
525 HARDING STREET
NEW CUMBERLAND, PA 17070
SENDER:
REFERENCE:
MILLER, J.
7196 9008 9040 0121 8405
PS Forth 3800 2005
RETURN Postage
RECEIPT Certified Fee
SERVICE 0.44
Retum Receipt Fee
Restri
t
d D
c
e
ell"
Total Postage & Fees
„n
r
US Postal Service Px ATE
Receipt for o
Certified Mail
4c'
No Insurance Coverage Provided U S
Do Not Use Ior International Mail
TO7EAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
SENDER:
REFERENCE:
MILLER, J.
7196 9008 9040 0121 8436
PS Form 3800 ,!anus 2005
RETURN Postage
RECEIPT Certified Fee
SERVICE
Retum Receipt Fee
Restricted
Total Postage & Fees 7' i
US Postal Service PO OR A
Receipt for
Certified Mail r
No Insurance Coverage Provided
O
Do Not use for intemawnal Mail S
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February 22, 2011
TO:
OWNER(S):
PLAINTIFF/SELLER:
DEFENDANT(S):
PROPERTY:
CUMBERLAND C.C.P. NO.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
ALL PARTIES IN INTEREST AND CLAIMANTS
JEAN F. MILLER
U.S. BANK NA ND
JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
10-6681 CIVIL TERM
The above captioned property is scheduled to be sold at Sheriffs Sale on JUNE 1, 2011 at
10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. You
may hold a judgment on the property, which maybe extinguished by the sale. You may wish to
attend the Sheriff's Sale to protect your interest.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not
later than 30 days after sale. Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the schedule.
Sincerely,
r
6regory Jav ian, Esquire
Law Office f Gregory Javardian
1310 Industrial Boulevard
1 st Floor, Suite 101
Southampton, PA 18966
(215) 942-9690
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson r 1;- - ?N r
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
US Bank NA
vs.
Jean F. Miller
E ? ? r
PENNS Y±_1V,4,N!A
Case Number
2010-6681
SHERIFF'S RETURN OF SERVICE
03/18/2011 04:48 PM - Deputy Michael Barrick, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 525 Harding Street, New Cumberland, PA 17070, Cumberland County.
03/21/2011 06:11 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jean F.
Miller at 525 Harding Street, New Cumberland Borough, New Cumberland, PA 17070, Cumberland
County.
06/01/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County, Courthouse, Carlisle, PA on June 1, 2011 at 10:00 a.m. He sold the same for the
sum of $ 104,000.00 to Family First Financial LLC, 3315 Market Street, Camp Hill, PA 17011, being the
buyer in this execution, paid to the Sheriff the sum of $
SHERIFF COST: $3,22712 SO ANSWERS,
July 07, 2011 RON R ANDERSON, SHERIFF
00 /c.??
d'
u
SCHEDULE OF DISTRIBUTION
Date Filed: June 23, 2011
Writ No. 2010-6681 Civil Term
U.S. Bank NA ND
-vs-
.[can F. Miller
525 Harding Street
New Cumberland, PA 17070
Sale Date: June 1, 2011
Buyer: Family First Financial LLC
Bid Price: $ 104,000.00
Real Debt: S 135,981.12
Interest: 3,129.00
Attorney Writ Costs: 175.80
Total Due: $ 139,285.92
DISTRIBUTION:
Receipts:
Cash on Account (03/11/2011)
Cash on Account (06/01/2011)
Cash on Account (06/13/2011)
$ 1,500.00
10,400.00
99,142.00
Total Receipts: $ 111,042.00
Disbursements:
Sheriffs Costs
Legal Search
Transfer Tax (Local)
Transfer Tax (State)
Robin Gasperetti, New Cumberland Borough
Tax Collector (2011 School Taxes)
New Cumberland Borough (Sewer/Refuse)
Attorney Gregory Javardian
U.S. Bank NA ND
Total Disbursements:
Balance for distribution:
So Answers:
?71 11
$ 2927.12
300.00
1,581.00
1,581.00
1,422.90
267.25
1,500.00
101,462.73
($111,042.00)
00.00
Ronny R. Anderson
Sheri ff
r I
SNELBAKER & BRENNEMAN, P. C.
ATTORNEY AT LAW
44 W. Main Street
Mechanicsburg, PA 17055
TITLE REPORT
TO: Sheriff of Cumberland County
RE: Sheriffs Sale, Writ No. 2010-6681
Held June 1, 2011
EFFECTIVE DATE: June 1, 2011
PREMISES: 525 Harding Street, Borough of New Cumberland, Cumberland County,
Pennsylvania, Tax Parcel No. 26-23-0543-081 (the "Premises")
RECITAL: Being the same Premises which Kristin L. Drum, single woman, by her deed
dated March 17, 2006 and recorded March 22, 2006 in the Office of the Recorder
of Deeds in and for Cumberland County, Pennsylvania in Deed Book 273, Page
3279, granted and conveyed unto Jean F. Miller, single person.
The Premises identified above and as more fully described in the legal description
attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items
and exceptions. All recording and docket locations identified are in the Office of the Recorder of
Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County.
EXCEPTIONS:
Claims and charges for improvements and repairs to the Premises or delivery of materials
thereto for which payment has not been made.
2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments.
The rights or claims of any tenants or other parties in possession.
4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of
1997, as amended.
Any environmental liens or claims filed or on record in the Federal District Court.
Payment of state and local real estate transfer tax, if applicable.
7. Any secured transactions with respect to the Premises.
8. The area of the Premises is not certified.
9. Those matters which a view or inspection of the Premises would reveal.
10. The accuracy of the measurements and dimensions of the Premises or the rights or title of
or through any person or persons in possession of same, conflicts with adjoining
property, encroachments, projections or any other matter disclosed by an accurate survey
of the Premises.
11. The right of use as may be determined by any applicable municipal zoning ordinance or
regulation.
12. Any matter not of record at the Court House as of the effective date of this Title Report
and subsequent to the date hereof.
13. Any tax increase based on additional assessment made by reason of new construction or
major improvements.
14. The absence or failure of proper and required notice being given to all owners and
holders of liens and encumbrances intended to be divested by the Sheriffs sale and
procedural defects by any judgment creditor or lienholder executing on the Premises
giving rise to the Sheriffs sale noted above.
15. Identity and legal competency of all parties at any closing or conveyance of the Premises
should be established.
16. Access to the Premises by public road or street is not certified.
17. Suitability or existence of sewer and water facilities on or available to the Premises is not
certified.
18. Real Estate taxes on the Premises due and payable but not turned over for collection to
the Tax Claim Bureau.
19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate
taxes accruing on and after January 1, 2011.
20. Subject to the rights in the Premises by any spouse, if any, of Jean F. Miller.
-2-
21. Mortgage in the amount of $124,720.00 from Jean F. Miller to Wilmington Finance, Inc.
dated March 17, 2006 and recorded March 22, 2006 in Mortgage Book 1944, Page 907,
assigned July 15, 2010 to Instrument No. 201019054 to US Bank, NA.
22. Mortgage in the amount of $31,180.00 from Jean F. Miller to Wilmington Finance, Inc.
dated March 17, 2006 and recorded March 23, 2006 in Mortgage Book 1944, Page 924.
23. Judgment against Jean F. Miller in the amount of $135,981.12 entered January 14, 2011
in favor of US Bank, NA ND to No. 2010-6681.
24. Subject to all building set-back lines, easements, restrictions, conditions, notes and all
other matters appearing on the Plan of Cumberland Manor, Plan Book 2, Page 73.
25. Subject to the rights of others in and to any portion of the Premises lying within or
adjoining Harding Street and an alley.
The undersigned shall not be bound by this Title Report to any person, firm or entity
other than the Sheriff of Cumberland County.
Snelbaker & Brenneman, P. C.
By Il
Keith O. Brenneman
-3-
Writ No. 2010-6681 Civil
US Bank NA ND
vs.
Jean F. Miller
Atty.: Gregory Javardian
ALL THAT CERTAIN lot or piece of
land situate in the Borough of New
Cumberland, County of Cumberland
and Commonwealth of Pennsylvania,
bounded and described as follows:
BEGINNING at a point on the
Northern line of Harding Street, said
point being 155 feet in an Easterly
direction from Maple Street; thence
in a Northerly direction along a line
parallel with Maple Street 130 feet to
a 20-foot alley; thence in a Westerly
direction along the Southern line of
said 20-foot alley, 50 feet to a point;
thence in a Southerly direction along
a line parallel with Maple Street, 130
feet to Harding Street; in an Easterly
direction along the Northern line of
Harding Street 50 feet to the place
of beginning.
BEING the Western 45 feet of Lot
No. 114, Section 2, and the Eastern
5 feet of Lot No. 115, Section 2, of a
Plan of Lots known as Cumberland
Manor, said Plan being recorded in
the Recorder's Office at Carlisle, PA,
in Plan Book 2, page 73.
BEING known as 525 HARDING
STREET, NEW CUMBERLAND, PA
17070.
BEING THE SAME PREMISES
which Kristin L. Drum, single wom-
an, by Deed dated March 17, 2006
and recorded March 22, 2006 in the
Office of the Recorder of Deeds in
and for Cumberland County in Deed
Book 273, Page 3279, granted and
conveyed unto Jean F. Miller, single
person.
PARCEL No. 26-23-0543-081.
EXHIBIT A
.I
i
.S BANK NA ND 'COURT OF COMMON PLEAS
'S. CUMBERLAND COUNTY
EAN F. MILLER No.: 10-6681 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129.1
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution
,vas filed the following information concerning the real property located at 525 HARDING
`;TREET, NEW CUMBERLAND, PA 17070:
Name and address of Owner(s) or reputed Owner(s):
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
JEAN F. MILLER 525 HARDING STREET
NEW CUMBERLAND, PA 17070
Name and address of Defendant(s) in the judgment:
JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
4. Name and address of last recorded holder of every mortgage of record:
I Jame
F lainti ff.
Mortgage Electronic Registration Systems,
Inc. (MFRS) as Nominee for
Wilmington Finance, Inc.
Mortgage Electronic Registration Systems,
Inc. (MERS) as Nominee for
Wilmington Finance, Inc.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
P.O. Box 2026
Flint, MI 48501-2026
401 Plymouth Road, Suite 400
Plymouth Meeting, PA 19462
1' 1
Name and address of every other person who has any record lien on the property
Jame Last Known Address (if address cannot be
reasonably ascertained, please indicate)
done.
Name and address of every other person who has any record interest in the property and whose
Merest may be affected by the sale.
Jame.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Cumberland County Domestic Relations
Cumberland County Tax Claim Bureau
I A Department of Public Welfare
I ureau of Child Support Enforcement
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
7. Name and address of every other person of whom the plaintiff has knowledge who has any
ii iterest in the property which may be affected by the sale:
T ame Last Known Address (if address cannot be
reasonably ascertained, please indicate)
T enants/Occupants 525 HARDING STREET'
NEW CUMBERLAND, PA 17070
I verify that the statements made in this affidavit are true and correct to the best of my
k lowledge, information and belief. I understand that false statements herein are subject to the
p nalties of I8 Pa. C.S.A. 4904 relating to unsworl falsification to authorities.
G ORY JA 4AN, ESQUIRE
attorney for PlaiF ?bruary 22, 2011
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1ST FLOOR, SUITE 101
SOUTHAMPTON. PA 18966
i 15)942
-9690
L1.S. BANK NA ND COURT OF COMMON PLEAS
'? s. CUMBERLAND COUNTY
JEAN F. MILLER No.: 10-6681 CIVIL TERM
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: JEAN F. MILLER
525 HARDING STREET
NEW CUMBERLAND, PA 17070
Your house (real estate) at 525 HARDING STREET, NEW CUMBERLAND, PA 17070, is
scheduled to be sold at Sheriffs Sale on JUNE 1, 2011 at 10:00 A.M., in the Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of
5135,981.12, obtained by U.S. BANK NA ND, against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back paymei,ts, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215
942-9690.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale
for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorriey.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (215) 942-9690.
2. You maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened, you may call Gregory Javardian, Esquire at (215) 942-9690.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to
evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state
who will be receiving that money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within
ten (10) days.
7. You may also have other rights and defenses, or ways of getting your home back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
(800) 990-9108
ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows:
BEGINNING at a point on the Norther line of Harding Street, said point being 155 feet in an
Easterly direction from Maple Street; thence in a Northerly direction along a line parallel with Maple
Street 130 feet to a 20-foot alley; thence in a Westerly direction along the Southern line of said 20-
foot alley, 50 feet to a point; thence in a Southerly direction along a line parallel with Maple Street,
130 feet to Harding Street; in an Easterly direction along the Norther line of Harding Street 50 feet
to the place of beginning.
BEING the Wester 45 feet of Lot No. 114, Section 2, and the Eastern 5 feet of Lot No. 115, Section
2, of a Plan of Lots known as Cumberland Manor, said Plan being recorded in the Recorder's Office
at Carlisle, PA, in Plan Book 2, page 73.
BEING known as 525 HARDING STREET, NEW CUMBERLAND, PA 17070
BEING THE SAME PREMISES which Kristin L. Drum, single woman, by Deed dated March 17,
2006 and recorded March 22, 2006 in the Office of the Recorder of Deeds in and for Cumberland
County in Deed Book 273, Page 3279, granted and conveyed unto Jean F. Miller, single person.
PARCEL No. 26-23-0543-081
WRIT OF EXECUTION and/or ATTACHMENT
,COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO10-6681 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due U.S. BANK NA ND Plaintiff (s)
From JEAN F. MILLER
(l ) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGA1.
DESCRIPTION.
(:2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined. from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due 5135,981.12
L.L..50
Interest From 01/12/11 to Date of Sale at $22.35 per diem
Atty's Comm % Due Prothy S2.00
Atty Paid $175.80
Plaintiff Paid
Other Costs
Date: 2/25/11
(Seal)
Deputy
REQUESTING PARTY:
Name: GREGORY JAVARDIAN, ESQUIRE
Address: 1310 INDUSTRIAL BOULEVARD
IST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
Attorney for: PLAINTIFF
Telephone: 215-942-9690
? ?Y_'4j
vid D. Buell, Prothonotary
By: _
TRIjE COPY FROM RECORV and
.,hand
In Testimony whereof, l hers unto set my
said Court at C°riisle, Pa
and the se 20 -L---
do'l cif
This
6kl?A
Supreme Court ID No. 55669
(.)ii Marcie i the -5vterill evied upon tale
defendant's interest in the real property situated in
New Cumberland Borough, Cumberland County. PA,
Known and numbered as. ?-25 Harding Street,
New Cumberland, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein,
Date: :!larch )0l
B
beat Estate Coordinator
CUMBERLAND LAW JOURNAL
Writ No. 2010-6681 Civil
US Bank NA ND
vs.
Jean F. Miller
Atty.: Gregory Javardian
ALL THAT CERTAIN lot or piece of
land situate in the Borough of New
Cumberland, County of Cumberland
and Commonwealth of Pennsylvania,
bounded and described as follows:
BEGINNING at a point on the
Northern line of Harding Street, said
point being 155 feet in an Easterly
direction from Maple Street; thence
in a Northerly direction along a line
parallel with Maple Street 130 feet to
a 20-foot alley; thence in a Westerly
direction along the Southern line of
said 20-foot alley, 50 feet to a point;
thence in a Southerly direction along
a line parallel with Maple Street, 130
feet to Harding Street; in an Easterly
direction along the Northern line of
Harding Street 50 feet to the place
of beginning.
BEING the Western 45 feet of Lot
No. 114, Section 2, and the Eastern
5 feet of Lot No. 115, Section 2, of a
Plan of Lots known as Cumberland
Manor, said Plan being recorded in
the Recorder's Office at Carlisle, PA,
in Plan Book 2, page 73.
BEING known as 525 HARDING
STREET, NEW CUMBERLAND, PA
17070.
BEING THE SAME PREMISES
which Kristin L. Drum, single wom-
an, by Deed dated March 17, 2006
and recorded March 22, 2006 in the
Office of the Recorder of Deeds in
and for Cumberland County in Deed
Book 273, Page 3279, granted and
conveyed unto Jean F. Miller, single
person.
PARCEL No. 26-23-0543-081.
54
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA.
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
April 22, April 29, and May 6, 2011
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Lisa Marie Coyne,
itor
!il
SWORN TO AND SUBSCRIBED before me this
6 day of Mav 2011
Notary r?
-
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
9, 2014
Inky Commission Expires Apr 2
The Patriot-News Co.
2020 Technology. Pkwy
Suite 300:
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
z4fPatriot News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
04/22/11
04/29/11
05/06/11
..........
Sworn to arid subscribed before me thi5,?3 day of May, 2011 A.D.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sherrie L. Klsner, Notary Public
Lower Paxton Twp., Dauphin County
My Commission Expires Nov. 26, 2011
MEmRr, Pennsylvania Assoda l.n 'Notaries
2010-6681 QvG Term
US Bat* NA NO
vs
Jean F. Mller
Atty, Gregory Javardlan
ALL THAT CERTAIN lot or piece
of land situate in the Borough of New
Cumberland, County of Cumberland
and G' lonwealth of Pennsylvania,
bounded and described as follows:
BEGINNING at a point on the Northern
line of Harding Street, said point being 155
feet in an Easterly direction from Maple
Street; thence in a Northerly direction
along a line parallel with Maple Street
130 feet to a 20-foot alley; thence in a
Westerly direction along the Southern line
of said 20-foot alley, 50 feet to a point;
thence in a Southerly direction along a
line parallel with Maple Street, 130 feet
to Harding Street; in an Easterly direction
along the Northern line of Harding
Street 50 feet to the place of beginning.
BEING the Western 45 feet of Lot No.
114, Section 2, and the Eastern 5 feet of
Lot No. 115, Section 2, of a Plan of Lots
known as Cumberland Manor, said Plan
being recorded in the Recorder's Office
at Carlisle, PA, in Plan Book 2, page 73.
BEING known as 525 HARDING STREET,
NEW CUMBERLAND, PA 17070
BEING THE SAME PREMISES which
Kristin L. Drum, single woman, by Deed
dated March 17, 2006 and recorded March
22, 2006 in the Office of the Recorder of
Deeds in and for Cumberland Coufay in
geed Book 273, Page 3279, granted aid
conveyed unto Jean F. Muter, single per".
PARCEL No. 26-23-054301
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Family First Financial LLC is the grantee the same having been sold to said
grantee on the 1 day of June A.D., 202011, under and by virtue of a writ Execution issued on the 25 day
of February, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010
Number 6681, at the suit of U.S. Bank NA ND against Jean F. Miller is duly recorded as Instrument
Number 201118973.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and I of said office this day of
A.D.
a
of Deeds
morder i f Deeds, ambeftd Courdy, Cwft, PA
ay Commission Expires fm Frei Monday of Jan. 2014