HomeMy WebLinkAbout12-2936-/
HARTMAN UNDERHILL & BRUBAKER LLP°
By: Robert W. Pontz, Esquire
Attorney I.D. No. 56554 zo 1 z y 10 A 071/' 2 0
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 89491
221 East Chestnut Street
Lancaster, PA 17602 Attorneys for Plaintiff:
(717) 299-7254/(717) 299-3160 (Fax) Susquehanna Bank
SUSQUEHANNA BANK,
Plaintiff
V.
ROBERT S. GOODRICH and
LISA GOODRICH, h/w
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
No.
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this Complaint and
Notice are served, by entering a written appearance personally or by attorney and filing in writing
with the Court your defenses or objections to the claims set forth against you. You are warned that
if you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other claim
or relief requested by the Plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108/ 717-249-3166
(00648939.21
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HARTMAN UNDERHILL & BRUBAKER LLP
By: Robert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 89491
221 East Chestnut Street
Lancaster, PA 17602
(717) 299-7254/(717) 299-3160 (Fax)
Attorneys for Plaintiff
Susquehanna Bank
SUSQUEHANNA BANK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
V.
ROBERT S. GOODRICH and
LISA GOODRICH, h/w
Defendant
: No.
COMPLAINT
1. The Plaintiff, Susquehanna Bank, is a financial institution organized and
existing under the laws of the Commonwealth of Pennsylvania, with its principal offices
located at 1570 Manheim Pike, Lancaster, Lancaster County, Pennsylvania 17604.
2. Defendants, Robert S. Goodrich and Lisa Goodrich, husband and wife, are adult
individuals with a last known address of 218 S. Pebble Beach Blvd, Sun City Center, Florida,
33573.
3. On or about June 5, 2009, Defendants executed and delivered to Plaintiff a
certain HELOC Promo Interest Only Consumer Open-End Agreement (the "Agreement") in
the principal amount of Ninety-Seven Thousand, Three Hundred and 00/100 Dollars
($97,300.00) to evidence a consumer loan (the "Loan"). A true and correct copy of the
Agreement is attached hereto, marked Exhibit A and incorporated by reference as if fully
{00648939.2}
set forth herein.
4. As security for the Loan, on or about June 5, 2009, Defendants, as mortgagors,
executed and delivered to Plaintiff an open-end mortgage ("Mortgage") upon certain premises
known and numbered as 1595 W. Lisburn Road, Mechanicsburg, Monroe Township
Cumberland County, Pennsylvania, the Mortgage being of record in the Office of the Recorder
of Deeds of Cumberland County, Pennsylvania, at Instrument Number 200920354 (the
"Mortgaged Premises"). A true and correct copy of the Mortgage is attached hereto,
incorporated by reference and marked Exhibit B.
5. Plaintiff is the lawful holder of the Mortgage, and the Mortgage has not been
assigned.
6. Defendants are the real owners and mortgagors of the Mortgaged Premises.
7. The Agreement and Mortgage presently are in default because Defendants have
failed to pay to Plaintiff (a) monthly installments of accrued finance charges and other fees
and charges due under the terms of the Agreement, each such installment being in the amount
billed by Plaintiff in accordance with the terms of the Agreement, due on October 31, 2011,
and at monthly intervals thereafter, and (b) monthly late charges in a total amount of $360.98,
whereby the entire balance of principal and interest due under the Agreement has become
immediately due and payable in full, together with late charges, costs of collection, reasonable
attorneys' fees and other amounts provided under the terms of the Agreement and the
Mortgage.
8. An itemization of the amount due, including finance charges, late and other
charges and attorneys' fees as authorized by the Agreement, is as follows:
{00648939.doc }
l
Principal $97,300.00
Finance Charges accrued through $ 3,114.56
4/30/2012 (Current per diem is
$13.29235)
Late Charges $ 360.98
Other Charges $ 360.50
Reasonable Attorneys'
Fees, as authorized $ 3,500.00
TOTAL $104,636.04
9. Continuing finance charges, costs of suit and all attorneys' fees and other fees
and charges under the Agreement and Mortgage which accrue hereafter are to be collectable
under the judgment.
10. On March 13, 2012, Plaintiff sent a written Notice of Intention to Foreclose as
required by the Loan Interest and Protection Law of 1974, 41 P.S. §403 (Act 6), by certified
mail, return receipt requested, and by regular first class mail, to the Mortgaged Premises and
to the last known address of each Defendant, in accordance with the provisions of Act 6 and
the regulations promulgated thereunder. True and correct copies of the Act 6 notices, together
with copies of the certified mail envelopes and certificates of mailing received with respect to
such notices, are attached hereto, incorporated by reference and collectively marked Exhibit
C.
11. Pursuant to notices published in the Pennsylvania Bulletin, 41. Pa. B. 2789 (May
28, 2011) and 41 Pa. B. 3943 (July 16, 2011), Plaintiff was not required to send Defendants
written notice of the provisions of the Pennsylvania Homeowners' Emergency Assistance Act
{00648939.doe}
A
of 1983, 35 P.S. §1680.401c, et seq. (Act 91).
12. The amount due and owing as set forth in Paragraph 8 reflects all credits applied
and payments received by Plaintiff on Defendants' account as of the date of filing of this
Complaint.
13. This Complaint is not based upon any writings other than those pled herein and
attached hereto.
WHEREFORE Plaintiff, Susquehanna Bank, demands judgment in its favor and
against Defendants in the amount of One Hundred Four Thousand, Six Hundred Thirty-six and
04/100 Dollars ($104,636.04), together with subsequently accruing finance, late and other
charges, attorneys' fees, finances charges accruing from April 30, 2012 (currently $13.29235
per diem on the current principal balance) and costs of suit.
Dated: 5 2? l2
HARTMAN UNDERHILL & BRUBAKER LLP
Attorneys for Plaintiff
B3?- C
ert W. Pontz, Esquire
Dana C. Panagopoulos, Esquire
100648939.doc?
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LOAN NUMBER LOAN NAME ACCT. lily ABM DATE INITIALS
10008788389 ROBERT S GOODRICH GAA3960 08/05109
CREDIT LIMIT INDEX lw/Margin) INITIAL RATE MATURITY DATE LOAN PURPOSE
$97,300.00 908 WSJ 15th EFF tat 2.990% 08105/34 Consumer
Business Day plus
1.750%
TRANS. ACCT. DRAW PERIOD REPYMT. PERIOD PAYMENT DATE BIiLM CYCLE
NUNWEER
10006786371 10 Years 15 °Years as indicated on my Monthly
periodic statement
Creditor Use Only
HELOC PROMO INTEREST ONLY (U70)
CONSUMER OPEN-END AENIENT
GATE AND PARTIES. The date of this HELOC. Proms Interest Only tU70) Agreement (Agreement) is June 5. 2009. The
parties and their addresses are.,
LENDER:
SUSQUEHANNA BANK -
157'0 Manheim Pike
PO Box 3300
Lancaster, PA 17604-3300
Telephone: (800) 311-3182
BORROARR:
ROSERT 8 GOODRICH
1595 W LISBURN RD
MECHANICSBURG, PA 17055
LISA GOODRICH
1595 W LISBURN RD
j?
MECHANICSBURG, PA 17055
1 DEFINITIONS. As used in this Agreement, the terms have the following mein t?gs.
A. Pronouns. The pronouns "I", `me" and "my" refer to all Borrowers along this Agreement, individually and together
with their heirs, successors and assigns, and each other person or legal entity (including guarantors, endonws, and
sureties) who egress to pay this Agreement. "You" and "your" refer to the Lender, any participants or syndicators,
successors and assigns, or any person or company that acquire an Interest in the Line of Credit.
B. Agreement. Agreement refers to this HELOC Promo Interest Only, iU70) Agreement, and any extensions, renewals,
modifications and substitutions of it.
C. Line of Cruet. Line of Credit refers to this transaction generally, including obligations and dutles arising from the terms
of all documents prepared or submitted for this transaction such as applications, security agroornonts, disclosures or notes,
and this Agreement.
G. Loan Account Balance. Loan Account Balance means the aura of the unpaid principal balance advanced under the terrns
of this Agreement, finance charges, certain fees and charges, crack Inmtrance ot debt cancellation coverage premiums that
are due, and other amounts advanced to me or others under the terms of this Agreement.
E. Dollar Amounts. All dollar amounts will be payable In lawful money of the United States of America.
F. 1111" Cycle. Billing Cycle means the interval between the days or dates of regular periodic statements. My Billing Cycle
is Monthly. My Billing Cycle ends as indicated on my periodic statement.
0. Crealt Limit. Credit Limit means the maximum amount of the principal you will permit me to owe you under this Ulna of
Credit, at any one time.
H. Property. Property means any property, real, personal or intangible, that secures my performance of the obligations of
this Line of Credit.
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Other important terms are defined throughout this Agreement.
2. TAX DEDUCTRILITY. I should consult a tax 4kM*" regwdng the deductibility of Interest and charges under this Line of
crack.
3. PROMISE TO PAY. For value received, I promise to pay to you or your order, at your address, or at such other location se
You may designate, the principal amount of 087,300.00 (Credit Limit), of so rrluch of the Credit Unlit as may be advanced
from time to time under the terms of this Agreement, plus costs, expenses and interest accruing as described in this
Agreement until this Agreement matures or this obligation is accelerated.
A. Agreement Term. This Agreement begins on the Agreement Date and continues until the Maturity Date. The Draw
Period is a period during the term of this Agreement that i may request advances. I may not request advances during the
Repayment Period. Periodic minimum payments are required during both the Draw Period and Repayment Period.
The Draw Period is 10 years, and begbha on the Agreement Date. The Repayment Period will then continue for 15 yews, I
may request to renew this Line of Credit at that time.
S. Advances. i can request advances by the following rids:
(1) 1 request a withdrawal In person.
f2)1 request a withdrawal by phone.
(3) 1 request a withdrawal by mail.
(4) 1 write a check that you have given me for this purpose
(5) Overdraft Protection Feature. This Line of Credit may be tied to a designated Checking socount for check reserve
purposes. If you have designated a Checking account and the account becomes overdrawn, funds will be drawn from
this Ura of Credit and deposited In the account to cover the amount of the overdraft. The funds for this purpose will
be drawn from your Line of Credit in 0260.00 increments.
(6) Telephone Banking Transfers, Requesting a credit advance from your line of credit to a deposit account authorized
under your internet banking and telephone banking service with us; any request using the procedures and security
devices established for that intemst or telephone banking service is agreed to be an authorized request from you.
You will make the advance by paying the amount directly to me, depositing it in a designated account, or by paying a
designated third person or account.
C. Advance Limkatlons. Requests for, and access to, advances are subject to the following limitations.
(1) Initial Advance. On June 10, 2009, 1 will receive an Initial Advance of 097,300.00.
(2) Minimum Advance. I will only request advances that equal, or exceed 0250.00 (Minimum Advance).
(3) Advance Amount. When I request an advance, you will, subject to the limitations contained in this Agreement,.
advance either the Minimum Advance, or the smallest multiple of the Minimum Advance necessary to cover my
request. For example, If my Minimum Advance is 0100.00, you will make advances for 0 €00.00, 0200.00, 0300.00,,
etc. You will make the advance by one of the methods described in the Advances section. You will record the amount
as an advance and increase my Loan Account Balance.
If my request is for Is" then the Minimum Advance, you may, at your option, grant the request to the extent permitted
by law. However, granting the request does not mean you will be required to grant requests for leas then the Minimum
Advance in the futures You always have the option to deny any such request.
(4) Credit Limit. 1 agree not to request or obtain an advance that will cause the unpaid prftipal of spy Loan Account
Balance to exceed the Credit Limit. I understand that you will not ordinarily grant a request for an advance that would
cause the unpaid principal of my Loan Account Balance to be greater than my Credit Limit. You may, at your option,.
grant such a request without obligating yourselves to do so in the future. If I exceed the Credit Limit, I agree to pay
the amount by which the unpaid principal of my Loan Account Balance exceeds the Credit Limit immediately, even It
you have not yet billed me.
4. COMPUTATION OF FINANCE CHARGES. Finance charges begin to accrue immediately when you make an advance to me.
To figure the finswe charge for each day in a Billing Cycle, you multiply the daily periodic rate by the Prkm*W Balance of my
Loan Account Balance on that day. You then add up those daily finance charges to figure the total finance charge for that
Fulling Cycle. To figure the Principal Balance for each day, you first take my Loan Account Balance at the beginning day and subtract any unpaid finance charges and credit Insurance
or debt cancellation cover of each
age premiums of any} that we due.
Next, you subtract the portion of any payments or credits received that day which apply to the repayment of my debt. (A
portion of each payment I make is applied to finance charges and credit insurance or debt cancellation coverage premiums, if
any.) Then you add any new advances made that day. The final figure is the Principal Balance.
A. Periodc Nota and Annual Percentage Rate. The periodic rate used in calculating; the FINANCE CM AW is .00819178
percent per period, which corresponds to an ANNUAL PERCENTAGE RATE of 2.990 percent per annum. The annual
percentage rata includes Interest and not other costs.
B. Variable Refs. The annual percentage rate may change. It will be based on the value of the index described as Prime
Rata, being the highest such rats published In the Money Rates section of the Well Street Joumal as of the fifteenth day of
each month, to be effective on the first business day of the following month plus 1.784 percentage points. This rate will
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be rounded to the nearest .001 percent. The annual percentage rate may increase if the Index rate incises. An Index
rate increase will result In an Increase in the interest portion of the finance charge and it may have the effect of increasing
my periodc Minimum Payment. A decrease in the Index rate will have the opposite effect as an increase.
An Index rate Increase or decrease will take effect on the first day of the billing cycle following the index change. The
annual percentage rate can increase or decrease monthly, after remaining fixed for 3 months. If the Index rate changes
more frequently than the annual percentage rate, you will use the Index rate in effect on the day you adjust the annual
percents rate to determine the now annual percentage rate. In such a case, you will Ignore any changes in the Index rate
that occur between annual percentage rate adjustments.
C. Rata Change Limitations. Annual percentage rate changes are subject to the following limitations:
(1) The maximum ANNUAL PERCENTAGE RATE that can apply during the term of this Line of Credit is 18.000
percent, or the maximum annual percentage rate allowed by applicable law, whichever is low The minimum ANNUAL
PERCENTAGE RATE that can apply during the term of this Line of Credit is 4.000 percent.
D. Preferred Rases. The stated rates are Preferred Rates reflecting a discount equal to .250 percentage points of the
corresponding ANNUAL IPEAMTAG£ RATE. If these rates were based on the actual market rates, the periodic rats
used in calculating the FINANCE CHARGE would be .01438366 percent per period, which corresponds to an ANNUAL
PERCENTAGE RATE of 5.250 percent per annum. These Preferred Rates are offered in consideration of my agreement
that all periodic payments will be paid pursuant to an automatic debit arrangement. If i fail to provide this consideration,
unless otherwise required by law, the corresponding annual percentage rate will, without notice, automatically increase.
The periodic rate will increase proportimmisly.
If I fail for any reason to make timely payments under this Agreement pursuant to the automatic debit arrangement, the
corresponding ANNUAL PERCENTAGE RATE will increase .250 percent, per annum.
A change will be effective immediately after the date 1 fail to meet the conditions of my arrangements with you. Such an
increase will remain in effect for the remainder of the term of this Agreement.
E. Discounted Rates, The stated rates also reflect a discount equal to 2.990 percentage points of the corresponding
ANNUAL 'PERCENTAGE RATE. This discount Is in addition to any Preferred Rate discount that I may receive. These
Discounted Rotes will be In effect until the and of the 3rd billing cycle. At that time, the rates will be subject to further
adjustments and limitations, and produce the effects described above. If those rates were based on the actual rates, the
periodic rate used in calculating the FINANCE CHARGE would be .01438356 percent per period, which corresponds to an
ANNUAL PERCENTAGE RATE of 5.250 percent per annum.
5. FEES AND CHARGES. In addition to the interest portion of the Finance Charge, I agree to pay the"additional fees and
charges.
A.' Rome" Charges, I agree that I will pay certain fees and charges if I don't comply with the terms of this Agreement.
(1) Late Charge. If a payment is more than 15 days late, I will be charged 10.000 percent of the Amount of Payment..
However, this charge will not be less than $20.00. 1 will pay this iota charge promptly but only once for each late
payment.
6. PAYMENTS.
A. Payment Date. During the term of this Agreement, a Minimum Payment will be due by the Payment Data for any Billing
Cycle in which there is an outstanding balance on my account. My Minimum Payments will be due monthly.
B. Payment Amount. On or before each Payment Date, I agree to make a payment of at least the Minimum Payment
amount.
During the Draw Period, a Minimum Payment will equal the amount of any credit Insurance or debt cancellation coverage
premiums that are due, earned fees and charges, and the greater of the following: the amount of accrued finance charges
'on the last day of the Billing Cycle or 4100.00.
This amount will be rounded down to the nearest 4.01.
During the Repayment Period, a Minimum Payment will equal the amount of any credit insurance or debt cancellation
coverage premiums that are due, owned fees and charges, and the greater of the following: the amount of accrued finance
charges on the last day of the Billing Cycle plus .556 percent of the Prim Balance or 4100,00.
This amount will be rounded down to the nearest $.01.
C. Prkt*W Reduction. The Minimum Payments may not fully repay the Principal Balance outstanding on my Loan Account
Balance.
D. Final Payment. At maturity, I may have to repay the entire outstanding Loan Account Balance in a single payment. At
that time you may, but are not ob!'W*d to, refinance this Line of Credit. If you do refinance this Line of Credit at maturity,
I understand that I may have to pay some or all of the closing costs normally associated with a new loan.
E. Additional Payment Terms, if my Loan Account Balance on a payment data is less than the Minimum Payment amount, i
must pay only the Loan Account. Balance. If I fad to make a payment, you may, but are not required to, advance money to
me to make the payment. All the terns of this Agreement would apply to such an advance. I con pay off ail or part of
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what 1 owe at any time. However, so long as 1 owe any amount I must continue to make my periodic Minimum Payment as
otherwise required by this Agreement unless you otherwise consent In writing In advance, which consent you agree not
unreasonably to withhold. Unless otherwise agreed or required by appkable taw, payments and other credits will be
applied first to any finance charges that are due, than to credit insurance pr miums that are due, than to principal that is
due, than to late charges that are due, and finally to any charges that i owe other than principal and finance charges. No
late charge will be assessed on any payment when the only delinquency is due to late fees sssesaed on earlier payments
and the payment is otherwise a full payment.
7. AUTOMATIC WITHM 1tAL. I authorize you to automatically withdraw the Mksmum Payment from my Transaction
Account, Account No. 10000766371, on each Payment Data. If my Transaction Account does not have enough money in It
to make the Minimum Payment, you may, but are not required to, lead me money to make the payment. All the terms of this
Agreement will apply to such a loan. N my Loan Account Balance is Ion than the Minimum Payment amount, you will
withdrew only the arnount necessary to reduce my Loan Account Balance to zero.
8. PERKOUIC STATEMENTS. If I have an outstanding balance on my account or have any account activity, you will send me a
periodic stamment at the and of each Billing Cycle. This periodic statement wig reflect, amarip other things, credit advances,
finance cs, other charges. payments made, other credits, my previous account balance and my new account balance.
The periodic statement will also Identify my Minimum Payment for the cycle and the date it is due (Payment Data).
9. CHAM THE TERMS OF THIS AGREEMENT. Generally, the terms of this Agreement cannot be changed. i do, however,
agree to the changes Hated here.
A. You may make changes that I agree to in writing.
0. You rosy make changes that unequivocally benefit me.
G. You may make changes to insignificant terms of this Agreement.
D. You may change the Index and margin if the original Index becomes unavailable. Any new index must have a historical
movement similar to the original, and together with the margin, produce a "or interest rate.
I also agree to the additional changes you may make as described elsewhere in this Agreement. You will send any notice of a
change in terms to my address Hated in this Agreement. I agree to inform you of any change in my address.
10. SECURITY. The Line of Credit is secured by separate security instruments prepared together with this Agreement as
follows:
Doatxnont Name Paroles to Doe nterd
Mortgage - 1595 W LISBURN RD ROBERT S GOODRICH, USA GOODRICH
11. DEFAULT. I will be in default It any of the following occur:
A. Fraud. I engage In fraud or material misrepresentation in connection with the Uns.of`Credit.
B. Payments. I fail to make a payment as required by this Agreement.
C. Property. My action or inaction adversely affects the Property or your rights in the Property.
12. DUE ON SALE. You may, at your option, declare the entire balance of this Agreement to be Immediately dui and, payable
upon the creation of, or contract for the creation of, any transfer or sale of all or any part of the Property. This right is subject
to the restrictions Imposed by federal law 0 2 C.F.R. 591), as applicable.
18. SUSPENSION OF CREDIT AND REDUCTION OF CREDIT LIMIT. You may temporarily prohibit me from obtaining additional
advances or reduce my Credit Limit during any period in which any of the following are in effect:
A. The value of the Property securing this Una of Credit declines significantly below its appr*ad valuo4or purposes of this
Una of Credit;
S. You reasonably believe that i will not be able to most the repayment requirements under; my Una of Credit due to a
material change in my financial circumstances;
C. I am in default of a material obligation under this Line of Credit. I understand, that you consider all of my obligations to
be material. Categories of obligations that you consider material include, but are not limited to: my obligation to not
commit frsud or n imepresentation in connection with this Una of Credit; my obligation to meet the repayment terms of this
Line of Credit, my obligation to not adversely affect the Property or your rights In the Property, my obligation to fulfill the
terms of the instrument securing this Agreement, and any other security instrument on the Property; my obligation to
notify you; and my obligation to provide you with information;
0. Government action prevents you from imposing the annual percentage rate provided for In this Agreement;
E. The priority of your security inter+asi Is adversely affected by government action to the extent that the value of the
security Interest isloss than 120 percent of my Credit Umit;
F. You are notified by a regulatory agency that continued edvanose constitute an unsafe and unsound practice;
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0. The maximum annual percentage rate allowed under this Agreement is reached; or
H. Any one of us requests a suspension of credit privileges.
In order to reinstate my credit privileges under the original terms of this Agreement, I must send you a written request to that
effect. My crack privileges will only be reinstated it you determkw that the condition which caused you to prohibit additional
extension and/or reduce the Credit Umlt no longer exists. If appraisal or credit report fees are incurred in makkp this
detente%otion, you may lit allowed by applicable law) charge me such fees. If credit privileges were suspended at my request,
they need not be reinstated unless all Borrowers request reinstatement.
14. WAIVERS AND CONSENT. To the extent not prohibited by law, I waive protest, presentment for payment, demand, notice
of acceleration, notice of intent to accelerate and notice of dishonor.
A. Additional Waihrete By Borrower. In addition, I, and any party to this Agreement and Line of Credit, to the extent
permitted by law, consent to certain actions you may take, and generally waive defenses that may be available based on
these actions or based on the status of a party to this Agreement.
(:1) You may renew or extend payments on this Agreement, regardless of the number of such renewals or extensions.
12) You may release any Borrower, endorser, guarantor, surety, accommodation maker or any other co-signer.
13) You may release, substitute or impair any Property securing this Agreement.
(4) You, or any institution participating in this Agreement, may invoke your right of set-off;
15 You may enter into any sales, repurchases or participations of this Agreement to any person In any amounts and
waive node of such safes, repurchases or participations.
16) 1 agree that any of us signing this Agreement as a Borrower is authorized to modify the terms of this Agreement or
any Instrument securing, guarantying or relating to this Agreement.
B. No Waiver By Umdsr. Your course of dealing, or your forbearance from, or delay In, the exercise of any of your rights,
remedies, pdv**W or right to insist upon my strict performance of any provisions contained In this Agreement, or other
Line of Credit documents, shall not be construed as a wahror by you, unless any such waiver Is in writing and is signed by
you.
15. DES. After I default, and after you give any legally required notice ;and opportunity to cure the default, you may at
your option do any one or more of the following.
A. Termination ik Acceleration. You may terminate this Una of Credit and make aN or any part of the amount owing by the
terms of this Agreement immediately due.
B. Advances. You may temporarily or permanently prohibit any additional advances.
C. Credit Lkntt. You may temporarily or permanently reduce the Credit Limit.
D. Additional Security. You may demand security, additional security, or additional parties to be obNgatetl to pay this
Agreement.
E. Sources. You may use any and all remedies you have under state or federal law or In any instrument securing this
Agreement.
F. Insurance Benefits. You may make a claim for any and all insurance benefits or refunds that may be available on my
default.
G. Payments Made On My Behalf. Amounts advanced on my behalf will be immediately due and may be added to the
balance owing under the terms of this Agreement, and accrue interest at the highest post-maturity interest rate.
H. Set-Off. You may use the right of set-off. This means you may set-off any amount due and payable under the terms of
this Agreement against any right I have to receive money from you.
My right to receive money from you includes any deposit or share account balance I have with you; any money owed to me
on an item presented to you or in your possession for collection or exchange; and any repurchase agroonont or other non-
deposit obligation. "Any amount due and payable under the terms of this Agreement" means the total amount to which
you are entitled to demand payment under the terns of this Agreement at the time you set-off.
Subject to any other written contract, If my right to receive money from you Is also owned by someone who has not agreed
to pay this Agreement, your right of set-off will apply to my interest in the obligation and to any other amounts I could
withdraw on my sole request or andorsamerrt.
Your right of set-off does not apply to an account or other obligation where my rights arise only in a representative
capacity. It also does not apply to any Individual Retirement Account or other tax-deferred retirement account.
You will not be liable for the dishonor of any check when the dishonor occurs because you set-off against any of my
accounts. I agree to hold you harmless from any such claims arising as a result of your exercise of your right of set-off.
I. WMver. Except as otherwise required by law, by choosing any one or more of these remedies you do not give up your
right to use any other remedy. You do not waive a default If you choose not to use a remedy. By erecting not to use any
remedy, you do not waive your right to later consider the event a default and to use any remedies If the default continues
or occurs again.
1000e7ee"
Corw~ Opors-W AWseawt
PAN44N13702WO"t70W00197023060409N •1888 Bw*4= SyMms. Im. St. Clegg.MN Pao 5
18. TERMINATION OF ACCOUNT. I may terminsto this Una) of Crack and cancel this Agreernetnt at any tine, upon written
notice to you. Notice of temdnstion will be sent to a Susquehanna Bank branch office. If you terminate this Una of Credit as
provided for in this Agrosmient, you will send me notice of termination at my lest address known to you. Tarrnination will not
affect trey obligation to repay advances made prior to the temhination, nor will It alter my duties to perform under the "a of
an instrument securing this Agreement until such instrument Is released.
17. COLLECTION WU43M S AND ATTORNEYS' FEES. On or after Default, to tree extent permitted by law, I agree to pay all
expenses of coiiaction, enforce rent or protection of your rights and remedies under this Agraernant. EVorisse include, but are
not gmited to, attorneys' fees, court costs and other legal expenses. These expenses are due and peyaWe immediately. If not
paid Immediately, these expenses will bear interest from the date of payment until paid in full at tits highost interest rata in
effect as provided for In the terms of this Agreement. All fees and expenses will be secured by the Property I have-granted to
you, if any. In addition, to the extent permitted by the United States Bankruptcy Code, i agree to pay the reasonable
ottomeys' fees incurred by you to protect your rights and interests in connection with any bankruptcy proceedings initiated by
or against me.
18. WAFMAN[IES AND REPRESENTATIONS. I have the right and authority to enter into this Agreement. The execution and
delivery of this Agreement will not violate any agreement governing me or to which I am a party.
18. INSURANCE. I agree to obtain the insurance described in this Agreement.
A. Propany Inouranw. I will insure or retain insurance coverage on the Property and abide by the insurance requirements of
any security instrument securing the Una of Credit.
G. Flood Inaurenoa. Food insurance is not required at this torte.. It may be required in the future should the property be
included In an updated flood plain map, If required in the future, i may obtain flood insurance from anyone I want that is
reasonably acceptable to you.
C. Insurance Warra ndes. I agree to purchase any insurance coverages that are required, in the amounts you require, as
described in this or any other documents I sign for the Una of Credit. I will provide you with contltmuing proof of coverage. I
will buy or provide insurance from a firm licensed to do business in the State where the Property is located. If i buy or
provide the insurance from someone other than you, the firm will be reasonably acceptable to you. i will have the insurance
company name you as loss payee on any insurance policy. You will apply the insurance proceeds toward what 1 owe you
on the outstanding balance. 1 agtee that if the insurance proceeds do not cover the amounts I still owe you, I will pay the
difference. 1 will keep the Insurance until all debts secured by this agreement are paid. If I want to buy the insurance from
you, I have signed a separate statement agreeing to this purchase,
20. COMMISSIONS. I understand and agree that you for your affiliate) will eam commissions or fees on any insurance
products, and may earn such fees on other services that I buy through you or your affiliate.
21. APPLICABLE LAW. This Agreement is governed by the laws of Pennsylvania, the United Staters of America, and to the
extent required, by the laws of the jurisdiction where that Property is located, except to the extent such state lows are
prearived by federal law. Any provision than appoints you as an agent is not subject to the provisions of 20 Pa.C.S.A.
Section 5601 at seq. (Chapter 58; Decedents, Estates and Fiduciaries Code). By exercising any of your rights under this
Agreement, you do so for your sale benefit.
22.JOINT AND iWXVIDUAL LMWW AND SUCCESSORS. My obligation to pay the Una of Credit is independent of the
obligation of any other person who has also agreed to pay it. You may sue me alone, or anyone else who is obligated on the
Una of Credit, or any number of us together, to collect the Una of Credit, Extending the line of Cruet or now obligations
under the Une of Credit, will not affect my duty under the Una of Credit and I will still be obligated to pay the Una of Credit.
The duties and benefits of the Una of Credit will bind and benefit the successors and assigns of you and me.
23. INTEGRATION AND SEYLRABILiTY. This Agreement is the complete and final expression of the agreement. If any
provision of this Agreement is unenforceable, then the unenforceable provision will be severed and the remaining provisions
will still be enforceable.
24. I TTERPRETATION. Whenever used, the singular includes the plural and the plural Includes the singular. The section
headings are for convenience only and are not to be used to Interpret or define the terms of this Agreement.
26. NOTICL FINANCIAL REPORTS AND ADDiTIQtIIAL DOCUMENTS. Unless otherwise required by law, any notice will be
given by delivering it or mailing it by first class mail to the appropriate party's address gated in the DATE AND PARTIES
section, or to any oiler address dosignsted in writing. Notice to one Borrower will be deemed to be notice to all Borrowers. i
will inform you in writing of any change In my name, addressor other application information. I will provide you any financial
staternent or Information you rowest. All financial statements and information I give you will be correct and complete. I agree
to sign, "ver, and file any oddbional documents or certifications that you may consider necessary to perfect, continue, and
preserve my obligations under this Una of Credit and to confirm your lien status on any Property. Time is of the essence.
28. CREDIT 11 iIATICN. 1 agree to supply you with whatever information you reasonably feel you need to decide whether
to continue this Una of Credit. You will make requests for this information without undue frequency, and will give me
reasonable time in which to supply the information,
10006701114180
PAt4lNt3702NOW1700D 19702306 1 *191110 ea*ws sv:t.m. Inc., Sc. Vwxl, MN w-W pj"e
27. SIGNATURES. By signing under a". I agree to the terms contained in this Agreement. I also acknowledge receipt of a
copy of this Agreement.
MY !BILLING RIGHTS
KEEP THIS NOTICE FOR FUTURE USE
This notice contains important information about my rights and your responsibilities under the Fair Credit Billing Act.
Notify You M Case of Errors or Questions About My Big
If I think my bill is wrong, or if I need more information about a transaction on my bill, I will write you at the address listed
on my bill. I will writs to you as soon as possible. You must hear from me no later than 60 days after you sent me the first
bbl on which the error or problem appeared. I can telephone you, but doing so will not presetve my rights,
in my letter, I will give you the following information:
My name and account number.
The dollar amount of the suspected error.
Describe the error and explain, if I can, why I believe there is an error'. If I need mom Informbillon, I will describe the
item I am not sure about.
If I have authorized you to pay my bill automatically from my savings, checking, share draft or other account, I can stop the
payment on any amount I think is wrong. To stop the payment my letter must reach you three business days before the
automatic payment is scheduled to occur.
My Rights and Your Responsiblihiss
After You M"W My Written Nafto
You must acknowledge my letter within 30 days, unless you have corrected the error by 'then, Within BO days, you must
wither correct the error or explain why you believe the bill was correct.
After you receive my letter, you cannot try to collect any amount i question, or report me as delinquent. You can continue
to bill me for the amount I question, including finance charges, and you can apply any unpaid amount against my credit
limit. 1 do not have to pay any questioned amount while you are investigating, but I am still obligated to pay the parts of
my bill that are not in question.
If you find that you made a mistake on my bill, 1 will not have to pay any finance charges related to any quastboged amount.
If you didn't make a mistake, I may have to pay finance charges, and I will have to make up any missed payments on the
questioned amount. In either case, you will send me a statement of the amount I owe and the date that it is due.
If i fail to pay the amount that you think I owe, you may report me as delinquent. 1-kn ever, it your explenatlon does not
satisfy ma and 1 write to you widen ten days teeing you that I still refuse to pay, you must tell anyone you report me to that
I have a question about my bill. And, you must tell me the name of anyone you reported me to. You must tell anyone you
report me to that the matter has been settled between us when it finally is.
If you don't follow these rules, you can't collect the first *W of the questioned amount, even if my bill was correct.
10000M389
Canw~ OpowEnd Agmmem
PV4tN13702BOD441700000197023060409N 01&ge eankwa Systmo, Inc., St. CWW,, MN F. a?rr? page 7
Individually
\/
oiu
Prepared By Collateral Processing
Department, Susquehanna Bank, 1570
Manheim Pike, PO Box 3300, Lancaster,
Pennsylvania 17604-3300, (888) 238-
8949
Return To Susquehanna Loan Center, PO
Box 639, Maugensville, MD 21767-0639
Parcel Number 22-10-0640-025
Premises: 1595 W LISBURN RD,
MECHANICSBURG, Pennsylvania, 17055
Space Above This Line For Recording Data
OPEN-END MORTGAGE
This Mortgage Secures Future Advances
DATE AND PARTIES. The date of this Mortgage (Security Instrument) is June 5,
2009. The parties and their addresses are:
MORTGAGOR:
ROBERT S GOODRICH
1595 W LISBURN RD
MECHANICSBURG, PA 17055
LISA GOODRICH
1595 W LISBURN RD
MECHANICSBURG, PA 17055
LENDER:
SUSQUEHANNA BANK
Organized and existing under the laws of Pennsylvania
1570 Manheim Pike
PO Box 3300
Lancaster, PA 17604-3300
1. CONVEYANCE. For good and valuable consideration, the receipt and sufficiency of
which is acknowledged, and to secure the Secured Debts and Mortgagor's
performance under this Security Instrument, Mortgagor grants, bargains, conveys and
mortgages to Lender, the following described property:
SEE ATTACHED SCHEDULE A
MONROE TOWNSHIP
The property is located in Cumberland County at 1595 W LISBURN RD,
MECHANICSBURG, Pennsylvania 17055.
10006766369
Pennsylvania Mortgage
PA141N13702600441700000197023060409Y 01995 Banker. Systems, Inc„ SL Cloud, MN Epd5gW Page 1
Together with all rights, easements, appurtenances, royalties, mineral rights, oil and
gas rights, all water and riparian rights, wells, ditches and water stock and all existing
and future improvements, structures, fixtures, and replacements that may now, or at
any time in the future, be part of the real estate described tall referred to as Property).
This Security Instrument will remain in effect until the Secured Debts and all
underlying agreements have been terminated in writing by Lender.
2. MAXIMUM OBLIGATION LIMIT. The total principal amount secured by this Security
Instrument at any one time will not exceed $97,300.00. This limitation of amount
does not include interest and other fees and charges validly made pursuant to this
Security Instrument. Also, this limitation does not apply to advances made under the
terms of this Security Instrument to protect Lender's security and to perform any of
the covenants contained in this Security Instrument.
3. SECURED DEBTS AND FUTURE ADVANCES, The term "Secured Debts" includes
and this Security Instrument will secure each of the following:
A. Specific Debts. The following debts and all extensions, renewals, refinancings,
modifications and replacements. A promissory note or other agreement, No.
10006766389, dated June 5, 2009, from Mortgagor to Lender, with a maxirnurn
credit limit of $97,300.00.
B. Future Advances. All future advances from Lender to Mortgagor under the
Specific Debts executed by Mortgagor in favor of Lender after this Security
Instrument. If more than one person signs this Security Instrument, each agrees
that this Security Instrument will secure all future advances that are given to
Mortgagor either individually or with others who may not sign this Security
Instrument. All future advances are secured by this Security Instrument even
though all or part may not yet be advanced. All future advances are secured as if
made on the date of this Security Instrument. Nothing in this Security Instrument
shall constitute a commitment to make additional or future advances in any amount.
Any such commitment must be agreed to in a separate writing. In the event that
Lender fails to provide any required notice of the right of rescission, Lender waives
any subsequent security interest in the Mortgagor's principal dwelling that is
created by this Security Instrument.
C. Sums Advanced. All sums advanced and expenses incurred by Lender under the
terms of this Security Instrument.
4. PAYMENTS. Mortgagor agrees that all payments under the Secured Debts will be
paid when due and in accordance with the terms of the Secured Debts and this
Security Instrument.
6. WARRANTY OF TITLE. Mortgagor warrants that Mortgagor is or will be lawfully
seized of the estate conveyed by this Security Instrument and has the right to grant,
bargain, convey, sell and mortgage the Property. Mortgagor also warrants that the
Property is unencumbered, except for encumbrances of record.
6. PRIOR SECURITY INTERESTS. With regard to any other mortgage, deed of trust,
security agreement or other lien document that created a prior security interest or
encumbrance on the Property, Mortgagor agrees:
A. To make all payments when due and to perform or comply with all covenants.
B. To promptly deliver to Lender any notices that Mortgagor receives from the
holder.
C. Not to allow any modification or extension of, nor to request any future
advances under any note or agreement secured by the lien document without
Lender's prior written consent.
7. CLAIMS AGAINST TITLE. Mortgagor will pay all taxes, assessments, liens,
encumbrances, lease payments, ground rents, utilities, and other charges relating to
the Property when due. Lender may require Mortgagor to provide to Lender copies of
10008788388
P-MOVI ntvw MortwW
PA141N13702800441700000197023080409Y 01998 Bankers Systems, Inc., St. Cloud, MN Page 2
all notices that such amounts are due and the receipts evidencing Mortgagor's
payment. Mortgagor will defend title to the Property against any claims that would
impair the lien of this Security Instrument. Mortgagor agrees to assign to Lender, as
requested by Lender, any rights, claims or defenses Mortgagor may have against
parties who supply labor or materials to maintain or improve the Property.
8. DUE AN SALE. Lender may, at its option, declare the entire balance of the Secured
Debt to be immediately due and payable upon the creation of, or contract for the
creation of, any transfer or sale of all or any part of the Property. This right is subject
to the restrictions imposed by federal law (12 C.F.R. 591), as applicable..
9. WARRANTIES AND REPRESENTATIONS. Mortgagor has the right and authority to
enter into this Security Instrument, The execution and delivery of this Security
Instrument will not violate any agreement governing Mortgagor or to which Mortgagor
is a party.
10. PROPERTY CONDITION; ALTERATIONS AND INSPECTION. Mortgagor will keep
the Property in good condition and make all repairs that are reasonably necessary.
Mortgagor will not commit or allow any waste, impairment, or deterioration of the
Property. Mortgagor will keep the Property free of noxious weeds and grasses.
Mortgagor agrees that the nature of the occupancy and use will not substantially
change without Lender's prior written consent. Mortgagor will not permit any change
in any license, restrictive covenant or easement without Lender's prior written
consent. Mortgagor will notify Lender of all demands, proceedings, claims, and
actions against Mortgagor, and of any loss or damage to the Property.
Lender or Lender's agents may, at Lender's option, enter the Property at any
reasonable time for the purpose of inspecting the Property. Lender will give Mortgagor
notice at the time of or before an inspection specifying a reasonable purpose for the
inspection. Any inspection of the Property will be entirely for Lender's benefit and
Mortgagor will in no way rely on Lender's inspection.
11. AUTHORITY TO PERFORM. If Mortgagor fails to perform any duty or any of the
covenants contained in this Security Instrument, Lender may, without notice, perform
or cause them to be performed. Mortgagor appoints Lender as attorney in fact to sign
Mortgagor's name or pay any amount necessary for performance. Lender's tight to
perform for Mortgagor will not create an obligation to perform, and Lender's failure to
perform will not preclude Lender from exercising any of Lender's other rights under the
law or this Security Instrument. If any construction on the Property is discontinued or
not carried on in a reasonable manner, Lender may take all steps necessary to protect
Lender's security interest in the Property, including completion of the construction.
12. MORTGAGE COVENANTS. Mortgagor agrees that the covenants in this Security
Instrument are material obligations under the Secured Debts and this Security
Instrument. If Mortgagor breaches any covenant in this Security Instrument, Lender
may refuse to make additional extensions of credit or may reduce the credit limit. By
not exercising either remedy on Mortgagor's breach, Lender does not waive Lender's
right to later consider the event a breach if it happens again.
13. DEFAULT. Mortgagor will be in default if any of the following occur:
A. Fraud. Mortgagor engages in fraud or material misrepresentation in connection
with the Secured Debts.
B. Payments. Any party obligated on the Secured Debts fails to make a payment
when due.
C. Property. Any action or inaction occurs that adversely affects the Property or
Lender's rights in the Property.
14. REMEDIES ON DEFAULT. In addition to any other remedy available under the
terms of this Security Instrument, Lender may accelerate the Secured Debts and
foreclose this Security Instrument in a manner provided by law if Mortgagor is in
10008788389
Pennsylvania Mon"90
PA141N19702800441700000197023060409y 01896 Bankers Systerns, Inc., St. Cloud, MN fev Pega 3
default. In some instances, federal and state law will require Lender to provide
Mortgagor with notice of the right to cure, or other notices and may establish time
schedules for foreclosure actions.
At the option of Lender, all or any part of the agreed fees and charges, accrued
interest and principal will become immediately due and payable, after giving notice if
required by law, upon the occurrence of a default or anytime thereafter.
The acceptance by Lender of any sum in payment or partial payment on the Secured
Debts after the balance is due or is accelerated or after foreclosure proceedings are
filed will not constitute a waiver of Lender's right to require complete cure of any
existing default. By not exercising any remedy on Mortgagor's default, Lender does
not waive Lender's right to later consider the event a default if it happens again.
16. EXPENSES; ADVANCES ON COVENANTS; ATTORNEYS' FEES; COLLECTION
COSTS. If Mortgagor breaches any covenant in this Security Instrument, Mortgagor
agrees to pay all expenses' Lender incurs in performing such covenants or protecting
its security interest in the Property. Such expenses include, but are not limited to,
fees incurred for inspecting, preserving, or otherwise protecting the Property and
Lender's security interest. Mortgagor agrees to pay all costs and expenses incurred by
Lender in collecting, enforcing, or protecting Lender's rights and remedies under this
Security Instrument or any other document relating to the Secured Debts. Expenses
include, but are not limited to, attorneys' fees, court costs and other legal expenses.
These expenses are payable on demand and will bear interest from the date of
payment until paid in full at the highest interest rate in effect as provided for in the
terms of Secured Debts. In addition, to the extent permitted by the United States
Bankruptcy Code, Mortgagor agrees to pay the reasonable attorneys' fees incurred by
Lender to protect Lender's rights and interests in connection with any bankruptcy
proceedings initiated by or against Mortgagor. This Security Instrument will remain in
effect until released. Mortgagor agrees to pay for any recordation costs of such
release.
16. ENVIRONMENTAL LAWS AND HAZARDOUS SUBSTANCES. As used in this
section, (1) Environmental Law means, without limitation, the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA, 42 U.S.C. 9601 at
seq.), all other federal, state and local laws, regulations, ordinances, court orders,
attorney general opinions or interpretive letters concerning the public health, safety,
welfare, environment or a hazardous substance; and (2) Hazardous Substance means
any toxic, radioactive or hazardous material, waste, pollutant or contaminant which
has characteristics which render the substance dangerous or potentially dangerous to
the public health, safety, welfare or environment. The term includes, without
limitation, any substances defined as "hazardous material," "toxic substance,"
"hazardous waste," "hazardous substance," or "regulated substance" under any
Environmental Law.
Mortgagor represents, warrants and agrees that:
A. Except as previously disclosed and acknowledged in writing to Lender, no
Hazardous Substance is or will be located, stored or released on or in the Property.
This restriction does not apply to small quantities of Hazardous Substances that are
generally recognized to be appropriate for the normal use and maintenance of the
Property.
B. Except as previously disclosed and acknowledged in writing to Lender,
Mortgagor and every tenant have been, are, and will remain in full compliance with
any applicable Environmental Law.
C. Mortgagor will immediately notify Lender if a release or threatened release of a
Hazardous Substance occurs on, under or about the Property or there is a violation
of any Environmental Law concerning the Property. In such an event, Mortgagor
will take all necessary remedial action in accordance with any Environmental Law,
10006704389
P. wylvahw Mort~
PA14IN 13702600441700000197023060409Y 01996 Sonkws Sysuma, Inc., St. Glt W. MN 645iAW Pag* 4
D. Mortgagor will immediately notify Lender in writing as soon as Mortgagor has
reason to believe there is any pending or threatened investigation, claim, or
proceeding relating to the release or threatened release of any Hazardous Substance
or the violation of any Environmental Law.
17. CONDEMNATION. Mortgagor will give Lender prompt notice of any pending or
threatened action by private or public entities to purchase or take any or all of the
Property through condemnation, eminent domain, or any other means. Mortgagor
authorizes Lender to Intervene in Mortgagor's name in any of the, above described
actions or claims. Mortgagor assigns to Lender the proceeds of any award or claim for
damages connected with a condemnation or other taking of all or any part of the
Property. Such proceeds will be considered payments and will be applied as provided
in this Security Instrument. This assignment of proceeds is subject to the terms of
any prior mortgage, deed of trust, security agreement or other lien document.
18. INSURANCE. Mortgagor agrees to keep the Property insured against the risks
reasonably associated with the Property. Mortgagor will maintain this insurance in the
amounts Lender requires. This insurance will last until the Property is released from
this Security Instrument. What Lender requires pursuant to the preceding two
sentences can change during the term of the Secured Debts. Mortgagor may choose
the insurance company, subject to Lender's approval, which will not be unreasonably
withheld. All insurance policies and renewals will include a standard "mortgage
clause" and, where applicable, "loss payee clause."
Mortgagor will give Lender and the insurance company immediate notice of any loss.
All insurance proceeds will be applied to restoration or repair of the Property or to the
Secured Debts, at Lender's option. If Lender acquires the Property in damaged
condition, Mortgagor's rights to any insurance policies and proceeds will pass to
Lender to the extent of the Secured Debts.
Mortgagor will immediately notify Lender of cancellation or termination of insurance.
If Mortgagor fails to keep the Property insured, Lender may obtain insurance to protect
Lender's interest in the Property and Mortgagor will pay for the insurance on Lender's
demand. Lender may demand that Mortgagor pay for the insurance all at once, or
Lender may add the insurance premiums to the balance of the Secured Debts and
charge interest on it at the rate that applies to the Secured Debts. This insurance may
include coverages not originally required of Mortgagor, may be written by a company
other than one Mortgagor would choose, and may be written at a higher rate than
Mortgagor could obtain if Mortgagor purchased the insurance. Mortgagor
acknowledges and agrees that Lender or one of Lender's affiliates may receive
commissions on the purchase of this insurance.
19. ESCROW FOR TAXES AND INSURANCE. Mortgagor will not be required to pay to
Lender funds for taxes and insurance in escrow.
20. CO-SIGNERS. If Mortgagor signs this Security Instrument but is not otherwise
obligated to pay the Secured Debts, Mortgagor does so only to mortgage Mortgagor's
interest in the Property to secure payment of the Secured Debts and Mortgagor does
not agree by signing this Security Instrument to be personally liable on the Secured
Debts. If this Security Instrument secures a guaranty between Lender and Mortgagor,
Mortgagor agrees to waive any rights that may prevent Lender from bringing any
action or claim against Mortgagor or any party indebted under the obligation. These
rights may include, but are not limited to, any anti-deficiency or one-action laws.
21. WAIVERS. Except to the extent prohibited by law, Mortgagor waives all
appraisement rights relating to the Property.
22. OTHER TERMS. The following are applicable to this Security Instrument,
A. Una of Credit. The Secured Debts include a revolving line of credit provision.
Although the Secured Debts may be reduced to a zero balance, this Security
10006766388
Pannavlvanfa Mongago
PA14IN13702600441700000197023060409Y 01 996 B-kws System. Inc., St. Cloud, MN 6-? P.O. 5
Instrument will remain in effect until the Secured Debts and all underlying
agreements have been terminated in writing by Lender.
B. Open-End Mortgage. This Security Instrument secures advances by Lender used
in whole or in part to complete erection, construction, alteration or repair of the
Property. Accordingly, this Security Instrument, and the lien hereunder, is and shall
be construed as an open-end mortgage with all pf the rights, priorities and benefits
thereof under the laws of the Commonwealth of Pennsylvania. '
23. APPLICABLE LAW. This Security Instrument is governed by the laws of
Pennsylvania, the United States of America, and to the extent required, by the laws of
the jurisdiction where the Property is located, except to the extent such state laws are
preempted by federal law.
24, JOINT AND INDIVIDUAL LIABILITY AND SUCCESSORS. Each Mortgagor's
obligations under this Security Instrument are independent of the obligations of any
other Mortgagor, Lender may sue each Mortgagor individually or together with any
other Mortgagor. Lender may release any part of the Property and Mortgagor will still
be obligated under this Security Instrument for the remaining Property. If this Security
Instrument secures a guaranty between Lender and Mortgagor, Mortgagor agrees to
waive any rights that may prevent Lender from bringing any action or claim against
Mortgagor or any party indebted under the obligation. These rights may include, but
are not limited to, any anti-deficiency or one-action laws. Mortgagor agrees that
Lender and any party to this Security Instrument may extend, modify or make any
change in the terms of this Security Instrument or any evidence of debt without
Mortgagor's consent. Such a change will not release Mortgagor from the terms of this
Security Instrument. The duties and benefits of this Security Instrument will bind and
benefit the successors and assigns of Lender and Mortgagor.
25. AMENDMENT, INTEGRATION AND SEVERABILITY. This Security Instrument may
not be amended or modified by oral agreement. No amendment or modification of this
Security Instrument is effective unless made in writing and executed by Mortgagor and
Lender. This Security Instrument and any other documents relating to the Secured
Debts are the complete and final expression of the agreement. If any provision of this
Security Instrument is unenforceable, then the unenforceable provision will be severed
and the remaining provisions will still be enforceable.
26. INTERPRETATION. Whenever used, the singular includes the plural and the plural
includes the singular, The section headings are for convenience only and are not to be
used to interpret or define the terms of this Security Instrument.
27. NOTICE, FINANCIAL REPORTS, ADDITIONAL DOCUMENTS AND RECORDING
TAXES. Unless otherwise required by law, any notice will be given by delivering it or
mailing it by first class mail to the appropriate party's address listed in the DATE AND
PARTIES section, or to any other address designated in writing. Notice to one
Mortgagor will be deemed to be notice to all Mortgagors. Mortgagor will inform
Lender in writing of any change in Mortgagor's name, address or other application
information. Mortgagor will provide Lender any financial statements or information
Lender requests. All financial statements and information Mortgagor gives Lender will
be correct and complete. Mortgagor agrees to pay all expenses, charges and taxes in
connection with the preparation and recording of this Security Instrument. Mortgagor
agrees to sign, deliver, and file any additional documents or certifications that Lender
may consider necessary to perfect, continue, and preserve Mortgagor's obligations
under this Security Instrument and to confirm Lender's lien status on any Property,
and Mortgagor agrees to pay all expenses, charges and taxes in connection with the
preparation and recording thereof, Time is of the essence.
100087"SU
Pamaylyania Meet~
PAI41N 137026004417000001970230450409Y 01996 Sonkva Systems, Inc., St. Cloud, MN I5jd5 vY Page 6
SIGNATURES. By signing under seal, Mortgagor agrees to the terms and covenants
contained in this Security Instrument.. Mortgagor also acknowledges receipt of a copy
of this
M
Individually
ACKNOWLEDGMENT.
(Individual)
??WlaM.+?k?brcrlf OF SyGtlblNG¢ G?oU,?TY OF G oP^0C ,t^0 ss,
On is the S day of ..? owe :;2 00 before me,
0414- f- the undersigned officer, personally
appeared ROBERT S GO RICH, and LISA GOODRICH, known to me (or satisfactorily
proven) to be the person(s) whose name(s) is/are subscribed to the within instrument
and acknowledged that he/she/they executed the same for the purposes therein
contained.
In witness whereof, I hereunto set / hand and official ealMy commission expires: 17P?L /J..2 Public}
COMMONWEALTH OF PENNSYLVANIA
NoterW Seat
GO F. Hens, Notary PIA1Mc
Hampden Ttiep., Cumb4d:d C
My Ca wnbsbn EM*- APr.15, 2010
Member, Permylmla Association of Notaries
10006788389
PenneyWaNe 1Aortps9e
PA/41N13702600441700000197023000409Y 01998 9ankers Systems, Inc., St. Coed, MN E aW P¦9e 7
It is hereby certified that the address of the Lender within named is: 1570 Manheim
Pike PO Box 3300, Lancaster, Pennsylvania 17604-3300.
Susquehanna a
B _
Ana o
10000796389
Pennsylvania Merpyayo
MAIN 13702WO441700000197023060409Y 01996 Bankers Systems, Inc., St. Cloud, MN Eli Fags 8
PropcM Address
1595 W LISBURN RD
MONROB TWP (MECHANICSBURO), PA
SCHEDULE A
ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN
THE TOWNSHIP OF MONROE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF
PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEGINNING AT TE IRON PIN ON THE SOUTHERN LINE OF LISBURN ROAD AT THE CORNER OF
PROPERTY NOW OF FORMERLY OF GEORGE EBENER, AS SHOWN ON THE PLAN OF ALLEN PARK,
WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND
COUNTY IN PLAN BOOK 22, PAGE 83; THENCE ALONG THE SOUTHERN LINE OF LISBURN ROAD,
SOUTH 65 DEGREES 31 MINUTES 15 SECONDS EAST, 205.26 FEET TO A POINT; THENCE ALONG
LAND NOW OR LATE OF SKIRO, INC. (LOT 8 ON SAID PLAN), SOUTH 24 DEGREES 28 MINUTES 45
SECONDS WEST, 150.11 FEET TO A POINT; THENCE ALONG THE SAME, SOUTH 65 DEGREES 32
MINUTES 15 SECONDS EAST, 30.08 FEET TO A POINT; THENCE CONTINUING ALONG LANDS NO W
OR LATE OF SKIRO, INC., SOUTH 26 DEGREES 35 MINUTES WEST 500.00 FEET TO A POINT AT LINE
NOW OR FORMERLY OF WILLIAM E. LEIS; THENCE ALONG THE LATTER, NORTH 63 DEGREES 25
MINUTES WEST, 329.38 FEET TO A POINT AT LINE OF LANDS NOW OR LATE OF GEORGE EBENER;
THENCE ALONG THE LATTER, NORTH 34 DEGREES 27 MINUTES 20 SECONDS EAST, 647.48 FEET TO
AN IRON PIN, THE PLACE OF BEGINNING.
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240.6370
Instrument Number - 208920354
Recorded On 6116/2009 At 1:05:52 PM
* Instrument Type - MORTGAGE
Invoice Number -46107 User ID - KW
* Mortgagor - GOODRICH, ROBERT S
* Mortgagee - SUSQUEHANNA BANK
* Customer - SUSQUEHANNA
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $10.00
JUSTICE
RECORDING FEES - $21.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $58.50
* Total Pages - 10
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
RECORDER O D DS
* - Information denoted by an asterisk may change during
the verification process and may not be reflected an this payees.
11111111111111
??
J r ? ?
Susquehcin?'
Susquehanna Bank
P.O. Box 639
Maugansvift. MD 217674639
Toll free 888.722.7270
CERTIFIED MAIL 91 7199 9991 7030 6661 5200
Dote: March 13, 2012
TO: Lisa Goodrich
RE: Mortgage Loan # 766389
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by Susquehanna Hank now Susquehanna Bank, (hereinafter we, us or ours)
on your property located at
1595 W Lisburn Road, Mechanicsburg, PA 17055
A. IS IN SERIOUS DEFAULT
Principal Amount Due:
Interest Amount Due:
Attorney Fees:
Appraisal Fees:
Title Search:
Force Placed Insurance:
Escrow:
Other:
Late Charges:
$ 0.00
$1,998.00
$ 0.00
$ 300.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 281.22
TOTAL AMOUNT TO CURE THE DEFAULT
$ 2,579.22
The total amount now required to cure this default, or in other words, get caught up with your
payments, as of the date of this letter is $2,579.22.
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not
applicable.)
2459591-1
of the date of this letter b a vin to us the
You cure this default within THIRTY 34 DAYS -.Y 10 la
above amount of $2 579 22 plus ny additional monthly pgMent and late charge which may become
due if payment is not made lbv Auril 16.20 U. Such payment must be made either by cash, cashier's
check, certified check or money order and sent to:
Susquehanna Bank
C/o Susquehanna Loan Center
P.O. Box 639
Maugansville, MD 21767-4639
You can cure any other default by taking the following action within THIRTY (30) DAYS of the
date of this letter: (Do not use if not applicable.)
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our ristht to
gMlerate the mortgage RUments. 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 (34) DAYS, we also intend to instruct our attomevs to start a lawsuit to foreclose your
mortggged »roperty. If the mortgage is foreclosed. your mortgaged property will be sold by the
Sheriff to off the mo a 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 $50.44. 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. If you cure the default
within the thirty day period you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage. Such suit against you personally may also result in your mortgage being foreclosed and
your mortgaged property being sold at Sheriffs sale.
If we start the lawsuit to foreclose your mortgage, or if we sue you personally for the unpaid balance
and all other sums due under the mortgage which may also result in foreclosure and sale of your
mortgaged property, you have the right to assert in either of those lawsuits the nonexistence of a
default or any other defense you may have to acceleration and foreclosure.
If you have obtained an Order of Discharge from the United States Bankruptcy Court, which
includes this debt, we are not attempting to obtain a judgment against you, nor are we alleging that
you have any personal liability for this debt. We may, however, take action against the property
pledged as collateral for the debt, which may include repossession and/or foreclosure of the
property.
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 lrevent the sale at any time un to one hour before the
2459591-1
Sheriffs foreclosure sale You maYdo sq b uaving_the, total amount of the unpaid monthly payments
plus„any late or other charges then due as well as the reasanbie attorney's fees and costs connected
with the foreclosure sale and perform any other Le-WI rements under the mortaaae It is estimated that
the earliest date that such a Sheriffs sale could be held would be approximately fly 11.20. A
notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You may find out at any time exactly
what the required payment will be by calling us at the following number:
Name of Lender: Susquehanna Bank
Address: C/O Susquehanna Loan Center, P.O. Box 639, Maugansvilie, MD 217674.639
Phone Number: 888-722-7270 ext. 27234
Fax Number: 240-313-1563
Contact Person: Christina / seg
E-Mail Address: LoanCTR-Collection usguehana%.net
This payment must be in cash, cashiers 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 you.
You have additional rights to help protect your interests 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 HAVE THE RIGHT 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.
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Susquehanna Bank offers consumer
assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are
provided without cost to our customers. You may be eligible for a loan workout plan or other similar
situation. If you would like to learn more about these programs, you may contact the Susquehanna Bank
Collections and Recovery Department 1-888-722-7270. WE ARE VERY INTERESTED IN ASSISTING
YOU.
Attention Servicemembers and dependents: The Federal Servicemembers' Civil Relief Act
("SCRA") and certain state laws provide important protections for you, including prohibiting
foreclosure under most circumstances. If you are currently in the military service, or have been within
the last nine (9) months, AND joined after signing the Note and Security Instrument now in default,
please notify us immediately. When contacting Susquehanna Bank as to your military service, you
must provide positive proof as to your military status. If you do not provide this information, it will be
assumed that you are not entitled to protection under the above-mentioned Act.
2459591-1
For your benefit and assistance, there are government approved homeownership counseling agencies
designed to help homeowners avoid losing their homes. To obtain a list of approved counseling
agencies, please call (800) 5694287 or by visiting http://www.hud.gov/offices/hsgtsfh/hcc/hcs.efin.
You may also contact the Homeownership Preservation Foundation's Hope hotline at (888) 995-
HOPE (4673). This matter is very important. Please give it your immediate attention.
Christina / seg, Legal Coordinator
Susquehanna Bank
1-888-722-7270 ext. 27234
2459591-1
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Susquehanna Bank
P.O. Box 639
Maugarmipe, MD 21767-0839
Toll free 888.722.7270
CERTIFIED MAIL 917199 "917030 6661 5217
Date: March 13, 2012
TO: Lisa Goodrich
RE: Mortgage Loan # 766389
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by Susquehanna Bank now Susquehanna Bank, (hereinafter we, us or ours)
on your property located at
1545 W Lisburn Road, Mechanicsburg, PA 17055
A. IS IN SERIOUS DEFAULT
Principal Amount Due:
Interest Amount Due:
Attorney Fees:
Appraisal Fees:
Title Search:
Force Placed Insurance:
Escrow:
Other:
Late Charges:
$ 0.00
$ 1,998.00
$ 0.00
$ 300.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 281.22
TOTAL AMOUNT TO CURE THE DEFAULT
$ 2,579.22
The total amount now required to cure this default, or in other words, get caught up with your
payments, as of the date of this letter is $2,579.22.
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not
applicable.)
2459591-1
Susquehanna Bank
C/o Susquehanna Loan Center
P.O. Box 639
Maugansville, MD 21767-0539
You can cure any other default by taking the following action within THIRTY (30) DAYS of the
date of this letter: (Do not use if not applicable.)
If you do notcure the default within THIRTY (30) DAYS, we intend, togxercise our ri t to
ac, Werate the mortgage RUM=. 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
If the mortgage is 2EMIogsed. your 1 o will sold by the
Ski ff_to gU off the n gage 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 awe us, which may also include our reasonable costs. If you cure the default
within the thirty day pp iod You will not be required to nay Mg-m-s
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage. Such suit against you er ally may also result in your mortgage being foreclosed and
your mortgaged property being sold at Sheriffs sale.
If we start the lawsuit to foreclose your mortgage, or if we sue you personally for the unpaid balance
and all other sums due under the mortgage which may also result in foreclosure and sale of your
mortgaged property, you have the right to assert in either of those lawsuits the nonexistence of a
default or any other defense you may have to acceleration and foreclosure'.
If you have obtained an Order of Discharge from the United States Bankruptcy Court, which
includes this debt, we are not attempting to obtain a judgment against you, nor are we alleging that
you have any personal liability for this debt. We may, however, take action against the property
pledged as collateral for the debt, which may include repossession and/or foreclosure of the
property.
If you have not cured the default within the thirty-day period and foreclosure proceedings have begun,
you still have the ' t to cure the, f ul and event the sale at an time to one hour before the
2439591-1
Shc-dffg f osure sale. You do aQ by min& the WW amount
lus to or oftr charges then as well as tly r of the `d Moghly n
le e ' f c sonab and costs
with 11A foreclosum le and taerform any other repuircments under the mortaage. It is estimated that
the earliest date that such a Sheriffs We could be held would be approximately July 11. 2012. A
notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You may find out at any time exactly
what the required payment will be by calling us at the following number:
Name of Lenders
Address:
Pbone Number:
Fax Number:
Contact Person:
E-Mail Address:
240-313-1563
This payment must be in cash, cashiers 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 dive in the property after the Sheriffs sale, a lawsuit could be
started to evict you.
You have additional rights to help protect your interests 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 PAYOFF THIS DEBT.
YOU HAVE THE RIGHT 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.
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Susquehanna Bank offers consumer
assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are
provided without cost to our customers. You may be eligible for a loan workout plan or other similar
situation. If you would like to leers more about these programs, you may contact the Susquehanna Bank
Collections and Recovery Department 1-$$$-722-7270. WE ARE VERY INTERESTED IN ASSISTING
YOU.
Attention Servicemembers and dependents The Federal Servicemembers` Civil Relief Act
("SCRA") and certain state laws provide important protections for you, including prohibiting
foreclosure under most circumstances. If you are currently in the military service, or have been within
the last nine (9) months, AND joined after signing the Note and Security Instrument now in default,
please notify us immediately. When contacting Susquehanna Bank as to your military service, you
must provide positive proof as to your military status. If you do not provide this information, it will be
assumed that you are not entitled to protection under the above-mentioned Act.
2459591-1
For your befit and assistance, there are government approved homeownership counseling agencies
designed to help homeowners avoid losing their homes. To obtain a list of approved counseling
agencies, please call (800) 569-4287 or by visiting http:f/www.hud.gov/offices/hsg/sMcc/hcs.cfin.
You may also contact the Homeownership Preservation Foundation's Hope hotline at (888) 995-
HOPE (4673). This matter is very important. Please give it your immediate attention.
Christina / seg, Legal Coordinator
Susquehanna Bank
1-888-722-7270 ext. 27234
2459591-1
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CERTIFIED MAIL 9171" 9991 7030 66615187
Date: March 1.3, 2012
TO: Robert S Goodrich
RE: Mortgage Loan # 766389
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by Susquehanna Bank now Susquehanna. Bank, (hereinafter we, us or ours)
on your property located at
1595 W Lisburn Road, Mechanicsburg, PA 17055
A. IS IN SERIOUS DEFAULT becauw you have riot wade monthly t>a yments and other
chames for October 30, 2011 thru February 28, 2011 as follows.
Principal Amount Due:
Interest Amount Due:
Attorney Fees:
Appraisal Fees:
Title Search:
Force Placed Insurance:
Escrow:
Other:
Late Charges:
TOTAL AMOUNT TO CURE THE DEFAULT
lun guar Bmlc
Po; Box 639
Maupnsville, MD 21787-0839
Toll ftm 888:722:7270
$ 0.00
$ 1,998.00
$ 0.00
$ 300.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 281.22
$ 2L579.22
The total amount now required to cure this default, or in other words, get caught up with your
payments, as of the date of this letter is $2,579.22.
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not
applicable.)
2459591-1
You may cure this default within THIRTY (30) DAYS, of the date of this letter, by gaying to us the
above amount of $2,579.21 plus any additional monthly pgvment and late charge which may become
due if payment is not made by April 16, 20112. Such payment must be made either by cash, cashier's
check, certified check or money order and sent to:
Susquehanna Bank
C/o Susquehanna Loan Center
P.O. Box 639
Maugansville, MD 21767-0639
You can cure any other default by taking the following action within THIRTY (30) DAYS of the
date of this letter: (Do not use if not applicable.)
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to
accelerate the mortgage paymeuq, 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 forec M your
mortgaged property If the mortgaae is foreclosed, your mortgag nroRg ty will be sold by the
Shoriffto pay off the moAM 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. If you cure the default
within the thirty dj period, owl not be required to nay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage. Such suit against you erso may also result in your mortgage being foreclosed and
your mortgaged property being sold at Sheriffs sale.
If we start the lawsuit to foreclose your mortgage, or if we sue you personally for the unpaid balance
and all other sums due under the mortgage which may also result in foreclosure and sale of your
mortgaged property, you have the right to assert in either of those lawsuits the nonexistence of a
default or any other defense you may have to acceleration and foreclosure.
If you have obtained an Order of Discharge from the United States Bankruptcy Court, which
includes this debt, we are not attempting to obtain a judgment against you, nor are we alleging that
you have any personal liability for this debt. We may, however, take action against the property
pledged as collateral for the debt, which may include repossession and/or foreclosure of the
property.
If you have not cured the default within the thirty-day period and foreclosure proceedings have begun,
you still have the rioht to cure the default and prevent the sale at any time uv to one hour before the
2459591-1
Sheriff s forlosure sale You may do so by haying the total mount of the utt>,aid monthly navments
plus any late or other charges then due as well as the reasonable attomey's fees an costs connec
with the foreclosure sale and rforrn any od-wr MgMirements under the mortg,=e It is estimated that
the earliest date that such a Sheriffs sale could be held would be approximately Jul 11, 2012. A
notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You may find out at any time exactly
what the required payment will be by calling us at the following number:
Name of Lender: Susquehanna Bank
Address: C/O Susquehanna Loan Centor, PD. box 639, NuutaurAlle, l4ID 2176740639
Phone Number: 8>I13-722-7270 ext. 27234
F'ax' Number: 240-313-1563
Contact Person: Christina / seg
E-Mail Address: Le*nCTR-Colle+cqpns&u utb*nua
This payment must be in cash, cashiers 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 you.
You have additional rights to help protect your interests 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 PAYOFF THIS DEBT.
YOU HAVE THE RIGHT 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.
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Susquehanna Bank offers consumer
assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are
provided without cost to our customers. You may be eligible for a loan workout plan or other similar
situation. If you would like to team more about these programs, you may contact the Susquehanna Bank
Collections and Recovery Department 1-888-722-7270. WE ARE VERY INTERESTED IN ASSISTING
YOU.
Atte don Servicemembm and dependents; The Federal Servicemembere Civil Relief Act
("SCRA") and certain state laws provide important protections for you, including prohibiting
foreclosure under most circumstances. If you are currently in the military service, or have been within
the last nine (9) months, AND joined after signing the Note and Security Instrument now in default,
please notify us immediately. When contacting Susquehanna Bank as to your military service, you
must provide positive proof as to your military status. If you do not provide this information, it will be
assumed that you are not entitled to protection under the above-mentioned Act.
2459591-1
For your benefit and assistance, there are government approved homeownership counseling agencies
designed to help homeowners avoid losing their homes. To obtain a list of approved counseling
agencies, please call (800) 569-4287 or by visiting http://www.hud.gov/offices/hsglsftAce/hcs.cfim.
You may also contact the Homeownership Preservation Foundation's Hope hotline at (898) 995-
HOPE (4673). This matter is very important. Please give it your immediate attention.
Christina / seg, Legal Coordinator
Susquehanna Bank
1-888-722-7270 ext. 27234
2459591-1
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CERTIFIED MAIL 91 7199 "917030 6661 5194
Date: March 13, 2012
TO: Robert S Goodrich
RE: Mortgage Loan # 766389
8usgueMnns Bank
Ro. Box 639
Maugansviile, MO 21767.0639
ToU free W6.722.7270
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
The MORTGAGE held by Susquehanna Bank now Susquehanna Bank, (hereinafter we, us or ours)
on your property located at
1595 W Lisburn Road, Mechanicsburg, PA 17055
A. IS IN SERIOUS DEFAULT
Principal Amount Due:
Interest Amount Due:
Attorney Fees:
Appraisal Fees:
Title Search:
Force Placed Insurance:
Escrow:
Other:
Late Charges:
TOTAL AMOUNT TO CURE THE DEFAULT
Soguetrnnn
$ 0.00
$ 1,998.00
$ 0.00
$ 300.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 281.22
$ 2,579.22
The total amount now required to cure this default, or in other words, get caught up with your
payments, as of the date of this letter is $2,579.22.
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not
applicable.)
2459591-1
.. ,
You ;pa cure this default within THIRTY (30) DAYS, pf the date of this letter, by Raving to us the
above amount of $2,579.22, plus any -additional monthly Ravmentand late charge which may become
due if Rayment is not made by ARM 16, 2812. Such payment must be made either by cash, cashier's
check, certified check or money order and sent to:
Susquehanna Bank
C/o Susquehanna Loan Center
P.O. Box 639
Maugansville, MD 21767-0639
You can cure any other default by taking the following action within THIRTY (30) DAYS of the
date of this letter: (Do not use if not applicable.)
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to
accelerate the mortgggc p&yments. 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 in#end to instruct our attorneys to start a lawsuit to foreclose your
mortgaged pfo X If the mortgage is foreclosed, your mortgaged prvpgU 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. If you cure the default
within the thirty day period. you will not be reauir to Ray attorney'5fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the
mortgage. Such suit against you peMnally may also result in your mortgage being foreclosed and
your mortgaged property being sold at Sheriffs sale.
If we start the lawsuit to foreclose your mortgage, or if we sue you personally for the unpaid balance
and all other sums due under the mortgage which may also result in foreclosure and sale of your
mortgaged property, you have the right to assert in either of those lawsuits the nonexistence of a
default or any other defense you may have to acceleration and foreclosure.
If you have obtained an Order of Discharge from the United States Bankruptcy Court, which
includes this debt, we are not attempting to obtain a judgment against you, nor are we alleging that
you have any personal liability for this debt. We may, however, take action against the property
pledged as collateral for the debt, which may include repossession and/or foreclosure of the
property.
If you have not cured the default within the thirty-day period and foreclosure proceedings have begun,
o still have the right to cure th default and revers the We at an time LiR to one hour before the
2459591-1
4 e 4 s
Sheriffs foreclosure sale You may do so by gUina the total amount of the unvaid monthly vavments
plus any late or other charges then due as well as the monable attorney's fees and costs connected
with the foreclosure sale and perform another requirements under the mortgpie. It is estimated that
the earliest date that such a Sheriffs sale could be held would be approximately July 11, 2012. A
notice of the date of the Sheriffs sale will be sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You may find out at any time exactly
what the required payment will be by calling us at the following number:
Name of Lender:
Address:
Phone Number:
Fax Number:
Contact Person:
E-Mail Address:
Susquehanna Bank
C/O Susquehanna Loan Center, P.O. Box 639, MaugartrAlle, MD 21767-0639
888-722-7270 ext. 27234
240-313-1563
Christina / seg
LoanCTR-Collections(a-susquehanna.net
This payment must be in cash, cashiers 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 you.
You have additional rights to help protect your interests 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 HAVE THE RIGHT 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. '
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Susquehanna Bank offers consumer
assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are
provided without cost to our customers. You may be eligible for a loan workout plan or other similar
situation. If you would like to learn more about these programs, you may contact the Susquehanna Bank
Collections and Recovery Department 1-888-722-7270. WE ARE VERY INTERESTED IN ASSISTING
YOU.
Attention Servicemembers and dependents: The Federal Servicemembers' Civil Relief Act
("SCRA") and certain state laws provide important protections for you, including prohibiting
foreclosure under most circumstances. If you are currently in the military service, or have been within
the last nine (9) months, AND joined after signing the Note and Security Instrument now in default,
please notify us immediately. When contacting Susquehanna Bank as to your military service, you
must provide positive proof as to your military status. If you do not provide this information, it will be
assumed that you are not entitled to protection under the above-mentioned Act.
2459591-1
'f . I A
For your benefit and assistance, there are government approved homeownership counseling agencies
designed to help homeowners avoid losing their homes. To obtain a list of approved counseling
agencies, please call (800) 569-4287 or by visiting http:/fwww.hud.gov/officesthsg/sfh/hcc/hes.cfaL
You may also contact the Homeownership Preservation Foundation's Hope hotline at (888) 995-
HOPE (4673). This matter is very important. Please give it your immediate attention.
Christina / seg, Legal Coordinator
Susquehanna Bank
1-888-722-7270 ext. 27234
2459591-1
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VERIFICATION
I hereby verify that I am a Legal Coordinator at Susquehanna Bank; that as such I am
authorized to make this verification; and that the information set forth in the foregoing
Complaint is true and correct to the best of my knowledge, information and belief. I
understand that any false statements contained herein are subject to the penalties of 18 Pa.C.S.
§ 4904, relating to unsworn falsification to authorities.
Dated:
Christina Frederickson, Legal Coordinator
Susquehanna Bank
{00648939.doc}
No. 12
;" ttrr".?`?uF
BRUBAKER CONNAUGHTON GOSS & LUCARELLI LLC 2012 AUG -2
By: Robert W. Pontz, Esquire
Attorney I.D. No. 56554 cUMBERIA
Dana C. Panagopoulos, Esquire PENNS)
Attorney I.D. No. 89491
460 New Holland Ave, Suite 6205 Attorneys for Plaintiff:
Lancaster, PA 17602 Susquehanna Bank
SUSQUEHANNA BANK,
Plaintiff
vs.
ROBERT S. GOODRICH and
LISA GOODRICH, h/w
Defendants
IN THE COURT OF COMMON
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 12-2936
PRAECIPE TO WITHDRAW APPEARANCE AND
CHANGE CONTACT INFORMATION
TO THE PROTHONOTARY:
Kindly withdraw the appearance of the law firm of Hartman Underhill & Brubaker
and enter the appearance of the law firm of Brubaker Connaughton Goss & Lucarelli LLC.
Please amend the docket to reflect the following new contact information:
Brubaker Connaughton Goss & Lucarelli LLC
480 New Holland Avenue, Suite 6205
Lancaster, PA 17602
Phone: 717-945-5745/Fax: 717-945-5764
CONNAUGHTON GOSS & LUCARELLI
Dated: 7 -? Z- By:
0.
Robert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 894941
!936
icL
NOTAR`f
2--11
Ty
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PR()'
2012AUG -7
"UNSERLANJ
BRUBAKER CONNAUGHTON GOSS & LUCARELLI LLC PE"SYV
By: Robert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 89491
460 New Holland Ave, Suite 6205 Attorneys for Plaintiff:
Lancaster, PA 17602 Susquehanna Bank
SUSQUEHANNA BANK,
vs.
Plaintiff
ROBERT S. GOODRICH and
LISA GOODRICH, h/w
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 12-2936
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Pursuant to Pa.R.C.P. 401(b)(1), please reinstate the Complaint filed on May 1(
2012 in the above-captioned matter.
BRUBAKER CONNAUGHTON GOSS & LUCARELLI
Dated: F I I ) / j 0'-O ' Z By:
Robert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 894941
6b
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BRUBAKER CONNAUGHTON GOSS & LUCARELLI LLC
By: Robert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 89491
460 New Holland Ave, Suite 6205 Attorneys for Plaintiff:
Lancaster, PA 17602 Susquehanna Bank
SUSQUEHANNA BANK, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
vs.
NO. 12-2936
ROBERT S. GOODRICH and
LISA GOODRICH, h/w
Defendants
MOTION FOR AUTHORIZATION TO SERVE COMPLAINT
BY PUBLICATION PURSUANT TO PA.R.C.P. 430
1. The Movant is Susquehanna Bank, a Pennsylvania banking institution with
offices located at 1570 Manheim Pike, Lancaster, Pennsylvania 17604, Plaintiff in this
proceeding.
2. The Respondents are Robert S. Goodrich and Lisa Goodrich, with a last known
address of 218 S. Pebble Beach Boulevard, Sun City Center, Hillsborough County, Florida
33573 ("Pebble Beach Blvd"), the Defendants in this proceeding.
3. Plaintiff commenced this civil proceeding by filing its Complaint (`
on May 10, 2012 for Defendants' failure to pay amounts due and owing under the terms of a li
of credit secured by a mortgage on the Defendants' former residence located at 1595 W. Lis
Road, Mechanicsburg, Cumberland County, Pennsylvania (the "Mortgaged Premises").
4. Upon filing, the Complaint was forwarded to MercuryServe, Inc.
("MercuryServe"), a process server located in Tampa, Florida, for personal service of the
Complaint upon the Defendants.
5. On May 25, 2012, MercuryServe informed counsel that the Defendants could
be located and had, according to others, moved from the Pebble Beach Blvd address. A true
correct copy of the affidavits of Lisa. Soupart of MercuryServe are collectively attached
incorporated by reference and marked as Exhibit A.
6. At the request of counsel, MercuryServe conducted a skip trace, but such
investigation did not reveal an alternative service address.
7. Counsel also conducted Internet research for an alternate address. The only
addresses found were the Pebble Beach Blvd address and the Mortgaged Premises.
8. Attached to this Motion, incorporated by reference and marked Exhibit B is
Affidavit of Plaintiff s counsel, describing the nature and extent of the investigation which has
been made to determine the whereabouts of Defendants and the reasons why service of the
Complaint in accordance with Pa.R.C.P. 402(a) cannot be made.
9. Plaintiff has made all reasonable efforts to locate and personally serve
with the Complaint herein.
10. Based upon information and belief, Plaintiff believes, and therefore avers, that
Defendants do not reside at the Pebble Beach Blvd address, but may reside elsewhere in Sun
City Center, Florida.
11. Based upon the information provide to MercuryServe by neighbors of the Pe
Beach Blvd address, counsel did not attempt to serve Defendants by mail. See Exhibit A.
12. Plaintiff believes that Defendants are avoiding service of the Complaint
them.
13. In light of the Plaintiff s continuing inability to serve the Defendants, despite
efforts outlined in Exhibits A and B, Plaintiff requests an Order pursuant to Pa.R.C.P. 430(a)
authorizing service of the Complaint by publication of notice of this proceeding as provided
under Pa.R.C.P. 430(b)(1).
14. Plaintiff proposes to publish notice of this proceeding complying with Pa.R.
430(b)(1), in the form attached hereto, incorporated by reference and marked Exhibit C, one
time each in the The Tampa Tribune and the Gulf Coast Business Review, both newspapers
general circulation in Hillsborough County, Florida.
WHEREFORE, Plaintiff and Movant, Susquehanna Bank, requests, pursuant to Pa.R.C~.P.
430, entry of an Order in the form submitted with this Motion, permitting alternate service of
Complaint described herein upon Defendants/Respondents, Robert S. Goodrich and Lisa
Goodrich.
BRUBAKER CONNAUGHTON GOSS & LUCARELLI
Dated: ~ ~ l By:
L,/
Hobert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 894941
EXHIBIT A
AFFIDAVIT OF NON-SERVICE
Commonwealth of Pennsylvania
Case Number: 12-2936
Plaintiff:
SUSQUEHANNA BANK
vs.
Defendants:
ROBERT S. GOODRICH AND LISA GOODRICH, HNV
For:
Robert Pontz
Hartman Underhill & Brubaker LLP
221 E Chestnut St.
Lancaster, PA 17602
County of
Received by MercuryServe, Inc. on the 18th day of May, 2012 at 10:18 am to be served on LISA
PEBBLE BEACH BLVD., SUN CITY CENTER, FL 33573.
I, Lisa Soupart, being duly sworn, depose and say that on the 23rd day of May, 2012 at 8:30 pm, I:
NON-SERVED: I discontinued attempting service of the NOTICE TO DEFEND AND COMPLAINT WITH
EXHIBITS A - C for the reasons detailed in the comments below.
Additional Information pertaining to this Service:
SUBJECT DOES NOT RESIDE AT THE GIVEN ADDRESS PER NEIGHBOR AT 216 PEBBLE BEACH BLVD
NEIGHBOR STATED THAT GOODRICH'S SISTER RESIDES AT 218 AND HAS BEEN GONE FOR OVER 2
MONTHS. NEIGHBOR ALSO STATED THAT SHE BELIEVES THE GOODRICH'S STILL LIVE SOMEWHERE
SUN CITY CENTER. SKIP TRACE DID NOT PROVIDE ANOTHER PROBABLE ADDRESS.
218
IN
I certify that I am over the age of 18 and have no interest in the above action. Pursuant to Florida Statute 92. 5,
and under penalties of perjury, I declare that I have read the foregoing Return of Service, and that the facts st ted in
it are true.
Subscribed and Sworn to before me on the 27th day
of July, 2012 by the affiant who is personally known to
me.
Lisa Soupart
09-711481
MercuryServe, Inc.
100 S. Ashley Drive
Suite 1235
Tampa, FL 33602
(813) 223-5400
Our Job Serial Number: MSI-2012005674
Circuit Court
Copyright ®1992-2011 Database Services, Inc. -Process Server's Toolbox V6.5c
AFFIDAVIT OF NON-SERVICE
Commonwealth of Pennsylvania
Case Number: 12-2936
Plaintiff:
SUSQUEHANNA BANK
vs.
Defendants:
ROBERT S. GOODRICH AND LISA GOODRICH, HNV
For:
Robert Pontz
Hartman Underhill & Brubaker LLP
221 E Chestnut St.
Lancaster, PA 17602
County of
Received by MercuryServe, Inc. on the 18th day of May, 2012 at 10:18 am to be served on ROBERT S.
GOODRICH, 218 PEBBLE BEACH BLVD., SUN CITY CENTER, FL 33573.
I, Lisa Soupart, being duly sworn, depose and say that on the 23rd day of May, 2012 at 8:30 pm, 1:
Circuit Court
NON-SERVED: I discontinued attempting service of the NOTICE TO DEFEND AND COMPLAINT WITH
EXHIBITS A - C for the reasons detailed in the comments below.
Additional Information pertaining to this Service: ~
SUBJECT DOES NOT RESIDE AT THE GIVEN ADDRESS PER NEIGHBOR AT 216 PEBBLE BEACH BLVD
NEIGHBOR STATED THAT GOODRICH'S SISTER RESIDES AT 218 AND HAS BEEN GONE FOR OVER 2
MONTHS. NEIGHBOR ALSO STATED THAT SHE BELIEVES THE GOODRICH'S STILL LIVE SOMEWHER IN
SUN CITY CENTER. SKIP TRACE DID NOT PROVIDE ANOTHER PROBABLE ADDRESS.
I certify that I am over the age of 18 and have no interest in the above action. Pursuant to Florida Statute 92.
and under penalties of perjury, I declare that I have read the foregoing Return of Service, and that the facts st
it are true.
_.__. _._
Subscribed and Swom to before me on the 27th day
of July, 2012 by the affiant who is personally known to
Lisa Soupart
09-711481
me.
MercuryServe, Inc.
t, ' ' 100 S. Ashley Drive
NOTARY PUBLIC Suite 1235
Tampa, FL 33602
" _ ' - _ (813) 223-5400
Our Job Serial Number: MSI-2012005673
Copyright ®1992-2011 Database Services, Inc. -Process Servefs Toolbox V6.Sc
in
EXHIBIT B
BRUBAKER CONNAUGHTON GOSS & LUCARELLI LLC
By: Robert W. Pontz, Esquire
Attorney LD. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 89491
460 New Holland Ave, Suite 6205 Attorneys for Plaintiff:
Lancaster, PA 17602 Susquehanna Bank
SUSQUEHANNA BANK, 1N THE COURT OF COMMON PLEA
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
vs.
NO. 12-2936
ROBERT S. GOODRICH and
LISA GOODRICH, h/w
Defendants
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA )
SS
COUNTY OF LANCASTER )
DANA C. PANAGOPOULOS, ESQ., being duly affirmed according to law, deposes
to the best of her knowledge, information and belief that:
1. She is an associate of the law firm of Brubaker Connaughton Goss & L
which firm is acting as attorneys for Susquehanna Bank, Movant and Plaintiff in this civil
2. On May 10, 2012, Plaintiff filed its Complaint herein and forwarded the
process server, MercuryServe, Inc. ("MercuryServe"), located in Tampa, Florida, for service
Defendants, Robert S. and Lisa Goodrich at their last known address in Plaintiff's records, 21 ~ S.
Pebble Beach Boulevard, Sun City Center, Florida 33573 ("Pebble Beach Blvd").
3. As set forth in the Motion to which this Affidavit is appended and i
says,
LLC,
by
to a
reference, MercuryServe was unable to serve the Complaint upon the Defendants.
4. Counsel conducted Internet searches but was unable to find another alternate ~ddress.
5. On or about June 7, 2012, counsel made an inquiry to the United State Postal Authority,
which revealed that Defendants' current address is the Pebble Beach Blvd address. A copy o the
Change of Address response from the Postmaster confirming Defendants' address is attache hereto as
Exhibit 1.
6. After extensive effort and investigation, as described in this Affidavit, the Af davit of
MercuryServe and the Motion, Plaintiff has been unable to locate another alternate address f r service
of the Complaint upon Defendants, Robert S. and Lisa Goodrich.
BRU AKER CONNAUGHTON GOSS & LUCAREL I LLC
~ ~ ~ ~ f r__.`` )
Dated: ; ' i ~% ~.1...` ,~ ~? By: ~ ~ ~" ~~''~ ,__.,_.____
~~
ana C. Panagopoulos, Esquire
Attorney LD. No. 894941
Sworn and subscribed
Before me this day of
2012.
Notary Public
My Commission expires:
EXHIBIT 1
The Postal Service does not have a database with the current address of all of its customers. It doesn't need that informal n since it
delivers to addresses, rather than to individuals. However, if a customer moves and files a change of address order, that i formation
is kept at the post office serving the last known address. The disclosure of customer name and address information is con ained at
section 265.6(d} of our regulations (39 CFR 265), which can be accessed from the FOIA home page. Change of address i formation
about individuals or families is available only to government agency requesters, to persons needing the information to serv legal
process who meet certain requirements, or pursuant to a court order.
The Postal Service suggests the following format to be used in conjunction with regulations at 39 CFR 265.6(d}(4)(ii) by pe sons
empowered by law to serve legal process when requesting change of address or boxholder information.
The request should be forwarded to the Postmaster of the last known address.
Postmaster Date June 7, 2012
Sun City Center, FL 33573
City, State, ZIP Code
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PR CESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: Lisa Goodrich
Address: 218 S. Pebble Beach Blvd. Sun Ci Center FL 33573
Note: Only one request may be made per completed form. The name and last known address are required for change of ddress
information. The name, if known and Post Office box address are required for boxholder information. The following inform tion is
provided in accordance with 39 CFR 265.6(d)(4)(ii). There is no fee charged for change of address or boxholder informatio .
1. Capacity of requester (process server, attorney, party representing self): Attorne for Sus uehanna Bank
2. Statute or regulation that empowers me to serve process (not required for attorney's or a party acting pro se-except a rporation
acting pro se must cite statute: nla
3. The names of all known parties to the litigation: Sus uehanna Bank v. Robert S. Goodrich and Lisa Goodrich
4. The court in which the case has been or will be heard: Court of Common Pleas of Cumberland Count Penns Ivania
5. The docket or other identifying number if one has been issued: CI-12-2936
6. The capacity in which this individual is to be served (defendant or witness) Defendant
WARNING: THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMAT ON OR
BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECT ON WITH
ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO 10,000
OR IMPRISONMENT OF NOT MORE THAN 5 YEARS, OR BOTH TI( TLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of I a!
ocess in conj
u
nction with actual or prospective litigation.
/
~
-
l
.
Hartman Underhill & Brubaker LLP, 221 East Chestnut Stree
_
S' nature Address
Dana C. Panagopoulos, Esquire
Lancaster, PA 17602
_
Printed Name City, State, ZIP Code
-------------------------------------------------------------------------------
-----------------------------------------------------------------------------------
FOR POST OFFICE USE ONLY ------------
,~ No change of address on file New Address or Boxholder Name and Street A ress
Moved and left no forwarding address
No such address
"~1 ,~
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t1SP`~
EXHIBIT C
To Robert S. Goodrich and Lisa Goodrich h/w
You are notified that the plaintiff, Susquehanna Bank has
commenced a civil action against you entered to docket number 12-2936 in the Court of
Common Pleas of Cumberland County, Pennsylvania, which you are required
to defend.
If you wish to defend, you must enter a written appearance personally or by attorney
file
your defenses or objections in writing with the court. You are warned that if you fail to do sd the case
may proceed without you and a judgment may be entered against you without further notice f~r the
relief requested by the Plaintiff. You may lose money or property or other rights important tc~ you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMAITON ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABL TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEG L
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
Dated:
BRUBAKER CONNAUGHTON GOSS & LUCARELLI
By:
Robert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 894941
CERTIFICATE OF SERVICE
I HERBY CERTIFY that I am this day serving the foregoing document upon the
person and in the manner indicated below:
Service via first class mail, as follows:
Robert S. Goodrich and Lisa Goodrich
218 S. Pebble Beach Boulevard
Sun City Center, Florida
BRUBAKER CONNAUGHTON GOSS & LUCARELLI LLC
Dated: August 10, 2012 By:
Panagopoulos, Esquire
I.D. No. PA 89491
T; Q,yONI c "ICINAL
2012 AUG 23 Phi 2: 19
-UMBERLAND COUNTY
PENNSYLVANIA
BRUBAKER CONNAUGHTON GOSS & LUCARELLI LLC
By: Robert W. Pontz, Esquire
Attorney I.D. No. 56554
D*na C. Panagopoulos, Esquire
A orney I.D. No. 89491
460 New Holland Ave, Suite 6205 Attorneys for Plaintiff:
Lancaster, PA 17602 Susquehanna Bank
SUSQUE ANNA BANK, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NO. 12-2936
ROBERT S. GOODRICH and
LISA GOODRICH, h/w
Defendants
AMENDED MOTION FOR AUTHORIZATION TO SERVE COMPLAINT
BY PUBLICATION PURSUANT TO PA.R.C.P. 430
No Judge has previously ruled upon any other issue in the same or related matter.
2. The undersigned has been unable to serve Defendant and, therefore has not sought
the concurrence of Defendants. The undersigned is unaware if Defendants have retained counsel
and there is no counsel of record.
WHEREFORE, Plaintiff and Movant, Susquehanna Bank, requests, pursuant to Pa.R.C.P.
430, entry of an Order in the form submitted with this Motion, permitting alternate service of the
Complaint described herein upon Defendants/Respondents, Robert S. Goodrich and Lisa
Goodrich.
BRUBAKER CONNAUGHTON GOSS & LUCARELLI LLC
Dated: ?Z By: 0 - _
??obert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 894941
3
OF THE FROIH011t t'J' T iii i
2012 AUG 23 AM 11: 19
CUMSERLARD COUNTY
`EI SYLVARIA
SUSQUEHANNA BANK,
vs.
Plaintiff
ROBERT S. GOODRICH and
LISA GOODRICH, h/w
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 12-2936
ORDER
AND NOW, this 131, of , 2012, upon consideration of
Plaintiff/Movant's Motion for Authorization to Serve Complaint by Publication Pursuant to
Pa.R.C.P. 430, it is ordered that the Motion is Granted. Plaintiff/Movant shall publish the
Notice, appended to the Motion as Exhibit C, one time each in The Tampa Tribune and the Gulf
Coast Business Review.
J.
;/ Nuot e. Ana5Op0.?0s.
Py ma, le
41
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BRUBAKER CONNAUGHTON GOSS & LUCARELLI LLC
By: Robert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 89491
460 New Holland Ave, Suite 6205 Attorneys for Plaintiff:
Lancaster, PA 17602 Susquehanna Bank
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SUSQUEHANNA BANK, IN THE COURT OF COMMC9N PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
vs.
ROBERT S. GOODRICH and
LISA GOODRICH, h/w
Defendants
NO. 12-2936
PA.RC.P. 403
The undersigned hereby certifies that pursuant to Pa.R.C.P. 403 a copy of the Complain
was served upon Defendants, Robert S. Goodrich and Lisa Goodrich, by certified rrlail, return
receipt requested on August 17, 2012 and received by Defendants, Robert S. Goodrich and Lis
Goodrich on August 24, 2012.
True and correct copies of the correspondence addressed to each Defendant and the
Return Receipt printouts are collectively attached hereto as Exhibit A.
Dated: p2 o~-C1 ~ ~ By:
BRUBAKER CONNAUGHTON DOSS & LUCARELLI
Robert W. Pontz, Esquire
Attorney I.D. No. 56554
Dana C. Panagopoulos, Esquire
Attorney I.D. No. 894941
EXHIBIT A
__./~~
v
LLC
BRUBAKER CONNAUGHTON
GOSS & LUCARELLI ~~c
ATTORNEYS AT IAW
Dana C. Panagopoulos, Esquire
Direct Dial: 717
August 17, 2012
SENT tllA CERTIFIED MAIL - RETURN RECEIPT
REQUESTED - NO. 701111 SO 00018844 0366
Mrs. Lisa Goodrich
218 S. Pebble Beach Blvd.
Sun City Center, FL 33573
Re: Susquehanna Bank v. Robert S and Lisa Goodrich
Case No. 12-2936
Dear Mrs. Goodrich:
Enclosed for service upon you is the Complaint filed in the Court of Common
Pleas of Cumberland County.
Please govern yourself accordingly.
Sincerely,
i
/~ A ~ f
i ~/~~((L
~-
ana C. Panagopoulos
DCPaIr
Enclosure
cc: Christina Frederickson, Legal Counsel
480 New Holland Avenue, Suite 6205, Lancaster, PA 17602
tel 717-945-5745 www.accL-LAw.coM 717-945-5764 faX
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STATUS Qr YOUR ITF. rA DATE 8 TIME I..OCATION FEATURES
Delivered August 24, 2012, 3:50 pm SUN CITY Certified Mail'"
CENTER, FL 33573
Processed through August 24, 2012, 1:52 am TAMPA.. FL 33630
'. USPS Sort Facility
Undeliverable as August 21.2012. 9:09 am SUN CITY
Adtlressed (:ENTER, FL 33573
Depart USPS Sort August 21; 2012 TAMPA, FL 33630
Facility
processed through August 21.. 2012, 2.16 am TAMPA. FL 33830
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~~~
v
LLC
BRUBAKER CONNAUGHTON
GOSS & LUCARELLI LLc
ATTORNEYS AT LAW
Dana C. Panagopculos, Esquire
August 17, 2012
SENT VIA CERTIFIED MAIL - RETURN RECEIPT
REQUESTED - NO. 701111 SO 0001 8844 03 73
Mr. Robert Goodrich
218 S. Pebble Beach Blvd.
Sun City Center, FL 33573
Direct Dial: 717-945•
Re: Susquehanna Bank v Robert S and Lisa Goodrich
Case No. 12-2936
Dear Mr. Goodrich:
Enclosed for service upon you is the Complaint filed in the Court of'Common
Pleas of Cumberland County.
Please govern yourself accordingly.
'ncerely,
;~ C~~G(
ana C. Panagopoulos
DCP:llr
Enclosure
cc: Christina Frederickson, Legal Counsel
480 New Holland Avenue, Suite 6205, Lancaster, PA 17602
tel 717-945-5745 WWW.BCGL-LAW.COM 717-945-5764 fax
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SERVICE aTATl1S Of YOUR ITEM DATE A TIME I..IJCATION rFATt1RES
'.. Delivered August 24, 2012, 3:51 pm SUN CITY Certified Mail'"
CENTER, FL 33573
,Processed through ,August 24, 2012, 1:52 am TAMPA, FL 33630
', USPS Sort Facility '.
'. Undeliverable as 'August 21, 2012, 5:09 am SUN CITY
', Addressed CENTER, FL 33573
'. Depart USPS Sort August Lt, 2012 TAMPA, FL 33630
', Facility ',
Processed through August 21.2012. 2:16 am ', TAMPA, FL 33630
USPS Sort Facility
Find
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IN THE COURT OF COMMOM PLEAS OF'
CUMBERLAND COUNTY, PENNSYLVANIA
Susquehanna Bank
Plaintiff, Case No.: 12-2936
v.
Robert S. Goodrich and
Lisa Goodrich -_
Defendants
SUGGESTION OF PENDING BANKRUPTCY PROCEEDINGS
A voluntary petition under Chapter 7 of the United States Bankru tcy Code was filed in the
Bankruptcy Court for the Middle District of Florida, Tampa Division, on ~'C f. o 1~-~ ~ , _ 1 _, 2012,
which case is captioned;
In re:
Robert Goodrich and
Lisa Goodrich
Chapter 7
Case No.: ~ • I•~ ~~K _ I ~- ~- 1,,, 1
The tiling of this Suggestion does not constitute a Notice of Appearance in these proceedings.
The undersigned represents the Defendant in connection with a federal bankruptcy case, as referenced
above, and is providing this Suggestion for informational purposes only.
Respectf y mitted,
G. Do ld olden, Fla. BarNo.: ()137080
don~r.~brandonlawyer.com
Joseph B. Battaglia, Fla. Bar No.: 008 i 99
joe@brandonlawyer.com
THE GOLDEN LAW GROUP
808 Oakfield Drive, Suite A
Brandon, Florida 33511
Telephone: (813) 413-8700
Facsimile: (813) 413-8701
Bankruptcy Counsel for Defendants
CERTIFICATE OF SERVICE
I HEREBY" CERTIFY THAT, on this _ ~ 1 day of ~_:(~~~,~° r 2012, a true and correct copy of the
foregoing has been provided via mail to; Attorney for Plaintiff; Brubaker Connaughton Cross &
Lucarelli, LI,C 480 New Holland Avenue, Suite 6205, Lancast , P 7602.
G. D al olden, Fla. Bar No.: 0137080
Jo h B.Battaglia, Fla. Bar No.: 0058 ] 99