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Home My WebLink About12-0731Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 FEDERAL CREDIT UNION PLAINTIFF Vs. MARK E. GOULD and MICHELE M. GOULD DEFENDANTS --a ""'Y Y yam{- . L n 7- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: /a - 731 a-IV i ITrm : 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE 5 ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY 103.''75 PD ATM e? I ?8? 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 corte en forma escrita sus defensas o sus obj ectiones 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 LISTED 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 1 sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: MARK E. GOULD and MICHELE M. GOULD DEFENDANT(S) : CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE COMPLAINT AND NOW, comes Members 1St Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the following complaint: I Plaintiff, Members 1St Federal Credit Union ("Members 1St"), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Defendants, Mark E. Gould and Michele M. Gould, (collectively "Defendants"), are adult individuals having a last known address of 8 Mayberry Lane, Mechanicsburg, PA 17050. 3. On or about November 20, 2007, Defendants borrowed from and agreed to repay to Members 1St FORTY THOUSAND AND 00/100 ($40,000.00) dollars (the "Loan"). The Loan is evidenced by a Closed-End Note, Disclosure, Loan and Security Agreement executed and delivered to Members 1St by Defendants on November 20, 2007 (the "Note"). A copy of the Note is attached hereto as Exhibit "A" and made part hereof. 4. As security for the Loan, Defendants executed and delivered to Members 1St a mortgage ("Mortgage") on all that certain real estate and improvements erected thereon situate in Silver Spring Township, Cumberland County, Pennsylvania, known and numbered as 8 Mayberry Lane, Mechanicsburg, PA 17050 (the "Property"). A description of the Property is attached hereto as Exhibit "B" and made part hereof. 5. On or about December 13, 2007, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office to Instrument No.:200746205. 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(s). 7. The Mortgage is in default because Defendants have failed to deliver to Members 1St the monthly payments of principal and interest due thereon on or before the first (1St) of each month in the amount of $313.93 each for September, 2011 through January, 2012, as more particularly described, in part, in the Act 6 Notice attached hereto as Exhibit "D" and made part hereof. 8. As a result of Defendants' default of Defendants' obligations under the Note and the Mortgage, on or about November 22, 2011, Members ls` provided to Defendants via regular, US certified mail, postage prepaid, return receipt requested, written notice addressed to Defendants at Defendants' last known address being the Property, of its intent to foreclose Pursuant to the Act of January 30, 1974, P.L. 13, No. 6, 41 P.S. section 101, et. seq., ("Act 6") and in particular section 403 thereof. A copy of the said notice is attached hereto as Exhibit "D" and made part hereof ("Act 6 Notice"). 9. Pursuant to notice published by PHFA in the Pennsylvania Bulletin (41 Pa.B. 2789), Members 1St is not required to provide to Defendants notice of Defendants' 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. sec.. ("Act 91"). 10. A copy of US Postal Form 3877 evidencing the mailing of the Act 6 Notice(s) is attached hereto as Exhibit "E" and made part hereof. II 12. 13. 14 15. Simultaneously, Members 1St forwarded to Defendants the same Notices as set forth in paragraph 8 above and to the same addresses as set forth in paragraph 8 above by United States mail, first class, postage prepaid, bearing the return address of Members 1St. The Notice(s) forwarded to Defendants in said manner have not been returned to the offices of Members 1 s` as undeliverable or otherwise. Defendants are indebted to Members 1St in connection with the Mortgage in the amount of THIRTY-EIGHT THOUSAND THREE HUNDRED SIXTY- SIX AND 01/100 ($38,366.01) dollars itemized as follows: a. Outstanding principal $35,596.69 b. Interest to February 6, 2012 1,740.82 c. Late Charge 78.50 d. Attorney's fees 950.00 e. Total due to Members 1St $38,366.01 Defendants also agreed under the terms and conditions of the Mortgage that in the event of default there under Defendants would pay, in addition to the amounts set forth in paragraph 12 above, costs incurred by Members 1St as a result of the institution and prosecution of these legal proceedings. The obligation owed to Members 1St continues to accrue interest at the rate of $6.9633 per day, through the date of payment and continues to accrue attorney's fees and costs. Members 1St is not seeking a judgment of personal liability (or an in personam judgment) against Defendants; however, Members 1St reserves the right to 4 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. 16. As set forth above, Members 1st has made demand upon Defendants to cure the default under the Mortgage. However, as of the date hereof, Defendants continue to fail and refuse to cure the default. WHEREFORE, Plaintiff, Members 1st Federal Credit Union, demands judgment, In Rem, against Defendants, Mark E. Gould and Michele M. Gould, in the amount of THIRTY-EIGHT THOUSAND THREE HUNDRED SIXTY-SIX AND 01/100 ($38,366.01) dollars plus interest at the rate of $6.9633 per day from February 6, 2012 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. Date: Z / 3 / 2-- Respectfully submitted, Karl M. Ledebohm, Esq. Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff F.1r:'T '. ily t? tit P15C:11 sNl ,SBII -'ra _ 1iE,?tIlERS lr' r.rl? ? I oAf,FR - _,: rD?T,;r. g7hlo, yr,Rr v.Ta ti vafnF 7_14gb MARK E._OLLD N 4, HNC JI,' uJAN NUMtlE? qtly Oi2 4'uR'. N C-I $rC(u 07 r 23429 l l t OF In dJ ' 1.)HTUFiTy CATS C - .ARIAF1l F .- J 7 120/200 12)Q :7027 ANNUAL PERCEN TAGE FINANCE CHARGE: Are, :r.t =maraca- -e amoun' of T;r?ai ul in?yrr.ents Tree anro.lf,i RATE - Tre uosi of your cfedll as a 'he eo Iar ,mount the 0-CrV f•; it cr cl, nJree to lou' _ri yo„r OLitl note polo a(-,,' you nF1 e a'e cost r.,? r_ a;f FaIn ail pa ,Ios as e,creo?ter 1q % e 5 35,42E.45 ere COG.OJ d $ ;,42F 48 r variable Rate: If your logic ties a vanable rate as ,d,eIlod above the Arvwel Pe'ccnlego Rota me,/ Increase doting tie term of Lis tra TSar ':he ill 1-, changes. 1 he -jr u? . r :ill ado a ^,argit of to old Indes union Till rate will ChinUe orllll-, u1' the Ilrs. day of Ihu mu')In. }'lla tale will nave' be I' yh;, fnnI tax, a 1/ role allowed by ' I never or, less Ulan F,ny inl ere sl ?dte increases will result -r. mar pay'rnc'it, ,-, the same enolrnl For ;,a nplo. ;our reel wu.; Pr ?? on( it, 154, lnr 18 •)I r,, nrd the Mn 1a Vr,r , n a - Pill, a crumsed by 25, a'ler in, yen/. '.nu ;anti or yore loan would HICra a::u ray ti c rnrnlh nr fervdHate I`cl)eoYC? thefc'dovAnpappleslovou?loan 'X A.,loPl Payment Discounted Rate. Ba in you have apfued e rrinke y ,,Jr nql m 'Ihly payrnenls Ihro tgn an ale mall cad r, n ro: L Fell Olg . T - r,,ounl. ;our ANNUAL Pf-PCF,,(TAGF RTA'E a_ teen ]isccunled by 2C`Ar T c AN J,'4L PERC-NTA.GC RATF dlsdosad abc' n in h;; A,NUAL PER'-ENr C, ,AIF onz s ,. e ALI- malls Pn,rn nl DISCO,rtCG Rate 1 his rate will -:ree.se by 2011L if you -case the aulcmWIC payn-ert oreangemenl or frail o ma r!?w -ft "lent f,nos n ,our account to ?vCr :1110 eulsmwl- payments In such H case. Ute C1fHC'. rl the I-rells_ xtt he 'o -lend 'rte IP.I III of vo ur can bor example i' your Auloma4C 'ay'n en D SCOIIn @d Nale IS O5c r,n i ?.;. JU0. 051uan for 50 month; and you -ease the aulima! c payment arra npame m- your taro wlu loci 1o 10resul!Ing in 1 od dlhonal payment Varlablc Kato Preforrod Loaner f your loan. is e variable rnte loan and you gaaldY for it P aterrea rate. your prclenr_d disco?.uv n taken ul Ine Ilrne yogi take nut yc,,r loan. Thly )lial pnl'ennd ANNUA_ I'ERCI,?NTAGE RATE unit Ire,, -,wy -coranlo l0 6henges in Ine Index (as disclosl•cr above j. car example. if a vanahle rate Icdr: s lower ANNUAL PE RC E', ..1,E RA`E is 12`14 al ml,! Uo e you take the teen. your initial prenm!n ar:NUA. PLr,'CE NTA,iF et l n wilt be N)A% our r lint pref-,,L AWILAL PFRI, Nt- ?,E RA'[ w.,I nerr nary al:con'7iro m Ino Inder_ as d-do-d 'r) the "Variable Hale' F+o vl nlnn Inoue Fired RdIs Preferred Loans, II your can Is ., fie: role foam and you quality for ; ;;refereed Fair yea. %r`:NI1;J_ 1-611 ,1: al AC is I/4T L. oc '.)r tree fell AIJNJAL R1,1-141 AGF Rk'E dlaclcsed above for as Icnp as you proteread stnlus rernuill in effect Nu<'rht,r <)1 PaYfnc tits ArFou n`. of paympn'.s t,ayrnenl I-,orllen'y 1h'hen Faynl-ll, Aso (ua Pruperty Insurance Oll nay n1 aim Properly I, SUrance (fowl a,iiy c'te you v?a n( (red! Is aerertable, i;' 23U S3)4 30 t.',r'I^I. - Beglrring u i,2.,...r h F, credit Imiur 11 yll) c t'he dr uriwctt Rom 1he recut U" Or JOU pa, R -5 1=1na'i Due - On it i 202? S N/A ?cu ?Ih ol, r. . in sec.rnng Jlrer loans ,,IF, ltiu crudll un orIh ,tn od= F :, e'ty __ )!;).)r 1 ISO ;-care 'h s soar Iarc 11. ving a se-,, tP :illl bt rn ,,, p r oc e:rnhni lli- It d'l end,: r;;eonslt r. ^,e -/tide orlon, and ). '.. h Clio J it I pev I In'. oy IC rays or n)o-e you wi Recl-IL Dupuo L3a:ance fins Annua' Perceltinge Rale (Ines' F0 in9 Pees frill ling Iisu ra tic o: vl : n_uge., it Ili 'Ur UI nl you. s,nedu ed payment. not lake 1011 aUCUr)l your reyuded deposit ?Htance. if any NIA c pa yrnen II you uay GH p f?. r u r el nave IU Oav ape narlY 1 5 u y u+n?,rac eo uun'ents :Ur an) itldlao real In-o?rm;I liar dbou nJnu )y r1Hnl Uola rnpu,red repayment- N'UY oe or? /.cars gist nu to I Ine s.Ae?luted dare and prcpdyrni l lalunds and penattioe ITEMIZATION OF AMOUNT FINANCED $ 10,200 Coy, Amo,, 11 Pat,] to others on your beh9lf IDescriLe) r, .L"JJNT ,IJEN TO YOU DIRECTLY 5 20 4F 82 gcoo----- $C DC 7, V. .o in ?e .,. 1 IjNT 'A C) DN YOJRACc'JJNT$ 19.L33 19 c To $ ------- 3 ?,' 3oao -o re ip=PAIL' FIN4,NCE CHARGE u3 i Jo Tc AI d4atc'.ron5 $'oC Tp Hnlen tiokumne SECURITY INFO MATION f'aeE ry'JDEr 5 0.R 'i I ILi G1REfd "InE At OF -- -- - OTHER (DesC(IhB): d r'n vV13L; RY L`,NE r T •'I0dgL shares AN1C CNT T'•CCU'JN. N,if,1R?R ahtOUNT?__ A.?;:OU NUNuE -- O'lclcr Geposds oT C, agree that.lf,c lean and Condlllons in Ire disdOsure slalenlem and Ine Ionl1 and Secufll'y agreements 'located on Uape 2 of Irils doCumbrV 51 HII apply to Ihis loan. It there Is more nA" 0,w c) ,Fo.lt WC :gret, that a.'. Ire Conditions 01 the o' n and 5eiiiUl a_1reerr 1 s governnq h s -0an s tal pply to both jointly and YeVerelly y01 acknowledge Ihal yoU h(It41 rte -f a rinpy of Ihn loan ann smut ty agreeirt and d .closwe slalerrrnt (i, gnnr, _' ypu are signing n, .u-signer- you oGkncwlJOge reef Jl of Ihu nonce to cc signer J M tR. 1 (lj 'O- {GR . Vd lv R 1 'C;,:1-SIGN, R DATE 1 _ fS1 ALi ( N , 'l [] CC-PdAKFR 'OTHER CW h'EfZ SIGNER DATE X SFAU 1, In. ur.. o?.,.. m<ai ,,..,, .. a?<, n,.m<c..l c ...,n .n r•a .va .,. <,. n.a a. .., aau<u. n. .,., ?. I.< APPLICATION FOR 6RI CREDIT INS(,RANCE ' , h ) ? pe(b) eele tBO bla .ant nprx, " r .Ire rep u: as prom uT ehldnd n. tons - n r, `. lr .w e Ca -1 lo, ll ii unUy and el ev ed 0 c a C JeA and In8 l er; or-not, y tiny tie -1 a..C tl Ili, In 1 s . '.I d 'fr.d it f M de Ile one trot C65 yne r I _' 'I U ? rrr lul ow ,? ?us514n s. and . ms f( be answered in it. lnrmlno 'Y n rr) e. , In Ira+ rdnr_e tDt' cl c le •s.r ctt u ,-ere pr :r.ly/ J.51 you Uc a ra•Jr roe ....,e s<ned/ ed rrp'u.,r .Cato ref vcu' r Lv c-.I t eon ,. it you rx a ago ?o Ih Cnea e malunt, I t o cUl I , 1? ..r Ii,g Fri, "'lien n e 'r_ ere fU .wades or prod IG 3(hevrS c /'sole Gtl wEth dad cave n9e9 se -",Q o 111 ^,dys , r .re Ina ia.e +uallio r.. ? it . , ede S :5 Ui:.6o r uilowuip yu . . .. < ^, p,nu;, ___ _ _ - . [ 13 ,r 5 (,e F- -. $yn„ . lp „l,lD$j n DS I c rr. ,r r -. _- .- i vn 1 fns. vr.r a. ...c,v 1 r ref ./.r ` ? L r 1- ._ _.. _ v ,.e ...n. nr•u :Iron ?r rln n uC J` y _r "Y? s ' t r.0 -,rOt? .S rv? und8151and Ne V.a art e p 0'e if nee a , are r.U 1 nJ L W I " I rw dale o lr.z aprN Cobs Ary Ire ti er, know olv ,n r I I ,ol l _ c ^ U I rH ary. II I le I' lu)O furmi,:-l-'f dl 1 1 to rl 11 - yll ,f 7 [ ' , n "Cl t p¢° t I n D', r "U" e r c a; y r ,11i.s e r avid r . f..t a ?„ orl it r acv cam ? t dvc rot -1 _nrrap err nahlrtr h- - """'n and Ue- I. (1 ]pp ---d l l>n Ov al ., f, 11 r. C .v l-I ,PEU'T I.N"UPAI Ali tit Fp R: N:I TE JNI , i)NG ATllr, N ',JAY n, -,Y SCR DISA Pi L'. T, COVL-RAGE _ Y_5 x_: NG Jiflg l9 Credll Life Total rare ii)Lfl' la iAJ NO, ,-,rP. LII L71?ar.h''!}' TOIa! PrgrTllu ;T'? - Y=s _ X l h,c Joint Credll i_ite C81E v.^tr IP?h;: are. tl, sl _ WJnu?n1 ??I Co_/)p pli Ulnl $ C.00 1, Jicate wnlul egad-anl(51 AnPI c srt -? .ppnra?t $ D DO ered Dory far In ryp•s of c /uyu lur wnlcn a girl arge Is I'd-ell - N c SI NAT D TE 0' I31RTIl DATr L Art lJC N1 . !, URI c DA IE 7F EIATH D 7F l ? ATE yy? SFC ?...? ?_ Exhibit "A" NAMED AS BORROWER(S). - - - - -- - LOAN AGREEMENT Payments/Finance Charges: For value received, you promise to pay, at the Credit Union's office, all amounts due. All payments shall be made pursuant to the disclosure statement on page 1 of this document. You understand that the finance charge and total of payments shown on page 1 of this document are based on the assumption that all installment payments will be made on the scheduled due dates, and , if you have qualified for preferred rate that you continue to satisfy the conditions of that preferred rate. It you fait to pay any installment by the time It Is due, you will pay additional interest on the overdue amount. Allocation of Payments and Additional Payments: Payments and credits shall be applied in the following order: any amounts past due; any fees or charges owing, including any insurance premiums; accrued interest or finance charges; outstanding principal. Payments made in addition to regularly scheduled payments shall be applied in the same order. Preferred Rate: It you quail (y for a preferred rate as disclosed on page 1 of this document or in a separate preferred rate addendum, you understand that you must meet the conditions disclosed to you in order to qualify for the preferred rate, and must continue to meet those conditions in order to keep your preferred rate. If you tail to meet those conditions, your rate will increase, thereby extending the terms of your loan. You promise to continue making payments and to meet all obligations under this Agreement even if you no longer receive the preferred rate. Late Charges: If you make a late payment, you agree to pay a late charge it one is disclosed on page 1 of this document. Property Insurance: If you obtain a loan secured by a motor vehicle or other tangible property, you must obtain Insurance which protects the credit union from financial loss. The amount and coverage of the property insurance must be acceptable to the credit union. Such a policy must provide at least Ore, theft. combined additional coverages and collision insurance it must contain a Loss Payable clause endorsement naming the credit union as lien holder. You may obtain this insurance from any agent of your choice and direct the agent to send the credit union a copy of the policy Debtor Responsibility: You promise to notify credit union of any change in your name address or employment. You promise not to apply for a loan if you know there is a reasonable probability that you will be unable to repay your obligation according to the terms of the credit extension. You promise to inform credit union of any new information which relates to your ability to repay your obligation. You promise not to submit false or inaccurate information or willfully conceal information regarding your creditworthiness, credit standing, or credit capacity. Default: You shall be considered in default if any of the following occur: 1) If you break any promise made under this Loan Agreement or under the Security Agreement; or (2) if you do not use the money the credit union loaned you for the purpose stated in your application; or (3) if the credit union should, in good faith, believe that prospect of payment, performance or realization of the collateral, If any, is impaired; or (4) if you die; or (5) H you file a petition in bankrupt ccyyis", olvency, or receivership or are put nvoiuntonly into such proceedi; or (6) f the collateral, if any, given as secunty for this account is lost, maged or destroyed, or if it is levied against attached or garnished; or (7) if you do not pay on time any of your other or future debts o the credit union. If you default, the credit union may, at the credit union's option and without prior notice, declare this loan immediately due and payable, and you must immediately pay to the credit union at that time the total unpaid balance, as well as the Finance Charge to date, any late charges and costs of collection permitted under law, including reasonable attorney's fees, that the credit union may incur, up to 20% of the unpaid principal and interest. Costs of collection include, but are not limited to. repossession fees. appraisals, environmental site assessments, casualty damage insurance coverage, and allomey's fees for any action taken by an attorney in order to collect this loan or preserve or protect the credit union's rights and remedies, Including, without limitation, pre-suit demands for payment pre-sull mediation or settlement neggotiations, Irvestigation and assessment of the credit unions' rights, paAicipation in bankruptcy cases, matters, and proceedings (including, without limitation, filing proofs of claim, pursuing reaffirmation agreements, attending meetings of creditors, and pursuing complaints, motions, and objections that relate in any way to the credit union's collateral or right to pa ment), collateral disposition, rein-bankruptcy suits and/or administrative actions, and appeals. The principal balance in default shat' bear interest at the contract rate Statutory Lien: If you are in default, federal law gives the credit union the right to apply the balance of shares and/or dividends in our account(s) at the time of default to satisfy this loan, Once you are in default, the credit union may exercise this right without further notice to you. Delay in Enforcement: Credit Union may delay enforcing any of the credit union rights under this agreement without losing them. Irregular Payments: The credit union may accept late pa ments or partial payments, even though marked "payment in full,' without losing any of the credit union rights under this agreement. Co-makers: It you are signing this agreement as a co-maker, you agree to be equally responsible with the borrower, but the credit union may sue either or both of you. The credit union does not have to notify you that this agreement has not been paid. The credit union may extend the terms of payment and release any security without notifying or releasing you from responsibility on this agreement. Contractual Pledge of 5hares: You pledge all your shares and deposits in the credit union, including future additions, as security for this loan. In case you default, the credit union may apply these shares and deposits to the payment of all sums due at the time of default, Including costs of collection and reasonable attorney's fees, that the credit union may Incur, up to 20% of the unpaid principal and Interest. No lien or right to Impress a lion on shares and deposits shall apply to any of your shares which may be held In an "Individual Retirement Account" or "Keogh Plan." SECURITY AGREEMENT 1. To secure payment of this loan and all expenditures Incurred by the credit union in connection with this loan, or In realizing on a security ? serest, you grant to the credit union a security interest in the propert y described on page 1 of this document. The security interest includes all Increases, substitutions and additions to the secured property, proceeds from any Insurance on the secured property and all earnings received from tho secured property. Cross-collaterallzation: Progeny given as security for this loan or for any other loan Borrower has wiet the credit union will secure all amounts Borrower owes the credit union now and In the future. However, properly securing another debt will not secure this loan If such property it, Borrower's principal residence (unless the proper rescission notices are given and any other legal requirements are sallsfled), or are non-purchase money household goods. 2. You will not change the location of, sell or transfer the collateral unless you have the credit union's prior written consent 3. You warren; that you have good title to the cdllateral, free of all security interests except that given to the cr It union and except for any interest of a nomco- maker owner of the collateral who has signed the agreement in the indicated place. 4. You will pay all taxes, assessments, and fiens against or attached to the properly described and further agree to keep the property in gpood condition, housed in a suitable shelter. You agree to execute financing statements and security agreement amendments at the credit union's request and will defend the properly against adverse third party claims 5. You will maintain Insurance to cover any vehicle or other property in which me credit union ties a security interest. This insurance will be w e form and an amount satisfactory to the credit union You will supply the credit union with proof of such insurance until all sums owed to credit union and secured by this Property are repaid. ff you fail to malnlain such insurance, credit union may, bu s not required a, obtain insurance of our awn and add the cast of such to the sums owed. This cost will bear interest at the contract rate unit! paid. You turiner assign to the credit union the nghl to rocaiva the proceeds of any insurance on such property, and direct any insurer to pay those proceeds direcoy to croon union. You authorize the credit union to endorse any check or draft provided as the proceeds of such insurance, and apply those proceeds to the sums owed to the credit union You further authorize the credit union to provide your Insurance Service Center with the necessary information for verification of adequate coverage. Vou acknowledge that insurenceor anyy extension thereat, placed by the credit union is without benefit to you individually but Is primarily for the pro action of the credll union. 6. Should the credit union feel at any time that the security presented has diminished in value, or for any reason feet that addilionef seamN is required, Yyou agree to assign to credit union within ten (10) days whatever additional secunty the credll union feels is necessary to protect the credit union against possible loss. 7, If a default as defined in the Loan Agreement should occur, the credit union has the authority, 9011 such default, to repossess and sell the collateral in lawful manner. In such case, the credit union or the credit union's authorized represenletives may, at the credit union's option, em9r the premises where the collateral is kept and take possession, subject to applicable laws. The credit union has the rigght to render the properly pledged as collateral unusable and may dispose of the collateral on fife premises where the collateral is kept. If the vedlt union decides to sell the collateral at a public sale, private sale or otherwise dispose of the collateral, the credit union will notify you of the lime and place of the intended disposition ten (10) days pprior to the sale or disposition. If e credit union sells or otherwise disposes of (he collateral the credit union may collect form you reasonable expenses Incurred in the retaking, holding and oy appucaowe law, incurred in connection min disposition of the properly. unless you default, you they keep possession of the property (collateral) described and use it in any lawful manner consistent with this agreement! or with the insurance poBcy re on the collateral. You understand that to credit union has teriein ngttls and fagot remedies avaNdble to the credit union under the Uniform Coo' focal Code antl other appficab a laws and that the credll union may usa these nohte to enforce payment if you default. In that event, you will at the credll union's quest ass e mble t he properly (collateraq and make it available to the credit union et a place or the credll union's choosmp. It the credit union decides to welve,his delsuit I I will not constitute waiver of any other subsequent defaults. The Credit union is hereby appointed as your Atiorruy-In-Facl io perform anyy acts which the credit union feels are necessary to protect the collateral and tho security Interest which this agreement creates If there is more then one borrower, your obligations under this agreament are joint and several, each being equally responsible to fulfill the terms of this agreement. This security agreement not only binds you, but your executors, administrators, heirs, and assigns. 6100 2/99 NOTICE TO CO-SIGNER You are being asked to guarantee this debt, Think carefully before you do. If the borrower doesn't pay the debt, you will have to. Be sure you can afford to pay it you have to. and that you want to accept this responsibility. You may have to pay up to the full amount of the debt if the borrower does not pay. You may also have to pay late fees or collection costs, which increase this amount. 7 he creditor can collect this debt from you without first trying to collect from the borrower The creditor can use the same coiiectlon methods against you that can be used against the borrower, such as suing you, garnishing your wages, etc. It this debt is ever in default that fact may become a part of your credll record This nclice is not the contract that makes you table for I e debt. ALL THAT CERTAIN lot of land situate in the Township of Siiver spring, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the eastern line of Mayberry lane 150 foot right of way), at the suuthwrestem comer of Lot No. 29 on the hereinafter mentioned Mari of Lots; THENCE along the southern line of Lot No. 29, North 84 degrees 59 minutes 52 seconds East, a distance of 274.72 feet to a point at line of lands now or formerly of John Erdis; THENCE along said Erdis lands, South 48 degrees 43 minutes 37 seconds East, a distance of 18.68 feet to a point at line of iands now or fate of Harold D. Stoner, THENCE along the western line of said Stoner lands, South 42 degrees 03 minutes 58 seconds West, a distance of 183.81 feet to a point at the northaastern comer of Lot No. 31 on the hereinafter mentioned Flan of Lots; THENCE along the northern line of Lot No- 31, North 72 degrees 05 minutes 02 seconds Wast, a distance of 181.! 7 feet to a point on the eastern line of Mayberry Lane; YHENCE along Mayberry Lrarier by a curve to the left having a radius of 150 feet, 3n arc distance of 70.00 feet to a point, the place of BEGINNING. BEING Lot No, 30 on the Final Major Subdivision Plan of Section 2, part 1J, Brandywine Village as recorded in the Cumberland County Recorder's Office in Plan Book 32, page 100. UNDER AND SUBJECT to a 16 foot storm sewer easement along property line of Lot No. 30 and Lot No_ 31, Section No. 2, part B, Brandywine Village, described in accordance with survey prepared by Robert G. Hartman, Jr., Registered Surveyor, dated November 11, 1983, described as follows, to wit: BEGINNING at a paint on the southern right of way line of Mayberry Lane, said point being located 363.17 feet in an easterly direction from the North end of a 7.92 feet arc connecting the eastern right of way line of Mayberry lane, a 50 foot right of way to the northem right of way line of Longview Road, a 50 foot right of way; THENCE from the point of beginning along the southem right of way line of Mayberry Lane on an arc of a curve curving to the left, having a radius of 175 feet and an are iength of 16.006 feet to a point; THENCE through Lot No. 30, South 72 degrees 05 minutes 02 seconds East, a distance of 133.65 feet to a point; THENCE through Lot 30 and Lot 31, South 48 degrees 38 minutes 35 seconds East, a distance of 46.80 feet to a point on the rear property line of Lot 31; THENCE along same, South 42 degrees 03 minutes 58 seconds West, a distance of 16 feet to a point; THENCE through Lot 30, North 48 degrees 38 minutes 35 seconds West, a distance of 43.28 feet to a point; THENCE through same, North 72 degrees 05 minutes 02 seconds West, a distance of 130.33 feet to a point, the point of BEGINNING. Together with improvements erected thereon known and numbered as 8 Mayberry Lane, Mechanicsburg, PA 17050. Being the same premises which James R. Lauer and Barbara J. Lauer by their deed dated July 30, 2004 and recorded in the Cumberland County Recorder of Deeds at Deed Book 264, Page 2461 granted and conveyed onto Mark E. Gould and Michele M. Gould. Tax Parcel No.: 38-21-0289-056 Exhibit "B" 02!01/12 09:35 FAX 7172438955 Douglas Law OfriceZ007 Prepared By: Members 1st FCU 5000 Louise Drive Mechanicsburg, PA 17055 When recorded mail to: I;IRST AMERICAN TITLE INSURANCE LENDERS ADVANTAGE 1100 SUPERIOR AVENUE, SUITE 200 CLEVELAND, 011I0 44114 ATTN: FT1120 MORTGAGE Made 11/20/2007 Between MARK E GOULD AND MICHELE M GOULD (hereinafter ca ed 'Mortgagor") And MEMBERS IST FEDERAL CREDIT UNION (hereinafter called "Mortgagee") (-Z? 51 M 6 G Whereas, Mortgagor has executed and delivered to Mortga ec a certain Mortgage Note (hereinafter called the "Note") of even date herewith, payable to the order of Mortgagee in the principal sum of $ 40000.00 , lawful money of the United States of America, and has provided therein far payment of any addttional moneys loaned or advanced thereunder by Mortgagee, together with interest thereon at the rate provided in the Note, in the manncr and at the times therein set forth, and containing certain other terns 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_ SILVER SPRING TORNSHIP__ _ -Cumberland___ County, Pennsylvania SEE EXHIBIT "A" which currently has the address of _ 8 MAYBERRY LANE [Street] Mechanicsbur?_ Pennsylvania 17050 [City] [Zip Code] n 23429602 Page 1 of 4 ua No AppID Exhibit "C" 02 01'1L 09:36 FAX 717?438955 Douglas Law Office ? 008 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 shalt 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 shal I keep and perform each of the other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby granted and conveyed shall become void. This Mortgage is executed and delivered subject to the following covenants, conditions and agreements: (1) The Note secured hereby shall evidence and this Mortgage shall cover and be security for any future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall be added to the principal debt. (2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and discharge, when and as the same shat l become due and payable, all taxes, assessments, sewer and water rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt secured hereby, (b) pay all ground rents reserved from the mortgaged premises and pay and discharge all mechanics' liens which may be filed against said premises and which shall or might have priority in lien or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax, including interest and penalties thereon, if any, now or hereafter becoming payable on the Note evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged premises, with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear, and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing charges; provided, however, that Mortgagee may at its option require that sums sufficient to discharge the foregoing charges be paid in installments to Mortgagee. (3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair of the buildings and improvements erected thereon. Aai No _ , _ AppiD_ 23429602_ Page 2 of 4 02,/0112 09:36 FAX 71 2438955 Douglas Law ol.fice o09 (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 al I or any part of the mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this Mortgage. (6) In case default be made for the space of thirty (30) days in the payment of any installment of principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum, additional loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice become immediately due and payable, and foreclosure proceedings may be brought forthwith on this Mortgage and prosecuted to judgment, execution and sale for the collection of the same, together with costs of suit and an attorney's commission for collection of five percent (5%) of the total indebtedness or $200, whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said proceedings, waives stay of execution, the right of inquisition and extension of time of payment, agrees to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions from levy and sale of any property that now is or hereafter may be exempted by law. (7) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage. Mortgagor shall pay any recordation costs. Mortgagee may charge Mortgagor a fee for releasing this Mortgage, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 'I'hc 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_ 23429602 Page 3 of 4 0201 12 09:36 1`:1\ 7172438955 Douglas Lai Office Witness the due execution hereof the day and Commonwealth of Pennsylvania County of CUMBERLAND ss: _ On this, the 2 0 th day of NOVEMBER 2007 , before me, r,r. M- the undersigned officer, personally appeared MARK E GOULD AND MIC Eli 01,11D _ -- - - - _- satisfactorily proven to me to be the person(s) whose name(s) is/are subscribed to the within Mortg-age, and acknowledged that he/she executed the same for the purposes therein contained. In Witness Whereof, 1 hereunto set my hand and official seal. My commission expires: 0010 COMMONWEALTH OF PENNSYLVANIA Notauiel Seal Isodwn M. Worley, NotaM, Public Lower Alen Twp,, Cumbeow:d Cr,;+q, MY Commission r.=s Apr. -?OC9 Member,Per.r.?yrosai C ,")o,.. wriaa Members I- Federal Credit Union, Mortgagee within n ed hereby certifies that its residence is 5000 Louise Drive, Mechanicsburg, PA 17055. By Aw No _ AppiD 23429602 Page 4 of 4 02?01?12 09:37 1=A1 7172438955 llouglas La%% Office 011 EXHIBIT A All that certain property situated in the Township of Silver Spring, in the County of Cumberland, Commonwealth of Pennsylvania , and being described as follows: 38-21-0289-056. Being more fully described in a deed dated July 30, 2004 and recorded August 03, 2004, among the land records of the County and State set forth above, in Deed Volume 264 and Page 2461. Permanent Parcel Number: 38-21-0289-056 MARK E. GOULD AND MICHELE M. GOULD, HUSBAND AND WIFE 8 MAYBERRY LANE, MECHANICSBURG PA 17050 Loan Reference Number 234296 First American Order No: 13572995 Identifier: FIRST AMERICAN LENDERS ADVANTAGE YII1II ANJ 1110 COULD 13572995 PA FIRST AMERICAN LENDERS ADVANTAGE MORTGAGE IIIIUIII1411144NiI IIUIIIIIIII IIA gIII I IIII lil 02/0112 09:37 1'_11 7172435955 1)011gL?js Lac+ office ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200746204 Recorded On 12/13/2007 At 12:35:04 PM * Instrument Type - MORTGAGE Invoice Number - 10725 User ID - MSW * Mortgagor - GOULD, MARK E * Mortgagee - MEMBERS 1ST FEDERAL CR UN * Customer - FIRST AMERICAN * FEES STATE WRIT TAR $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $13.50 RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $40.50 * Total Pages - 6 Certification Page DO NOT DETACH This page is now part of this legal document. 1 Certify this to be recorded in Cumberland County PA : o RECORDE/R O D DS taao * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0012 MiV!AIGOIIOCL5 IIVNM Date 11/2 2,12011 NOT ICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Members lst Federal Credit Union (hereinafter we, us or ours) on your property located at 8 MAYBERRY LANE, MECHANICSBURG,PA 17050 IS IN SERIOUS DEFAULT [because you have not made the monthly payments of $225.39 for 91112011, 5'313.93 for 101112011 and $313.93 for 11 '112011] The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $853,20 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $853.20, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at: Attn: Collections Department c/o Memberslst Federal Credit Union P.O. Box 40 5000 Louise Drive Mechanicsburg, PA 17055 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. if the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $ 50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $ 50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. lf'you cure the default within the thirty day period, you will not be required to pay attornei's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage ]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six months from now. A notice of the date of the Sheriff 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 will be by calling us at the following number: (717) 795-5165. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict vou. Exhibit "D" You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF ]'HE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RJGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if'no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Certified Mail: 91 7199 9991 7030 0943 0143 You have additional rights to help protect your interest in the property. YOU 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. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. I?you cure the default, the mortgage will he restored to the same position as' if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Certified Mail: 91 7199 9991 7030 0943 0105 Servicemembers Civil U.S. Department of Housing MB Approval No 2502-0565 Relief Act and Urban Development (exp 4/30/2007) Notice Disclosure Office of Housing Legal Rights and Protections Under the SCRA Servicemembers on "active duty" or "active service," or a dependent of such a servicemember may be entitled to certain legal protections and debt relief pursuant to the Servicemembers Civil Relief Act (50 USC App. §§ 501-596) (SCRA). Who May Be Entitled to Legal Protections Under the SCRA? 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 Servicemember or Dependent Request Relief Under the SCRA? In order to request relief under the SCRA, a servicemember or spouse, or both, must provide a written request to the lender, together with a copy of servicemember's military orders. The Lender providing this Notice is Members V Federal Credit Union, ATTN: Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The phone number is toll free (800) 283-2328. How Does a Servicemember or Dependent Obtain Information About the SCRA? The U. S. Department of Defense's information resource is "Military OneSource". Website: llttp:/,/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://le2alassistance.law.af.mil/content/locator.php Form 3877 `' , Q'_ s Name aril Address. Permit Number MAC Cert Ver Nuns D' r Sequence Number. P?1FCFiANICSBURG Fr C10009i11 Pc ID rt; Addressee Name Postage ES ES Insured Due Total Article 4 Delivery Address Type Fee Value Sender Charge 2900000072639 ?arK Gouic G 44C 850 r DC 44i 91-199999170300943,1145 3 Mayberry Lane RR 15G C+000JUU-2647 tvlcnele hUu1c G 440 X50 O OG 4 44 31 1 go99917030094301 O` PAevoerr, ?anr' ERP. 15U VeC'IHnICSbUIC P;'7050 Page I otals: 7.200 60.000 67.200 Cunt Totals: 16 8.680 64 000 . 72.680 Exhibit 44 p Form 3877 Jr S Name ana Haaress Pc ID #r Addressee Narne Article 9 Delivery Address beguence Number: Postage ES ES Type Fee Page Totals: 1 1.480 Cuni Totals: 16 8.680 'ermit Number. MAU Cert Ver. Nurn i Itccci?.,?1 / _'l l.il lli ,' IBC SCIAi 11 L I, II I?P.'1 C, ??-??? R ?Vetf+v?Ei_.. 4.000 64.000 `--?az - f?? .• (( r ?-.:: .: :A. .ter Y ?. I Insured Due Total Value Sender Charge 5.480 '2.680 01/30/2012 17:39 7179320317 KARLLEDEBOHM PAGE 07/07 MEMBERS 1 ST FEDERAL : IN THE, COURT OF COMMON PLEAS CREDIT UNTON CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.. MARK E. GOULD and M.TC14ELE M. GOULD DEFENDANT(S) : CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE VERIFICATION I, Dave Thomas, Lead Collector for Members Vt Federal Credit Union., being authorized to do so on behalf of. Members 1' Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information knowledge and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4944, relating to unsworn falsification to authorities. Members I' Federal Credit Union. Ala I,z Dave Thomas, Lead Collector 6 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Members 1st FCU vs. Michele M. Gould (et al.) THE 'PROTHONOTAPk . att)?tr o! C 111"b"'141 b 2012 FEB t AM 10' CUM CNNSYLgs A T`r QFF,?E F Tr;E g..;R1FF D Case Number 2012-731 SHERIFF'S RETURN OF SERVICE 02109/2012 02:30 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on February 9, 2012 at 1430 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Michele M. Gould, by making known unto herself personally, at 8 Mayberry Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same_ N BENDER, DEPUTY 02/13/2012 08:00 PM - Timothy Black, Deputy Sheriff, who being duly sworn Mccording to law, states that on February 13, 2012 at 2000 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Mark E. Gould, by making known unto himself personally, at 8 Mayberry Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. Timlbl,ACK, DEPUTY 02/14/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Occupant of 8 Mayberry Lane, Mechanicsburg, Pennsylvania 17050, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Occupant. Request for service at 8 Mayberry Lane, Mechanicsburg, Pennsylvania 17050 is only occupied by Mark and Michele Gould, Husband and Wife. SHERIFF COST: $75.45 February 14, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF 41 :' Counh"Suite. She?dl Tee! 'qs: ft. !n:: It T H;: 20 12 HA 23 Ate 11 04 CUMBERLAND COWN PENNSYLVANIA Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1" FEDERAL CREDIT UNION PLAINTIFF Vs. MARK E. GOULD and MICHELE M. GOULD DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-731 CIVIL ACTION - LAW MORTGAGE FORECLOSURE PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter judgment in the above captioned proceeding in favor of Members 1St Federal Credit Union, Plaintiff, and against the Defendants, Mark E. Gould and Michele M. Gould, in the amount of THIRTY-EIGHT THOUSAND SIX HUNDRED SEVENTY-NINE AND 36/100 DOLLARS ($38,679.36) plus interest at the legal rate on and after entry of judgment until the date of payment, additional attorney's fees and costs of suit and for foreclosure and sale of the mortgaged property. Judgment is entered pursuant to Pa. R.C.P. 1037 for failure to file an Answer on behalf of Defendants, Mark E. Gould and Michele M. Gould, to Plaintiffs Complaint within twenty (20) days of service thereof and after a 10-day Notice was sent. Sr -4--v /A 5-34 ?.j (q /IWJc l f A z; le ?/1 Respectfully submitted, Date: March 22, 2012 ,ed bohm, Esquire Court ID #59012 P.O. Box 173 New Cumberland, PA 170700173 (717)938-6929 Attorney for Plaintiff I hereby certify that notices of intent to take default judgment were forwarded to Mark E. Gould and Michele M. Gould by United States Mail, first class, postage prepaid on March 6, 2012. The aforesaid notices were each contained within an envelope bearing the return address of the undersigned. The notices have not been returned to the undersigned as undeliverable or otherwise. A copy of the notice and Postal Forms 3817 are attached hereto and marked Exhibit "A" I , Karl M. Ledebohm P.O. Box 173 New Cumberland, (717)938-6929 Esquire PA 17070-0173 \4I:MBI1IZS I FT" D F R A 1. ('RIDI I'I IMON PLAIN FIFI, Vs. MARK E. GOULD and MICHELE M. GO[ 1LD DEFENDAN"I S IN THE COURTOF COMMON PI-F:AS CUMBERLAND COUNTY. PENNSYLVANIA NO.: 12-731 CIVIL ACTION - LAW MORTGAGE FORECLOSURF IMPORTANT NOTICE Date: March 6, 2012 TO: Mark E. Gould Michele M. GoLild 8 Mayberry- Lane Mechanicsburg, PA 17050 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS OFFICE IS A DEBT COLLECTOR AND THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU ARE IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT TO ENFORCE A LIEN UPON REAL ESTATE. YOL ART: IN DFFAULT BECAUSE YOU HAVE FAILED TO EN"LER A "'k11'1'EN API'LARANC ' PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WFITI THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SE'1'h'OR1'H AGAINST YOU. UNLESS YOU ACTT WITHIN TEN DAYS FROM 1"1-IE DAT F: OF THIS NOTICE, A JUDGMENT MAY BE ENTERED Exhibit "A" AGAINS"T" YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPER]'Y OR OTHI--'R IMPORTANT RIGHTS. YOU SHOt I.D 'FAKE: "PHIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO"I' HAVE A LAWYER. GO TO OR 'hELEPHONE THE OFFICE SL'l FORT11 131-TOW. THIS OFFICE (`AN PROVIDE: YOU WI"I'H INFORMATION ABOt I I HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOt_) WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER L.I"GAL SERVIC'ES "fO 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 Respectfully whnutted, Date: March 6. 2012 /Karl M. Ledebohm, Esq. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-017') (717) 938-6929 Attorney for Plaintiff C UNITED ST13TES Certificate Of POST/SL SERVICE Mailing C ,` t aili-g -evides evidence that mail has been presented to USPSC for mailing. il l m ti ?. p ona - „ jo- 7omestic and interna r m FrO(11 o p A?- __ O N Karl M. Ledebohm, Esq. - P.O. Box 173 - _ New Cumberland, PA 17070-0173 , _ Fn_ o C c7 • To. N OoZb5z' _._. Mark E. Gould W ° ?--? CtTOrn-'O Z o °°° 8 Mayberry Lane C3L31 N - Mechanicsburg, PA 17050 m =o PS Form 3817 April 2007 PSN 7530-02-000-9065 leg UNITED STATES Certificate Of JMW POST13L SERVICE, Mailing' C This Certificate of Mailing provides evidence that mail has been presented to USPS0for mailing. This form may be used for domestic and international mail. o a C_ From: o ?. o G - Karl M. Ledebohm, Esq. _ P.O. Box 173 New Cumberland, PA 1 7070-0 1 73 X 0 3 C o D r? To: Michele M. Gould - 8 Mayberry Lane - Mechanicsburg, PA 17050 PS Form 3817. April 2007 PSN 7530-02-000-9065 altw-r UI 35o -C33in W. C07Crrlr-+-u Q7?r Z• x!'000 ?l •of- 0 r o N Z D A O 0 rn ?o .D 4 A #F7€0 i. i 2012 MAR 23 AM 11: 015 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 (717)938-6929 MEMBERS I" FEDERAL CREDIT UNION PLAINTIFF Vs. ;CUMBERLAND CQUN T PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-731 MARK E. GOULD and CIVIL ACTION - LAW MICHELE M. GOULD DEFENDANTS MORTGAGE FORECLOSURE AFFIDAVIT OF NON-AULITARY SERVICE The undersigned hereby swears and affirms on behalf of Members 1St Federal Credit Union, the Plaintiff in the above captioned matter, that to the best of Plaintiff's knowledge, Mark E. Gould and Michele M. Gould are not currently on active military service. Date: March 22, 2012 xarl M. LWebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070 (717)938-6929 MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF : Vs. NO.: 12-731 MARK E. GOULD and CIVIL ACTION - LAW MICHELE M. GOULD DEFENDANTS : MORTGAGE FORECLOSURE NOTICE OF JUDGMENT PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE TO: Mark E. Gould Michele M. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 You are hereby notified that on J -c4 3 -lo)- , 2012 the following judgment has been entered against you in the above captioned case: Judgment in favor of Members 1" Federal Credit Union, Plaintiff, and against the Defendants, Mark E. Gould and Michele M. Gould, in the amount of THIRTY- EIGHT THOUSAND SIX HUNDRED SEVENTY-NINE AND 36/100 DOLLARS ($38,679.36) plus interest at the legal rate on and after entry of judgment until the date of payment, additional attorney's fees and costs of suit and for foreclosure and sale of the mortgaged property. Judgment is entered pursuant to Pa. R.C.P. 1037 for failure to file an Answer on behalf of Defendants, Mark E. Gould and Michele M. Gould, to Plaintiff's Complaint within twenty (20) days of service thereof and after a 10-day Notice was sent. Dated: Prothonotary is: I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236 Mark E. Gould Michele M. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 A: Mark E. Gould and Michele M. Gould Por este medio se le esta notificando que el de 2012 el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso mencionado en el epigrafe. Fecha: Protonotario Certifico que la siguiente direccion as la del defendido/a segue indicada en el certificado de residencia: Mark E. Gould Michele M. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 Date: March 22, 2012 H ,Karl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 1 7070-0 1 73 (717)938-6929 Attorney for Plaintiff 0TH;"It 2? 12 MAY 14 PM 3: 1" GUMBERLAN t; 'U. PENNSYLVANIA Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 J' FEDERAL CREDIT UNION PLAINTIFF Vs. MARK E. GOULD and MICHELE M. GOULD DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-731 CIVIL ACTION - LAW MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, Amount Due: $38,679.36 Interest from: 3/23/12 at the legal rate Attorney's fees $ to be added Costs $ to be added (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Mark E. Gould, 8 Mayberry Lane, Mechanicsburg, PA 17050, defendant; (3) against Michele M. Gould, 8 Mayberry Lane, Mechanicsburg, PA 17050, defendant; (4) and against N/A Garnishee (s); (5) and index this writ against Mark E. Gould and Michele M. Gould, 8 Mayberry Lane, Mechanicsburg, PA 17050, defendants; (a) against N/A Garnishee (s), and levy upon and seize the following real property of Defendants and index this writ against the following real property of Defendants as a lis pendens: All that certain real estate and improvements erected thereon situate in Silver Spring Township, Cumberland County, Pennsylvania, known and numbered as 8 Mayberry Lane, Mechanicsburg, PA 17050 and as more particularly set forth and described on Exhibit "A" attached hereto and made part hereof by reference. Dated: May 7, 2012 0-S 4.2 8-S-0 P0 AYW 15, q5 CBF /03.75 " 9.5o oZd to . 0 - Pp A77Y N- I?firl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff $.28. Sa -?L e& I-T77 ?a.a.5 ?- '?2-*? o?.7Sl7 50 LI . ALL THAT CERTAIN lot of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the eastern line of Mayberry Lane (50 foot right of way), at the southwestern corner of Lot No. 29 on the hereinafter mentioned Plan of Lots; thence along the southern line of Lot No. 29, North 84 degrees 59 minutes 52 seconds East, a distance of 274.72 feet to a point at line of lands now or formerly of John Erdis; thence along said Erdis lands, South 48 degrees 43 minutes 37 seconds East, a distance of 18.68 feet to a point at line of lands now or late of Harold D. Stoner; thence along the western line of said Stoner lands, South 42 degrees 03 minutes 58 seconds West, a distance of 183.81 feet to a point at the northeastern corner of Lot No. 31 on the hereinafter mentioned Plan of Lots; thence along the northern line of Lot No. 31, North 72 degrees 05 minutes 02 seconds West, a distance of 181.17 feet to a point on the eastern line of Mayberry Lane; thence along Mayberry Lane by a curve to the left having a radius of 150 feet, an arc distance of 70.00 feet to a point, the place of BEGINNING. BEING Lot No. 30 on the Final Major Subdivision Plan of Section 2, Part B, Brandywine Village, as recorded in the Cumberland County Recorder's Office in Plan Book 32, Page 100. UNDER AND SUBJECT to a 16 foot storm sewer easement along property line of Lot No. 30 and Lot No. 31, Section 2, Part B, Brandywine Village, described in accordance with survey prepared by Robert G. Hartman, Jr., Registered Surveyor, dated November 11, 1983, as follows, to wit: BEGINNING at a point on the southern right of way line of Mayberry Lane, said point being located 363.17 feet in an easterly direction from the North end of a 7.92 feet arc connecting the eastern right of way line of Mayberry Lane, a 50 foot right of way to the northern right of way line of Longview Road, a 50 foot right of way; thence from the point of beginning along the southern right of way line of Mayberry lane on an arc of a curve curving to the left, having a radius of 175 feet and an arc length of 16.006 feet to a point; thence through Lot No. 30, South 72 degrees 05 minutes 02 seconds East, a distance of 133.65 feet to a point; thence through Lot 30 and Lot 31, South 48 degrees 38 minutes 35 seconds East, a distance of 46.80 feet to a point on the rear property line of Lot 31; thence along same, South 42 degrees 03 minutes 58 seconds West, a distance of 16 feet to a point; thence through Lot 30, North 48 degrees 38 minutes 35 seconds West, a distance of 43.28 feet to a point; thence through same, North 72 degrees 05 minutes 02 seconds West, a distance of 130.33 feet to a point, the place of BEGINNING. BEING the same premises which James R. Lauer and Barbara J. Lauer, husband and wife, by their deed dated July 30, 2004 and recorded in Cumberland County Deed Book 264, Page 2461 granted and conveyed unto Mark E. Gould and Michele M. Gould, husband and wife. HAVING thereon erected a dwelling house known and numbered as 8 Mayberry Lane, Mechanicsburg, PA 17050. TAX PARCEL #38-21-0289-056 Exhibit "A" x' "R 0 T H0 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS I"' FEDERAL CREDIT UNION PLAINTIFF Vs. 201 12 MAY 14 PM 3: 19 CUMBERLAND CGUN-l'"Y PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-731 MARK E. GOULD and CIVIL ACTION - LAW MICHELE M. GOULD DEFENDANTS MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Members 1St Federal Credit Union, plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located in Silver Spring Township, Cumberland County, Pennsylvania, known and numbered as 8 Mayberry Lane, Mechanicsburg, PA 17050. 1. Name and address of owner(s) or reputed owner(s): Mark E. Gould Michele M. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 2. Name and address of defendant(s) in the judgment: Mark E. Gould Michele M. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Members 1St Federal Credit Union Attn.: Dave Thomas, Lead Collector 5000 Louise Drive Mechanicsburg, PA 17055 4. Name and address of the last recorded holder of every mortgage of record: Members 0 Federal Credit Union Attn.: Dave Thomas, Lead Collector 5000 Louise Drive Mechanicsburg, PA 17055 Bank of America, N.A. 13150 World Gate Dr. Hernon, VA 20170 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Inheritance Tax Bureau Commonwealth of PA Department of Revenue Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 Occupant 8 Mayberry Lane Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ,Ntfi?llAubmitted, Date: May 7, 2012 Resp KArl(M. tedebbhm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff JINU 12 MAY 14 PPS 3: 1 9 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 FEDERAL CREDIT UNION PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. MARK E. GOULD and MICHELE M. GOULD DEFENDANTS : NO.: 12-731 CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Mark E. Gould Michele M. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. Your house (real estate) at 8 Mayberry Lane, Mechanicsburg, PA 17050, as more particularly set forth and described on Exhibit "A" attached hereto and made part hereof, is scheduled to be sold at Sheriff's Sale on September 5, 2012 at 10:00 a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of $38,679.36 plus interest at the legal rate, legal fees, costs and other costs and charges collectible under the mortgage and foreclosure and sale of the mortgaged property obtained by the above named Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount of the judgment plus costs, interest and additional reasonable legal fees or the back payments, late charges, costs and reasonable attorney's fees, if any, due. To find out how much you must pay, you may call Karl M. Ledebohm, Esquire, at (717)938-6929 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your house (real estate) will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff at the County Courthouse, which number is listed below. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the house (real estate) as if the sale never happened. 5. You have a right to remain in the house (real estate) 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 (real estate). A schedule of distribution of the money bid for your house will be filed by the Sheriff on or before October 5, 2012 (within thirty (30) days after the Sheriff Sale). This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed by the Sheriff. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 The Sheriff's phone number is: (717)240-6390. Karl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ALL THAT CERTAIN lot of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the eastern lime of Mayberry Lane (50 foot right of way), at the southwestern comer of Lot No. 29 on the hereinafter mentioned Plan of Lots; thence along the southern line of Lot No. 29, North 84 degrees 59 minutes 52 seconds East, a distance of 274.72 feet to a point at line of lands now or formerly of John Erdis; thence along said Erdis lands, South 48 degrees 43 minutes 37 seconds East, a distance of 18.68 feet to a point at line of lands now or late of Harold D. Stoner; thence along the western line of said Stoner lands, South 42 degrees 03 minutes 58 seconds West, a distance of 183.81 feet to a point at the northeastern corner of Lot No. 31 on the hereinafter mentioned Plan of Lots; thence along the northern line of Lot No. 31, North 72 degrees 05 minutes 02 seconds West, a distance of 181.17 feet to a point on the eastern line of Mayberry Lane; thence along Mayberry Lane by a curve to the left having a radius of 150 feet, an arc distance of 70.00 feet to a point, the place of BEGINNING. BEING Lot No. 30 on the Final Major Subdivision Plan of Section 2, Part B, Brandywine Village, as recorded in the Cumberland County Recorder's Office in Plan Book 32, Page 100. UNDER AND SUBJECT to a 16 foot storm sewer easement along property line of Lot No. 30 and Lot No. 31, Section 2, Part B, Brandywine Village, described in accordance with survey prepared by Robert G. Hartman, Jr., Registered Surveyor, dated November 11, 1983, as follows, to wit: BEGINNING at a point on the southern right of way line of Mayberry Lane, said point being located 363.17 feet in an easterly direction from the North end of a 7.92 feet arc connecting the eastern right of way line of Mayberry Lane, a 50 foot right of way to the northern right of way line of Longview Road, a 50 foot right of way; thence from the point of beginning along the southern right of way line of Mayberry lane on an arc of a curve curving to the left, having a radius of 175 feet and an arc length of 16.006 feet to a point; thence through Lot No. 30, South 72 degrees 05 minutes 02 seconds East, a distance of 133.65 feet to a point; thence through Lot 30 and Lot 31, South 48 degrees 38 minutes 35 seconds East, a distance of 46.80 feet to a point on the rear property line of Lot 31; thence along same, South 42 degrees 03 minutes 58 seconds West, a distance of 16 feet to a point; thence through Lot 30, North 48 degrees 38 minutes 35 seconds West, a distance of 43.28 feet to a point; thence through same, North 72 degrees 05 minutes 02 seconds West, a distance of 130.33 feet to a point, the place of BEGINNING. BEING the same premises which James R. Lauer and Barbara J. Lauer, husband and wife, by their deed dated July 30, 2004 and recorded in Cumberland County Deed Book 264, Page 2461 granted and conveyed unto Mark E. Gould and Michele M. Gould, husband and wife. HAVING thereon erected a dwelling house known and numbered as 8 Mayberry Lane, Mechanicsburg, PA 17050. TAX PARCEL #38-21-0289-056 Exhibit "A" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-731 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION, Plaintiff (s) From MARK E. GOULD and MICHELE M. GOULD (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: $38,679.36 Interest from 3/23/12 at the legal rate Atty's Comm: % Atty Paid: $226.70 Other Costs: Plaintiff Paid: Date: 5/14/12 L. L.: $.50 Due Prothy: $2.25 vid D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: KARL M. LEDEBOHM, ESQUIRE Address: PO BOX 173 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart ?'??t l= Solicitor Members 1st FCU vs. Case Number Michele M. Gould (et al.) 2012-731 SHERIFF'S RETURN OF SERVICE 05/29/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $79.31 SO ANSWERS, May 29, 2012 RON R ANDERSON, SHERIFF .32? L,_L,fOd. ,v/ 70 COO 100 Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS I FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. : NO.: 12-731 MARK E. GOULD and CIVIL ACTION - LAW MICHELE M. GOULD DEFENDANTS MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 Members I" Federal Credit Union, plaintiff, in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located in Silver Spring Township, Cumberland County, Pennsylvania, known and numbered as 8 Mayberry Lane, Mechanicsburg, PA 17050. 1. Name and address of owner(s) or reputed owner(s): Mark E. Gould Michele M. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 2. Name and address of defendant(s) in the judgment: Mark E. Gould Michele M. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Members I st Federal Credit Union Attn.: Dave Thomas, Lead Collector 5000 Louise Drive Mechanicsburg, PA 17055 C(OPY 4. Name and address of the last recorded holder of every mortgage of record: Members l st Federal Credit Union Attn.: Dave Thomas, Lead Collector 5000 Louise Drive Mechanicsburg, PA 17055 Bank of America, N.A. 13150 World Gate Dr. Hernon, VA 20170 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 Domestic Relations Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Inheritance Tax Bureau Commonwealth of PA Department of Revenue Bureau of Individual Taxes Dept. 280601 Harrisburg, PA 17128-0601 Occupant 8 Mayberry Lane Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: May 7, 2012 ka'rl!M. tedebbhm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. : NO.: 12-731 MARK E. GOULD and CIVIL ACTION - LAW MICHELE M. GOULD DEFENDANTS MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE To: Mark E. Gould Michele M. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 THE UNDERSIGNED ATTORNEY IS A DEBT COLLECTOR. PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT-AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE CURRENTLY A DEBTOR IN BANKRUPTCY OR HAVE RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT BUT AN EFFORT TO FORECLOSE THE LIEN OF A MORTGAGE ON REAL ESTATE. Your house (real estate) at 8 Mayberry Lane, Mechanicsburg, PA 17050, as more particularly set forth and described on Exhibit "A" attached hereto and made part hereof, is scheduled to be sold at Sheriff's Sale on September 5, 2012 at 10:00 a.m. in the Office of the Sheriff, Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment in the principal amount of $386679.36 plus interest at the legal rate, legal fees, costs and other costs and charges collectible under the mortgage and foreclosure and sale of the mortgaged property obtained by the above named Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The Sheriff Sale will be cancelled if you pay to the above named Plaintiff the amount of the judgment plus costs, interest and additional reasonable legal fees or the back pAyments, late charges, costs and reasonable attorney's fees, if any, due. To find out how much you must pay, you may call Karl M. Ledebohm, Esquire, at (717)938-6929 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your house (real estate) will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the County Courthouse. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff at the County Courthouse, which number is listed below. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the house (real estate) as if the sale never happened. 5. You have a right to remain in the house (real estate) 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 (real estate). A schedule of distribution of the money bid for your house will be filed by the Sheriff on or before October 5, 2012 (within thirty (30) days after the Sheriff Sale). This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed by the Sheriff. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL. HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 The Sheriff's phone number is: (717)240-6390. Karl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA (717)938-6929 Attorney for Plaintiff 17070-0173 ALL,THAT'CERTAIN lot of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the eastern line of Mayberry Lane (50 foot right of way), at the southwestern corner of Lot No. 29 on the hereinafter mentioned Plan of Lots; thence along the southern line of Lot No. 29, North 84 degrees 59 minutes 52 seconds East, a distance of 274.72 feet to a point at line of lands now or formerly of John Erdis; thence along said Erdis lands, South 48 degrees 43 minutes 37 seconds East, a distance of 18.68 feet to a point at line of lands now or late of Harold D. Stoner; thence along the western line of said Stoner lands, South 42 degrees 03 minutes 58 seconds West, a distance of 183.81 feet to a point at the northeastern corner of Lot No. 31 on the hereinafter mentioned Plan of Lots; thence along the northern line of Lot No. 31, North 72 degrees 05 minutes 02 seconds West, a distance of 181.17 feet to a point on the eastern line of Mayberry Lane; thence along Mayberry Lane by a curve to the left having a radius of 150 feet, an arc distance of 70.00 feet to a point, the place of BEGINNING. BEING Lot No. 30 on the Final Major Subdivision Plan of Section 2, Part B, Brandywine Village, as recorded in the Cumberland County Recorder's Office in Plan Book 32, Page 100. UNDER AND SUBJECT to a 16 foot storm sewer easement along property line of Lot No. 30 and Lot No. 31, Section 2, Part B, Brandywine Village, described in accordance with survey prepared by Robert G. Hartman, Jr., Registered Surveyor, dated November 11, 1983, as follows, to wit: BEGINNING at a point on the southern right of way line of Mayberry Lane, said point being located 3163.17 feet in an easterly direction from the North end of a 7.92 feet arc connecting the eastern right of way line of Mayberry Lane, a 50 foot right of way to the northern right of way line of Longview Road, a 50 foot right of way; thence from the point of beginning along the southernmight of way line of Mayberry lane on an arc of a curve curving to the left, having a radius of 175 feet and an arc length of 16.006 feet to a point; thence through Lot No. 30, South 72 degrees 05 minutes 02 seconds East, a distance of 133.65 feet to a point; thence through Lot 30 and Lot 31, South 48 degrees 38 minutes 35 seconds East, a distance of 46.80 feet to a point on the rear property line of Lot 31; thence along same, South 42 degrees 03 minutes 58 seconds West, a distance of 16 feet to a point; thence through Lot 30, North 48 degrees 38 minutes 35 seconds West, a distance of 43.28 feet to a point; thence through same, North 72 degrees 05 minutes 02 seconds West, a distance of 130.33 feet to a point, the place of BEGINNING. BEING the same premises which James R. Lauer and Barbara J. Lauer, husband and wife, by their deed dated July 30, 2004 and recorded in Cumberland County Deed Book 264, Page 2461 granted and conveyed unto Mark E. Gould and Michele M. Gould, husband and wife. HAVING thereon erected a dwelling house known and numbered as 8 Mayberry Lane, Mechanicsburg, PA 17050. TAX PARCEL #38-21-0289-056 Exhibit "A" WRIT OF EXECUTION and/or ATTACHMENT COMMONWiALTH OF PENNSYLVANIA) NO. 12-731 Civil COUNT`.' OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS I" FEDERAL CREDIT UNION, Plaintiff (s) From MARK E. GOULD and MICHELE M. GOULD (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: $38,679.36 Interest from 3/23/12 at the legal rate Arty's Comm: % Atry Paid: $226.70 Other Costs: Plaintiff Paid: Date: 5/14/12 (Seal) REQUESTING PARTY: Name: KARL M. LEDEBOHM, ESQUIRE Address: PO BOX 173 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 L.L.: $.50 Due Prothy: $2.25 Deputy TRUE COPY FROM RECORD vlheMf, I here Unto set my ha In Testimony of said - R at Carlisle, Pa.?? and the seat 201 --- ?This ??da °f n ProttwnotarY On May 16, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA, known and numbered 8 Mayberry Lane, Mechanicsburg, PA 17050 more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 16, 2012 By: Claudia Brewbaker, Real Estate Coordinator U v ?I