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HomeMy WebLinkAbout11-5211FILED-OFFICE OF TN! PROTHONOTARY Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 IT FEDERAL CREDIT UNION 7011 X,11 23 AM 10: 23 CUMBERLAND COUNTY PENNSYLVANIA PLAINTIFF Vs. HEATHER R. KNIGHT DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. : CIVIL ACTION - LAW : MORTGAGE FORECLOSURE NOTICE TO DEFEND AND CLAIM RIGHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claims or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. a vctaob Fd I W-1 J6Gga3 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 NOTICIA Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defensas o sus objectiones a las demandas en contra suya. Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. UNLESS YOU DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF WITHIN THIRTY (30) DAYS OF THE RECEIPT OF THIS NOTICE, COUNSEL FOR PLAINTIFF WILL ASSUME THE DEBT TO BE VALID. IF DEFENDANT(S) NOTIFY COUNSEL FOR PLAINTIFF IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND MAIL TO DEFENDANT(S) WRITTEN VERIFICATION OF THE DEBT. LIKEWISE, IF DEFENDANT(S) PROVIDE COUNSEL FOR PLAINTIFF WITH A WRITTEN REQUEST WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THE THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUESTS US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND/OR RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: HEATHER R. KNIGHT DEFENDANT : CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE COMPLAINT AND NOW, comes Members 1 s' Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the following complaint: 1 1. Plaintiff, Members 1St Federal Credit Union ("Members 1" ), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Defendant, Heather R. Knight ("Defendant"), is an adult individual having a last known address of 1027 Drexel Hills Boulevard, New Cumberland, PA 17070. 3. On or about September 25, 2009, Defendant borrowed from and agreed to repay to Members 1St SIXTY THOUSAND AND 00/100 ($60,000.00) dollars (the "Loan"). The Loan is evidenced by a Closed-End Note, Disclosure, Loan and Security Agreement dated September 25, 2009 (the "Note") executed and delivered to Members 1St by Defendant. A copy of the Note is attached hereto as Exhibit "A" and made part hereof. 4. As security for the Loan, Defendant executed and delivered to Members 1St a mortgage ("Mortgage") on all that certain real estate and improvements erected thereon situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, known and numbered as 1027 Drexel Hills Boulevard, New Cumberland, PA 17070 a/k/a 1027 Drexel Hill Boulevard, New Cumberland, PA 17070 (the "Property"). A description of the Property is attached hereto as Exhibit "B" and made part hereof. 5. On or about October 12, 2009, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office at Instrument No.: 200934842. A true and correct copy of the Mortgage is attached hereto as Exhibit "C" and made part hereof. 2 6. The Mortgage has never been assigned by Members 1st and is still held by it as a valid and subsisting obligation of Defendant. 7. The Mortgage is in default because Defendant has failed to deliver to Members 1St the Bi-weekly payments of principal and interest due thereon in the amount of $235.93 each for January 21, 2011 and every two (2) weeks thereafter through the date of this complaint, as more particularly set forth and described, in part, in the Act 91 Notice attached hereto as Exhibit "D" and made part hereof. 8. Members lst gave written notice of its intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. seg., and in particular section 403 thereof, and of Defendant's rights in accordance with the Homeowners' Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. SeMc ., by letter dated March 29, 2011, addressed to Defendant, via certified mail, return receipt requested. A copy of the said notice is attached hereto as Exhibit "D" and made part hereof. 9. US Postal electronic Shipment Request Form and Track and Confirm evidencing the mailing of said Notices are attached hereto collectively as Exhibit "B" and made part hereof. 10. Simultaneously, Members 1St forwarded to Defendant the same Notice as set forth in paragraph 8 above addressed to Defendant by United States mail, first class, postage prepaid, bearing the return address of Members lst. The Notice 3 forwarded in said manner has not been returned to the offices of Members 1St 11. 12. as undeliverable or otherwise. As of June 20, 2011, Defendant is indebted to Members 1St in connection with the Mortgage in the amount of SIXTY-THREE THOUSAND SIX HUNDRED NINETY-SEVEN AND 58/100 ($63,697.58) dollars itemized as follows: a. Outstanding principal $58,935.37 b. Interest to June 20, 2011 1,844.21 c. Late fees 118.00 d. Attorney's fees 2,800.00* e. Total due to Members 1 st as of June 20, 2011 $63,697.58 *The above attorney's fees and expenses are calculated through sheriff's sale and are in accordance with Defendant's agreements as set forth in the underlying Mortgage and Note. If the Mortgage is reinstated prior to a Sheriff's Sale, the attorney's fees and expenses set forth above may be less or more than the amount demanded above based upon work actually performed. Defendant will be responsible for actual, reasonable legal fees incurred by Members 1St in this matter subject to any applicable limitation contained in the Mortgage and the Note. Defendant also agreed under the terms and conditions of the Mortgage that in the event of default there under Defendant would pay, in addition to the amounts set forth in paragraph 11 above, costs incurred by Members 1 st as a result of the institution and prosecution of these legal proceedings. 4 13. The obligation owed to Members 1St continues to accrue interest at the rate of $12.0131 per day, through the date of payment and continues to accrue attorney's fees and costs. 14. Members 0 is not seeking a judgment of personal liability (or an in personam judgment) against Defendant; however, Members 1St reserves the right to bring a separate action to establish that right, if such right exists. If one or more of Defendants have received a discharge of personal liability in a bankruptcy proceeding, this action in Mortgage Foreclosure is not an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the Property in accordance with Pennsylvania law. 15. As set forth above, Members 1St has made demand upon Defendant to cure the default under the Mortgage. However, as of the date hereof, Defendant continues to fail and refuse to cure the default. WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment, In Rem, against Defendant, Heather R. Knight, in the amount of SIXTY-THREE THOUSAND SIX HUNDRED NINETY-SEVEN AND 58/100 ($63,697.58) dollars plus interest at the rate of $12.0131 per day, through the date of judgment and at the legal rate thereafter until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage and for foreclosure and sale of the mortgaged property. 5 submitted, Date: ? WWI) Karl M. Ledebohm, Esq. Supreme Court ID 4: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ngnNCM+L AMWNI SOW Louise Drive, P.O. Box 40 Mechanicsburg, PA 17055 ANNUAL PERCENTAGE FINANCE CHARGE: Amount Financed; Themno0raof Total of Payments: The amount RATE : The cost of your reedit as a The dollar amount the credit will credit provided to you or on you( you wit have paid after you have yearly rate. ' cost you. behalf: made all payments as schedule d 7.44 % a S 56,766.17 a S 60,000.00 $ 122,909.77 e Varwbb Rata: If you ben Ilan a variable req as Yrdcated above the Am" Pernmage Rata may kcrease during the tam or ma eansapbn it No pndex) changes. Tho credit acct w11 sea .= fl to the indox value Thu raa wit thaga rnWWy rrrl the II A do oIft nxx*h Tha tab will nevor bo higher Uwn the maximuh role ak ad by . . bw. and Y wig revar be lens then . Any Interest too kgreesos will result In morn payments of the same amount. For Example, a your ben was for $5.000 at 15% for AS nionths and the Annual Perconiaga Rate Increased by 2% aw one year. the arm of your loan world invesso by two months x of Auedba auk Pt men?D xau? Role Becn ebyou C eve vo ed to more your rerauied meets IMagh an ouiomo k deduoion from Chet v ngs bos is above In ft t D A ? E l the AutorA K Myngm pscoumoo M to makniw llkipnt kxMM RiteTMS tale will tlcraes¢ Dy20%tlyou cease tea auomatlP?ym m an ergamM a Io a ment Discounyour acoom to Cover f DulonMtit Fa aMa f Neomadc Pa ted Rate is 10% mafts b acre us the ItTep a1 Ina iltrease wY! be b auarM da Nlm ar ea ban a K l! y o or QQ . " . y y . a e. On a $5.?.1)<) bit Iof 00 mahtlxh and yea Cape ale suomak paynwrlt a1f011gCmata, your fan rdM rlemasa l0 10.20%. rest* In 1 additional poymem. ,V. but. Rob Preferred t.oanS. II ypn bon Is a wria0b rata ban a royou gwrlM?TystOr a prabrred rata. you prManeo dlscaan ispltekan at Ule d? you cede as you ban. This ANNUAL or o ? T f b ? PERCENTA OERATEb 2$6n the Ume you lake llaben.7yacF faN lA%Yaur Mtla a? lLx dANNUA PERCENTAGE TE all awn Y, a M Fixed Rea Rbrea ban and NTAGE RATE wit be aw preferred ANNUAL PETAGE RATfar es ss yonar ws fe111ea1S b clap. d Number of Payments Amount of Paymems P"Itill Fraquarq When Paymenu; Are Duo yp part Prop y Insu Ence: YOU w&ob art IS atka ?18DIe 10 nyale Ins urance I Pay- 519 $236.19 Eli-Weekly • Beginning 1013D12009 ( the credtl union. 11 vowu et the insurance from the credit union ou will swl? • 1 $226.16 Final Due - On 09/2112029 y ?y S N/A airy: CoaatarN saaxkq aNe bans with Vie t'fadt union the goods or potwny Ougr wa bite Tacvo 4ts ban. you we giving a satarrity intorost In X being purcMwd. - ? (Describe): your shares andfar deposit in on craft union and: , Law Gorr9 : tl a payrront is late M 10 dsYS tlr mare you wit a l I NonFllirg Insurarxo: 0.oqulfod Deposit Balance: llq Annual Perconbgo Rite does Fllklg Foos Do erwgoU log be of 6% of your unedu af paymon. not woo Yto atsaw your required deport oapnair it arty, j NIA S NIA am:, p.y .7- nu loPaye Ana Y. M.Pwr}aNnrew tla sfwe/ieNM wl1 s any egpapnw. arMr reppnann r p¢rwartwlryt arYPwlin. un s+-. r wl? v r AMOUNT FINANCED $ 60,000.00 Amount Pail to others on your behalf (Describe) ' j t.2a1.r0 To MERRICK aK f To AMOUNT GIVEN TO YOU DIRECTLY] 51,11705 53911.011 TocaAoNt S TO S1_443.05 To CHSE.asieu7 $ To $2a3AS TO GEM&WAWART $ TO Slao.52 To TARGET acs. $ To AMOUNT PAID ON YOUR ACCOUNTS 4,24501 $17$'14 To GeMarwP $ To S 4311= To cawnutNCM $ TO 593.91 TO cr riNGERHIIf S TO S To $ To PREPAID FINANCE CHARGE $ 0.00 $ To $ 9.m To roes 5 To mwsaunw $ To Aaed5w9am MAKE MODEL VV YEAR1 I•D•NUMBER TYPE VALUE OTHER (Describe): 1027 DREXEL HILLS BLVD Oa 8dga hens AMOUNT ACCOUNT NUMBER $AMOUNT wsi of $ ACCOUNT NUMBER errd/Gr Ogts nKohw apac a cc" of the ban ond e s vasWmeYy ca agnwtwrgrnmnts advevid disclosure diadisclosudisclosure star wtaryrlwntapeameme. Co•sigrwrgevarwg: If you are ma Signing sear as w.skp rigdaor. oanplntry you Acknowledge antedge receievaaay.p of You trig octul Ifdgr you have romaine oa ic ks low to s4?rla tgrllakdaf an gaga 2. tb ER' GNATU OA CO-MAKER 'OTHEROWNER [] "CO-SIGNER DATE X (SEA tee. X (SEAL) ? CO-MAKER ?'OTHERO E ?"CO-SIGNER DATE [] CO-MAKER ?'OTHER OWNER D'•CO•SIGNER DATE X (SEAL) X (SEAL) [I CO-MAKER ?'OTHER OWNER ?"CO-SIGNER DATE ? CO-MAKER 1] 'OTHEROWNER0 "CO-SIGNER DATE X ISEAU X (SEAL) 'oM[A OMIRaiM1^/AVnNRM.?aanxtwwaY Irae acre of •rvM. ar dart n VN wee a..wewraariartlagre Ma. iMtav aww, web rNa wwew, h lien aeraera p V?f maw.w,naowrra nor o,A,1,nMN. a lane Vt. tilted tree W W d ?V aplwM/ tae Sm 0y?My AVw. "COrgNFa: Wr^ IJu,4na v?M.nenn'Y ?wi. m,,,M+N F'T"rn M1an Jn M'rN of Y%rN ?as,nn M wNr Ir.n IN Prr,?r ewerY rdeu wNrnN ? •rr euMarlere,aaY curb oemg asked to guaratlteo this debt. Think care fuN before you do. If the borrower doesn't pay the debt, you will have to. Be sure you can afford to 3 have la and that yyou want t0 accept this resporly5tblily. have to pay up to tfte lull amount of Vie debt if the lrofr wer does not pay. You may also have to pay late fees or collection costs, which increase this W can collect INS debt from yW wllh0gul firstDtrying Ip collect from the borrower. The creditor can use the some collection methods against you that am sthnot e borrcower cii11hai mske3 ?iou' 1%tr hint lofuebwages, etc. If this debt is ever in defauk. that fact may become o part oryour credit Page 1 of 2 Exhibit "A" I yD =59 NUMBER A__^, MIT NUMBER DATE OF Co. HEATHER R KNIGHT 07 102 09/2512009 NAMED AS EROMWENT S )THE WORDS "CREDIT UNION* MEANS MEMBERS t5T FEDERAL CREDIT UNION. THE WORDS -YOU,- 'YOUR' AND -YOURS- MEAN THOSE LOAN AGREEMENT Fa value receNed. yar anise la pay, x Itwnts [file. Aa pnymenls shit be tootle meal on 1 d this document. You a and o il svn ms shorn on at t diKatliete5 er?d .f ayt s1l k=1mmaelrlxed for a l7' the axuatgns of that preferred 1=11814 file duce due, you wit Pay Rdditlonal Payments: Payments and credits order: any amounts. past duo: accrued y foes to shed owq, kwlulWq eny rg prindpa1. nts made in addition to Shea 6e appl' lo a the same order. or a?prre?r r d roe as disclosed tOgr?Qp?ayfg?e 10! m disrdoseaa taedrtudlt touaualav Of the `ate 4haiges: a make a IetO pa meas. you agree to pay a lele "Ige if one is dsdoseC on page 1 of this document. 0 Igen waxed try Q moor vehicle or Pro Pit I ureme: Ir you obtain aha tanyprq propprt You must ttblen Insurance Jrfpch seas the credit union froftlannanctal loss. The amcium and coverage 0 th?propen ktsurpprtca must a acs We tQ t Ue .I union.5uch a poesy ' provge at keel fie, lieut. axnbnad additional cover40as lend too nsurarlue. it mist contain a Loss Payya?ble clause endasemenl the atada union wt;. holder. You may DWaln Ws Insurance Irom an rt d yyoou [talcs the agent to send the aeon anon a copy alt wt?rr4 Debtor Resppnsibilt y: Yo promise W holy ,credit W. Of eny the in Po (tame ass a nl. Y0t1 p se nIX a aPphf ni a toM Wu Wide e is a rpprfobabtl?I(lyy that ygu wYl be Ixil?t to repeY Ur obligadort acca d ip b th! l ats Of at! Cr ll lMenslon. ou pWnse o Inlom cr U of in Hirtfamadon whcYt relates to ur adIky to reGa YYoouurr You a not to submit false a Inac?y, ale kaorrnauon or Ay ortceeq ormetion regarding you aedrlwathness. cr slanaft or treat capacity. Statut fen: Y?you are in delauk, federal law Uylves the credit union the rlptt aaaY?p?1t. ?II@ belertq zhass atdla It Its In Yqa accolnt(s at the Ikno d delstm to 360 thlg ban. Once you are in, detauh, the credit union may exercise Iles it g at without ranter route to you. Dais in Enfod mentCredlt Union ma dalayr enforcing any o (the credit un t?rigttts this agreement whhoul Idsthem. Irreg.Aw Payments: The trade union may a apt late pa menus or partial pa seven [laugh mark?'paymem at ?ifll, without ?osirg any of the a k Itetin fighu u r Iles ogrltamenl. C akkeirs: II a s'?grtrlgihls a reament as a co•maker, ypu 8gtee to eq a! WRh thq bond) r, but the credit union Ihey alts either a you. The aadt union does Rd have to naNy ydw that this ag9reemert has rfet been paid. The credit unb may axtend the Tams of pbyment and release anyy security without rat yfng or re a you Fran responsibility on this agreemert. Contractual pledge of Shores: You pledge all your shores and tleposhe In the credit union. including future additions, ss saurky fee this ban. In cox you default. One treat union may app1y "3e shares and deposhs to tho psyrnent of all salt: due at Uta Ume of dbfiuIL Incltrling toatb W maacton and muorYbN atvney's fees; tit the aerst union may Inca, up to 20% oresrthe trlpaid principal and interest. No lion a right b Irnpnoss s Ikn on shaeM depmlb aisle apply to any of you sinres which troy be held in en'lndivWwl Rolwomenl Accourt' or "Iff"ll Plan.' SECURITY AGRE EMENT I' io secure W marl d cols Ipso and all azpe?nditures Mwrep by VV ueoh union In con w1th Ws ban, h raMlzhp on a seta tyvaaraef. you Rpreaprpl J4o a?y?r t uNon s sacanY gNrµCneat In the ?aperly desalbed on }uaYRL[of Wi TM erg InlKasI eKlurNS al I 1H. mss bans tlte?pop °rty"add eN L.T,N r ved Form they sewr°a?aao?n Oroaa{ellata limf n' Pr Nlert K BGUr Ian W5 an or br any tow banaprawgoUl?rolwMdaprcDrllr iH??a?r?a?1 b ?seepaHolgp evaryn?afpeoNpSarty f pflnet ?tUraaaS borMOOaftrutCStleMabnnrlalegera rprorn?'a ail raga 'omens is so" aanaol, p we ron•pur aso 7. You wi nx Caarrga Ilq ID<Mbn d, NO of uensNr the collateral unless you have the cro01 f br 0111 3. You wenxs 5nvw?hheave 8: o M ?p?t?al, by d so Zia kexests ez r a d It110e cdbror id, for 9ilaf?neaisa n Ihealn a. toad9. Msttb?atslty wet defaro Inl r aas feetr`t' paPcy adrae w asr any amRaarfs union r at it. You wal maMealn Inoue vehicle or of propRrty In wheal No be I 1 aerie unbrf nos a NUM. N ?wasfacle bn. Y0Y v/la sy IM aatls y? whin Proof orop?y al's rserbpY tale b??lnalaWln 4saallh i a+bnarrtra ui Is dx requrea to d I alto ar ore own W k b?rre oM?ds "gal UIe tpfnrsa rat amfNx ou lulna tested Of ass yuad nl0nam? oo Feeal, tho raeaaasa of on tyn?gppn YOU?Udwasuteuaanetnro. end ipp?y awSDSOIes lodowe?iu the ti uMaf oInsuraaco Sarvke Cents Ya it.- a Wraito ins agile unUK wpi th?evnecAUadeaaray r?NatOrr?uon C ion nwlof adaquxaoertoalvaat egah.7 uR tor Yu YnI WAhoufbetnola IoyauMndivai?na?lyaOU Is Wnb uiey fd UIa prambn oafalAe d MxN union tarealaamm56 x myin rer? t 14115 INV Woe tlUle it rtaalaW hob u vrb or t is f0oaod tlMaWeheO. u w asssbbnn aopt c8s tv adaabrufsaurlf?r atr?h uMart ?ieLC Is necessary 10 Inn 1ipnlxtla sMfIa1M? a to protMtYha?radt aim agebx posslae Page 2of 2 of 00 NW stn a?yl !jZ:vtlon trrpaspxµy io prYwnoraarihseacaaaomo sneniYw xWissewa4wcpn & pW"ymfpon AW?u?ipthost?rmsMt?sere h,,1$ ?Ila?sgroenant not only binds you. Ina your executors. admwWaarx T"I ALL THAT CERTAIN lot 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 northerly line of Drexel Hill Boulevard, at the dividing line between Lots 24 and 25, Block 8, on the hereinafter mentioned plan of lots; THENCE North 03 degrees 45 minutes East, through Lot No. 25 on said plan, 97.66 feet to a point; THENCE South 81 degrees 54 minutes East, along the southerly line of Lot No. 2, Block B, 70 feet to a point; THENCE South 03 degrees 07 minutes West, along lands now or late of E. G. Campbell & Son 144.79 feet to a point, on the northerly line of Drexel Hill Boulevard; THENCE along the latter line, westwardly by a curve to the right having a radius of 190 feet, an arc distance of 75 feet to the place of BEGINNING. BEING the greater part of Lot No. 24, and a triangular portion of Lot No, 25, Block 8 on the Plan of Section 2, Highland Park Hills, and Drexel Hills, said plan being recorded in Plan Book 7, Page 38. BEING known and numbered as 1027 Drexel Hill Boulevard. BEING THE SAME PREMISES which William R. Feist, III and Mary C, Feist, by deed dated November 16, 2007 and recorded November 20, 2007 in the Office of the Recorder of Deeds in and for Curnberiand County in Instrument No. 200743489, granted and conveyed unto Ramiro R. Medellin and Teresa A. Holman, now known as Teresa A. Medellin, the Grantors herein. Being the same premises which Ramiro R. Medellin and Teresa A. Medellin, formerly known as Teresa A. Holman, by their deed dated July 25, 2011 and recorded in the Cumberland County Recorder of Deeds Office at Instrument Number 200825969 granted and conveyed onto Heather R. Knight. Being Tax Parcel No.: 26-24-0809-285 .jj Exhibit "B" Prepared By: Members 1st FCU 5000 Louise Drive Mechanicsburg, PA 17055 When recorded mail to: Services First American Equity 1100 Superior Avenue, Suite 200 Cleveland, Ohio 44114 Attn: Recording Coordinators Par,ce.1 ; a(o-ay - 08og - a85 MORTGAGE Made 09/25/2009 Between HEATHER R KNIGHT (hereinafter called "Mortgagor") And MEMBERS 1ST FEDERAL CREDIT UNION NiIIIIIUIWIIIVIN (hereinafter called "Mortgagee") Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter called the "Note") of even date herewith, payable to the order of Mortgagee in the principal sum of $ 60.000.00 , lawful money of the United States of America, and has provided therein for payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and containing certain other terms and conditions, all of which are specifically incorporated herein by reference; Now, Therefore, Mortgagor, in consideration of said debt or principal sum and as security for the payment of the same and interest as aforesaid, together with all other sums payable hereunder or under the terms of the Note, does grant and convey unto Mortgagee, All that certain property of the Mortgagor located in NEW CUMBERLAND BOROUGH , C:umhprlanrl County, Pennsylvania SEE EXHIBIT "A" which currently has the address of 1027 DREXEL HILLS BLVD [Street] NEW CUMBERLAND Pennsylvania 17070 [City] [Zip Code] Acct No c?? i e < < AppIC Page 1 of 4 Exhibit "C" Together with the buildings and improvements erected thereon, the appurtenances thereunto belonging and the reversions, remainders, rents, issues and profits thereof. To Have and To Hold the same unto Mortgagee, its successors and assigns, forever, Provided, However, That If Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum, including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder and under the terms of the Note, together with interest thereon, and shall keep and perform each of the other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby granted and conveyed shall become void. This Mortgage is executed and delivered subject to the following covenants, conditions and agreements: (1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any f;;t,:re loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall be added to the principal debt. (2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt secured hereby, (b) pa all ground rents reserved from the mortgaged premises and pay and discharge all mechanics' liens which may be filed against said premises and which shall or might have priority in lien or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax, including interest and penalties thereon, if any, now or hereafter becoming payable on the Note evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged premises, with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear, and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge the foregoing charges be paid in installments to Mortgagee. (3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair of the buildings and improvements erected thereon. Acct No AppID_ , - Page 2 of 4 (4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fails to maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the principal debt secured hereby, and collect the same as a part of said principal debt. (5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this Mortgage. (6) In case default be made for the space of thirty (30) days in the payment of any installment of principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum, additional loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice become immediately due and payable, and foreclosure proceedings may be brought forthwith on this Mortgage and prosecuted to judgment, execution and sale for the collection of the same, together with costs of suit and an attorney's commission for collection of five percent (50/0) of the total indebtedness-or $200, whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said proceedings, waives stay of execution, the right of inquisition and extension of time of payment, agrees to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions from levy and sale of any property that now is or hereafter may be exempted by law. (7) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage. Mortgagor shall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing this Mortgage, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. The covenants, conditions and agreements contained in this Mortgage shall bind, and the benefits shall inure to, the respective parties hereto and their respective heirs, executors, administrators, successors and assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each shall be joint and several. Acct No AppID Page 3 of 4 Witness the due execution hereof the day and year first above written. y L DL _ HEATHER R KNIGHT Commonwealth of Pennsylvania County of York ss: On this, the 25th day of September'__, 2009 before me, Nadine S reF' et the undersigned officer, personally appeared HEATHER R KNIGHT satisfactorily proven to me to be the person(s) whose name(s) is/are subscribed to the within Mortgage, and acknowledged that he/she executed the same for the purposes therein contained. In Witness Whereof, I hereunto set my hand and official seal. My commission expires: COMMONWEALTH OF PENNSYLVANIA Notatfal Seal lic Nadine S. rm9t, Notary Pub Nevbe?ry Twp, May 23 2013 Conanb Mem?% *#a n of Netahes Certificate of Residence of Mortgagee Members I- Federal Credit Union, Mortgagee within named, hereby certifies that its residence is 5000 Louise Drive, Mechanicsburg, PA 17055. By ?,? Acct No ApplD Page 4 of 4 EXHIBIT A All that certain property situated in the Borough of New Cumberland, in the County of Cumberland, Commonwealth of Pennsylvania , and being described as follows: 26-24-0809-285. Being more fully described in a deed dated 07/25/08 and recorded 07/30/08, among the land records of the County and State set forth above, in Instrument 200825969. Permanent Parcel Number: 26-24-0809-285 HEATHER R. KNIGHT, A SINGLE INDIVIDUAL 1027 DREXEL HILLS BOULEVARD, NEW CUMBERLAND PA 17070 Loan Reference Number 359407 First American Order No: 41154524 Identifier: FIRST AMERICAN EQUITY LOAN SERVICES 1101111111 IIIIII11111 1JI1ll1 KNIGHT 41154524 FA FIRST AMERICAN E"LS MORTGAGE IIII11111111111111111111111111111111111111111 i ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200934842 Recorded On 10/12/2009 At 10:30:27 AM ' * Instrument Type - MORTGAGE Invoice Number - 53971 User ID - KW * Mortgagor - KNIGHT, HEATHER R * Mortgagee - MEMBERS 1ST FEDERAL CR UN * Customer - FIRST AMERICAN * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $13.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.50 * Total Pages - 6 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA c? cto ° RECORDER O D EDS »so * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 1I1111111111111111111111111 (Rev. 9/2008) Date: March 29, 2011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Exhibit "D" HOMEOWNER'S NAME(S): HEATHER R KNIGHT PROPERTY ADDRESS: 1027 DREXEL HILLS BLVD NEW CUMBERLAND, PA 17070 LOAN ACCT. NO.: 0002 ORIGINAL LENDER: Members I" Federal Credit Union CURRENT LENDER/SERVICER: Members I" Federal Credit Union HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the 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 financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. Page 2 of 5 AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE. OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 1027 DREXEL HILLS BLVD 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: $76.51 for 01-21-11, $235.93 for 02-04-11, $235-93 for 02-18-11, $235.93 for 03-04-11 and 1235.93 for 03-19-11 Other charges (explain/itemize): TOTAL AMOUNT PAST DUE: $1,092.23 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE, DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,092.23 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: Members 1" Federal Credit Union, ATTN: Dave Thomas 5000 Louise Drive Mechanicsburg, PA 17055 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not ap lip cable.) Page 3 of 5 IF YOLT DO NOT CURE THE D .FAUL.T--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose L^on your mortgaged property. IF THE, MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period. Xou will f, ees. not be required to Ray attorney's OTHER ,ENDER RE. .DI . -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT T CURE TH DEFAULT PRIOR TO _SH . IFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time uR to one hour before the Sheriffs Sale You may do so by paving the total amount then east due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and an other costs connected with the Sheriffs Sale as specified in writing b the lender and b erforminan other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SH RTFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately Three (3) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lenders Members 1St Federal Credit Union Address* 5000 Louise Drive Mechanieshurg, PA 17055 Phone Number: (7171795-5]33 or (800) 283-2328 Ext. 5133 Fax Number* (717) 795-5207 Contact Persona Dave Thomas E-Mail &ddreQs• thomasd{@.memberslst.org FFF . T OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORT A G , -- You may or XX may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 5 • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Certified Mail # 9171082133393914516624 Page 5 of 5 Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565 Relief Act and Urban Development (exp 4130/2007) Notice Disclosure Office of Housing Servicemembers on "active duty" or "active service," or a dependent of such a servicemember may be entitled to certain legal protections and debt relief pursuant to the Servicemembers Civil Relief Act (50 USC App. §§ 501-596) (SCRA). Who MMI Be Entitled to Leval Protections Under the S . A? • Active duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard, and active service National Guard; • Active service members of the commissioned corps of the National Oceanic and Atmospheric Administration; • Active service members of the commissioned corps of the Public Health Service; • United States citizens serving with the armed forces of a nation with which the United States is allied in the prosecution of a war or military action; and • Their spouses. What Legal Protections Are Servicemembers Entitled To Under the SCRA? The SCRA states that a debt incurred by a servicemember, or servicemember and spouse jointly, prior to entering military service shall not bear interest at a rate above 6 percent during the period of military service. The SCRA states that in a legal action to enforce a debt against real estate that is filed during, or within 90 days after the servicemember's military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 90 days after the servicemember's military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate. The SCRA contains many other protections besides those applicable to home loans. How Does A S rvicemember or Dependent Request Relief Under the S A? • In order to request relief under the SCRA, a servicemember or spouse, or both, must provide a written request to the lender, together with a copy of servicemember's military orders. The Lender providing this Notice is Members I" Federal Credit Union, ATTN: Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The phone number is toll free (800) 283-2328. Homy Does a Servicemember or Dependent Obtain Information About the SCRA? The U. S. Department of Defense's information resource is "Military OneSource". Website: http://www.militaryonesource.com The toll free telephone number for Military OneSource are: o From the United States: 1-800-342-9647 o From outside the United States (with applicable access code): 800-3429-6477 o International Collect (through long distance operator): 1-484-530-5908 • Servicemembers and dependents with questions about the SCRA should contact their unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal assistance office locator for all branches of the Armed Forces is available at http://Iegalassistance.law.af.mil/content/locator.php form HUD-92070 (212007) HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 1/2812011 8,36:10 AM 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 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Ship Request Shipment Request Form Z900000064264 From: Name: Department: Phone: David Thomas Collections 717-795-5133 Ship To 2: Address: 1027 DREXEL HILLS BLVD NEW CUMBERLAND, PA 17070 Country: US Special Instructions: Requested Date: 3/29/2011 12:10:13 PM To print this form: 1) Click the Print button. (Print two copies, one to attach to your package and one to keep for your records.) 2) Place the form in a waybill pouch or attach it to your shipment so that the barcode portion of the page can be read and scanned. Print Close Form (1 of 1) Page 1 of 1 5 To: Ship To 1: HEATHER R KNIGHT 71p8 2133 3939 1451 6624 91 Exhibit "E" httn•//ml rrnnhec/rlpmc/( ?demsid=Z%... 3/29/2011 USPS - Track & Confirm Page 1 of 1 • Home I help I Sign in FAQ;$ Track & Confirm Search Resells Label/Receipt Number: 9171 0821 3339 3914 6166 24 Class: First-Class Mail® Track & Confirm Service(s): Return Receipt Electronic Enter Label/Receipt Number. Status: Delivered Your item was delivered at 9:29 am on March 30, 2011 in NEW CUMBERLAND, PA 17070. Detailed Results: • Delivered, March 30, 2011, 9:29 am, NEW CUMBERLAND, PA 17070 • Arrival at Unit, March 30, 2011, 8:07 am, NEW CUMBERLAND, PA 17070 • Electronic Shipping Info Received, March 29, 2011 Pk6freteon Options Return Receipt (Electronic) Verify who signed for your item by email. Gu> $ite..MeP ?u$1Q!Tnt $eryj.Qe FQrm.s. Goy't_ ! rvirva Qw.p.er$ Privacy-PQli,ey Terms of._U.Se Business-Gu.Momor_GetgW. ey c S-! Ar{ o-rl-rN li, ?cn;ic, ; n i :, Copyright© 2010 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA I, ; 4n-naq ot° rh»; I ,r?aaa, ax, i :;; r httn•//trlrrnfrml cmi Ilene rnm/PTRTnternatWPh/TntPrT.nhPlTnrntirv.dn?nriaTrackNilm=917... 5/19/2011 06/14/2011 15:16 7179320317 MEMBERS I sT FEDERAL CREDIT UNION PLAINTIFF Vs. HEATHER R. KNIGHT DEFENDANT KARLLEDEBQHM PAGE 08/08 IN THE COURT OF COUNTY, PLEAS CUMBERLAND COQ, N A 1 y PENNSYLVANIA. NO.. CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE VERI WATION I, Arlauda Dintawan, Collateral Liquidation Specialist for Members l n Federal Credit Union, being authorized to do so on behalf of Members 1a Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my Wormat7ion knowledge and belief. I understand AW false sta CM are made subject to the penalties of 18 Fa. C.S.A. Section 4904 relating to unswora falsification to authorities. Members lst pede al Credit Union Date. 4; ? /? ?- 1 $y: Arlar?? Di X nkma, qu?ion Collates Specialist 7 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY _ F' - 0 T f 1:. 1 R1;n P- Y L- i ii 1 1 ? L Members 1st FCU Case Number vs. Heather R. Knight 2011-5211 SHERIFF'S RETURN OF SERVICE 08/02/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on August 2, 2011 at 1455 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Heather R. Knight. After several attempts the Complaint in Mortgage Foreclosure has expired. SHERIFF COST: $79.44 SO ANSWERS, August 02, 2011 RON R ANDERSON, SHERIFF Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS I" FEDERAL CREDIT UNION VICE yYV;'y TksO NO AT FRO' -?JmSY! ?JA1? A PLAINTIFF Vs. HEATHER R. KNIGHT DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-5211 Civil CIVIL ACTION -LAW MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT To the Prothonotary: Please reinstate the complaint filed in the above captioned matter. Respectfully submitted, Date: August 11, 2011-L Kar . Lee , Esq. Su reme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff v Cl?14 1 ags le 40